Privacy Policy

1. Introduction

At Enocus Limited ("us", "we", "our" or the "Company") we value your privacy and the importance of safeguarding your data. This Privacy Policy (the "Policy") describes our privacy practices for the activities set out below. As per your rights, we inform you how we collect, store, access, and otherwise process information relating to individuals. In this Policy, personal data ("Personal Data") refers to any information that on its own, or in combination with other available information, can identify an individual.

The office locations of where Enocus Limited can be found https://enocus.com

We are committed to protecting your privacy in accordance with the highest level of privacy regulation. As such, we strive to align our practices with applicable global regulations, which may include, where we meet the legal regulatory thresholds:

• The EU's and UK's General Data Protection Regulation (GDPR)
• Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and the applicable provincial legislations
• Quebec Law 25
• Brazil’s Data Protection Legislation (LGPD)
• Applicable United States comprehensive state privacy laws (such as the California Consumer Privacy Act (CCPA), where statutory thresholds are met)
• South Africa’s Protection of Personal Information Act (POPIA)
• Switzerland's Federal Act on Data Protection (FADP)
• Saudi Arabia's Personal Data Protection Law (PDPL)

Scope

This policy applies to the Enocus Limited websites, domains, applications, services, and products. This Policy does not, however, extend to third-party applications, websites, products, services, or platforms that may be accessed via links provided by Enocus Limited. These third-party sites operate independently and have their own privacy and data collection practices, for which Enocus Limited cannot accept liability or responsibility.

Processing Activities

This Policy applies when you interact with us by doing any of the following:

• Make use of our application and services as an authorized user
• Visit any of our websites that link to this Privacy Statement

2. Personal Data We Collect

What Personal Data We Collect

• Account and Billing Profile Information: When you create an account or prepare to subscribe, we collect your Profile Details (such as first and last name, email address, physical address, and phone number) and Billing Details (such as company name, Tax ID/VAT number, Company Registration Number, and billing address) directly through our platform forms. We use this data to manage your account and share it with our Merchant of Record (Stripe) to provision your customer profile, determine applicable taxes, and apply correct regional pricing.
• Financial Payment Information: When you finalize a purchase, your actual payment credentials (such as full credit card numbers, CVV, or connected bank account details) are collected and processed directly and exclusively by our Merchant of Record, Stripe (via the "Link" checkout service). Enocus Limited does not collect, store, or have direct access to your financial payment credentials.

How We Collect Your Personal Data

We collect Personal Data from the following sources:

• From You: You may give us your Account Information, Payment Information, Financial Information, Demographic Data, Purchase Information, Content, Feedback, Product Information, by filling in forms, using our products or services, entering information online or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide, for example, when you:
  • Create an account or purchase products on our website;
  • Use our products or services;
  • Create content through our products or services;
  • Express interest in our products or services;
  • Downloading software and/or our mobile application;
  • Subscribe to our newsletter;
  • Complete a voluntary market research survey;
  • Contact us with an inquiry or to report a problem (by phone, email, social media, or messaging service);
  • When you log in to our website via social media;
• Automated technologies or interactions: As you interact with our website, we may automatically collect the following types of data (all as described above): Device Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie section (below) for further details.
• Third parties: We may receive Personal Data about you from various third parties, including:
  • Account Information and Payment Information from another individual when they purchase a gift for you on our website;
  • Device and Usage Data from third parties, including analytics providers such as Google. For our "Web Radio Players" product, this includes analytics data such as the country of listeners and duration of sessions, which helps us understand product usage and improve our services.
  • Account Information and Payment Data from social media platforms when you log in to our website using such social media platforms;
  • Content from communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks;
  • Account Information and Payment Data from third parties, including organizations (such as law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction; and
  • Account Information, Payment Data, and Financial Data from providers of technical, payment and delivery services.

If you provide us, or our service providers, with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Policy. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact us by using the information set out in the "Contact us" section below.

Device and Usage Data

When you visit an Enocus Limited website, we automatically collect and store information about your visit using browser cookies (files which are sent by us to your computer), or similar technology. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help Feature on most browsers will provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on. We also process information when you use our services and products. This information may include:

• Login information
• Location information

Data we collect from third parties: We may receive your Personal Data from third parties such as companies subscribing to Enocus Limited services, partners and other sources. This Personal Data is not collected by us but by a third party and is subject to the relevant third party’s own separate privacy and data collection policies. We do not have any control or input on how your Personal Data is handled by third parties. As always, you have the right to review and rectify this information. If you have any questions you should first contact the relevant third party for further information about your Personal Data. Where that third party is unresponsive to your rights, you may contact the Data Protection Officer at Enocus Limited (contact details below). Our websites and services may contain links to other websites, applications and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties’ privacy statements, which you should review to better understand those third parties’ privacy practices.

Purpose and Legal Basis for the Processing of Personal Data

We collect and use your Personal Data with your consent to provide, maintain, and develop our products and services and understand how to improve them. These purposes include:

• Building a Safe and Secure Environment: To verify or authenticate your identity; and Investigate and prevent security incidents such as breaches, attacks and hacks

Where we process your Personal Data to provide a product or service, we do so because it is necessary to perform contractual obligations.

All of the above processing is necessary in our legitimate interests to provide products and services and to maintain our relationship with you and to protect our business for example against fraud.

Consent will be required to initiate services with you. New consent will be required if any changes are made to the type of data collected. Within our contract, if you fail to provide consent, some services may not be available to you.

Third Party Tools

We use these third party tools to store your information:

• Stripe (and Link): We use Stripe's Managed Payments service as our Merchant of Record to securely handle all checkout and subscription billing. Because Stripe is legally executing the financial sale to you, they act as an independent Data Controller for your sensitive payment information, processing it according to their own Privacy Policy. We maintain necessary data sharing agreements with Stripe to receive the order fulfillment data required to provide you with our services securely and in compliance with applicable data protection laws.

