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PRIVACY POLICY

​Last Updated: September 23, 2026

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INTRODUCTION

This Privacy Policy describes how Your Company ("we", "us", or "our") collects, uses, and shares information about you when you use https://enaka.co (the "Website").

By using our Website, you agree to the collection and use of information in accordance with this policy. We respect your privacy and are committed to protecting your personal data.

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INFORMATION WE COLLECT

We collect the following types of information:

  • Personal Information: Name, email address, and other contact details you provide when you contact us, request access.

  • Access Requests: Email address, request details, invite codes, and access verification events used to manage gated access.

  • Usage Data: IP address, browser type, device information, pages visited, time spent on pages, and other diagnostic data collected automatically.

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HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

  • To provide and maintain our Website

  • To notify you about changes to our Website or services

  • To provide customer support

  • To detect, prevent, and address technical issues

  • To communicate with you, including responding to your inquiries

  • To review access requests, issue invite codes, and verify access

  • To process transactions and send related information including purchase confirmations

  • To analyze usage patterns and improve our Website

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ACCESS REQUESTS AND INVITE CODES

We offer access via request-and-invite flows. When you request access, we collect your email address, request details, and access status. If approved, we issue an invite code that must match your email to verify access. We also log access verification events for security and auditing.

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COOKIES AND TRACKING

We use cookies and similar tracking technologies to track activity on our Website and hold certain information.

Types of Cookies We Use:

  • Essential Cookies: Required for the Website to function properly. These cannot be disabled.

  • Preference Cookies: Remember your settings and preferences for a better experience.

  • Analytics Cookies: Help us understand how visitors interact with our Website. We use Google Analytics for this purpose.

We also use localStorage in your browser to save in-progress tasks and preferences. You can clear this in your browser settings.

Managing Cookies: You can instruct your browser to refuse all cookies or indicate when a cookie is being sent. However, some features of our Website may not function properly without cookies.

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INFORMATION SHARING

We may share your information with third parties in the following circumstances:

  • Service Providers: We share information with vendors who help us operate our Website and provide services.

  • Legal Requirements: We may disclose information if required by law or in response to valid legal requests.

  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred.

  • With Your Consent: We may share information for other purposes with your explicit consent.

We do not sell your personal information.

We may sell or share personal information for cross-context behavioral advertising. You can opt out as described below.

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DATA SECURITY

We implement appropriate technical and organizational security measures to protect your personal information, including:

  • Encryption of data in transit using SSL/TLS

  • Secure storage of personal data

  • Regular security assessments

  • Access controls and authentication measures

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

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DATA RETENTION POLICY

We retain different categories of personal information for varying periods based on the purpose of collection, legal requirements, and legitimate business needs:

**Retention Schedule:**

| Data Category | Retention Period | Justification | |--------------|------------------|---------------| | Account Information | Duration of account + 2 years | Service provision and legal claims | | Transaction Records | 7 years (legal requirement) | Tax and accounting requirements | | Analytics Data | 26 months | Service improvement | | Marketing Data | Until consent withdrawn | Consent-based processing | | Support Records | 3 years after resolution | Quality assurance and dispute resolution | | Access Requests & Invites | 24 months | Access auditing |

**General Retention Policy:** As long as necessary

  • Securely delete the information from our active systems

  • Remove it from backups within 90 days

  • Or anonymize the data so it can no longer identify you

  • Comply with legal obligations

  • Resolve disputes

  • Enforce our agreements

  • Protect against fraud or abuse

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DATA BREACH NOTIFICATION

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

  • Notify affected individuals within 72 hours of becoming aware of the breach

  • Notify relevant supervisory authorities as required by applicable law (within 72 hours for GDPR)

  • Provide details about the nature of the breach, categories of data affected, and approximate number of individuals affected

  • Describe the likely consequences of the breach

  • Explain the measures taken or proposed to address the breach and mitigate potential adverse effects

We maintain incident response procedures to ensure timely detection, investigation, and response to potential data breaches.

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DO NOT TRACK DISCLOSURE

Do Not Track ("DNT") is a privacy preference you can set in your browser. When you turn on DNT, your browser sends a signal to websites requesting that they do not track your browsing activity.

Currently, we do not respond to DNT signals. This is because there is no industry-standard interpretation of how to respond to DNT signals. We will update this policy if a standard is established.

Regardless of DNT settings, you can opt out of analytics tracking using the methods described in the Cookies section above.

 

YOUR RIGHTS (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights under the General Data Protection Regulation (GDPR):

  • Right to Access: Request copies of your personal data

  • Right to Rectification: Request correction of inaccurate or incomplete data

  • Right to Erasure: Request deletion of your personal data ("right to be forgotten")

  • Right to Restrict Processing: Request limitation of processing of your data

  • Right to Data Portability: Request transfer of your data to another organization

  • Right to Object: Object to processing of your personal data

  • Right to Withdraw Consent: Withdraw consent at any time where we rely on consent

To exercise any of these rights, please contact us at info@enaka.co. We will respond within 30 days.

Legal Basis for Processing: We process your data based on the following legal grounds:

| Processing Purpose | Legal Basis | |-------------------|-------------| | Account Creation & Management | Necessary for contract performance (GDPR Art. 6(1)(b)) | | Analytics & Service Improvement | Our legitimate business interests (GDPR Art. 6(1)(f)) | | Marketing Communications | Your explicit consent (GDPR Art. 6(1)(a)) | | Payment Processing | Necessary for contract performance (GDPR Art. 6(1)(b)) | | Security & Fraud Prevention | Our legitimate business interests (GDPR Art. 6(1)(f)) | | Customer Support | Necessary for contract performance (GDPR Art. 6(1)(b)) | | Personalization | Your explicit consent (GDPR Art. 6(1)(a)) |

Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal data violates applicable law. You can find your local data protection authority at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

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DATA SUBJECT REQUEST PROCEDURE

We have established the following procedure for exercising your data protection rights:

**How to Submit a Request:**

Send an email to info@enaka.co with the subject line "Data Subject Request"

Specify which right you wish to exercise (access, rectification, erasure, portability, etc.)

Provide sufficient information to verify your identity and locate your data

  • Your full name and contact details

  • The specific data or processing activity your request relates to

  • Any relevant account identifiers or reference numbers

**Identity Verification:** To protect your privacy, we may need to verify your identity before processing your request. This may include requesting government-issued identification