International Data Transfer and Storage

Where possible, we store and process data on servers within the general geographical region where you reside (note: this may not be within the country in which you reside). Specifically, for European based companies, we have servers in the European Economic Area (EEA). Your Personal Data may also be transferred to, and maintained on, servers residing outside of your state, province, country or other governmental jurisdiction where the data laws may differ from those in your jurisdiction. We will take appropriate steps to ensure that your Personal Data is treated securely and in accordance with this Policy as well as applicable data protection law. Data may be kept in other countries that are considered adequate under your laws. For transfers to countries not deemed to provide an adequate level of data protection, we rely on appropriate safeguards such as the EU Standard Contractual Clauses (SCCs) to ensure your data is protected to the same standards as within the EEA. More information about these clauses can be found here: (https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32021D0914)

Sharing and Disclosure

We will share your Personal Data with third parties only in the ways set out in this Policy or set out at the point when the Personal Data is collected.

• Legal Requirement: We may use or disclose your Personal Data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical to do so, we will tell you in advance of such disclosure.
• Service Providers and Other Third Parties: We may use a third party service provider, independent contractors, agencies, or consultants to deliver and help us improve our products and services. We may share your Personal Data with marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others but only to maintain and improve our products and services. For further information on the recipients of your Personal Data, please contact us by using the information in the "Contact us" section below.

Our Role in Processing Client End-User Data

When our clients utilize the analytics features within the "Web Radio Players" service (e.g., to track current connections, geographical listener distribution, session duration of their end-users), Enocus Limited acts as a Data Processor for the personal data collected from these end-users. In this capacity, we process such data strictly on behalf of and according to the instructions of our clients.

Our clients, as the owners and operators of their respective radio stations and websites, are the Data Controllers for the personal data collected from their end-users via our players and hosted sites. They determine the purposes and means of processing this data. Accordingly, our clients are solely responsible for:

• Ensuring they have a lawful basis (e.g., obtaining necessary consents or relying on legitimate interests) for collecting and processing their end-users' data through our service.
• Providing their own comprehensive and legally compliant privacy policies to their end-users, clearly informing them about the data collection practices, including the use of third-party analytics services (like ours).
• Responding to requests from their end-users regarding their data rights (e.g., access, rectification, erasure).

We commit to processing this data securely and in accordance with applicable data protection laws, as outlined in this Privacy Policy and our agreements with our clients.

3. Cookies

We use cookies and similar tracking technologies to track activity on our Website and Service and to store certain information. Cookies are small files with information that your browser stores on your device. This information helps in the function of the site and is used to improve your experience.

For detailed information on the specific cookies we use, the purposes for which we use them, and how you can manage your cookie preferences, please see our dedicated Cookie Policy.

4. Retention & Deletion

We will only retain your Personal Data for as long as necessary for the purpose for which that data was collected and to the extent required by applicable law. When we no longer need Personal Data, we will remove it from our systems and/or take steps to anonymize it.

5. Merger or Acquisition

If we are involved in a merger, acquisition or asset sale, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy. Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

6. How We Keep Your Data Safe

We have appropriate organizational safeguards and security measures in place to protect your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. The communication between your browser and our website uses a secure encrypted connection wherever your Personal Data is involved. We require any third party who is contracted to process your Personal Data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law. In the unfortunate event of a Personal Data breach, we will notify you and any applicable regulator when we are legally required to do so.

7. Children's Privacy

We do not knowingly collect Personal Data from children under the age of 18 Years.

8. Your Rights for Your Personal Data

Depending on your geographical location and citizenship, your rights are subject to local data privacy regulations. These rights may include:

• Right to be Forgotten (right to erasure) (Subject to applicable local laws, such as the GDPR or applicable US state privacy laws): You have the right to request that we delete Personal Data that we process about you, unless we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
• Right to Restriction of Processing: You have the right to restrict our processing of your Personal Data under certain circumstances. In this case, we will not process your Data for any purpose other than storing it.
• Right to Portability: You have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to transmit such Personal Data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you or the third party that subscribes to services.
• Right to Opt Out: You have the right to opt out of the processing of your Personal Data for purposes of: (1) Targeted advertising; (2) The sale of Personal Data; and/or (3) Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Under certain applicable privacy laws (such as in California), you have the right to opt out of the sharing of your Personal Data to third parties and our use and disclosure of your Sensitive Personal Data to uses necessary to provide the products and services reasonably expected by you.
• Right to Objection: Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for processing which override your interests and rights, or if we need to continue to process the Personal Data for the establishment, exercise or defense of a legal claim.
• Nondiscrimination and nonretaliation: You have the right not to be denied service or have an altered experience for exercising your rights.
• File an Appeal: You have the right to file an appeal based on our response to you exercising any of these rights.
• File a Complaint: You have the right to bring a claim before their competent data protection authority. If you are based in the EEA, please visit this website for a list of local data protection authorities.
• Withdrawing Consent: If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge, such as where you wish to opt out from marketing messages that you receive from us. If you wish to withdraw your consent, please contact us using the information found at the bottom of this page.

How to Exercise Your Rights

You can make a request to exercise any of these rights in relation to your Personal Data by contacting our privacy team via email at [email protected]. For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information.

9. Changes

We may modify this Policy at any time. If we make changes to this Policy then we will post an updated version of this Policy at this website. When using our services, you will be asked to review and accept our Privacy Policy. In this manner, we may record your acceptance and notify you of any future changes to this Policy.

10. Contact Information

To request a copy for your information, unsubscribe from our email list, request for your data to be deleted, or ask a question about your data privacy, we've made the process simple:

Write to us at:

Last Updated: April 17, 2026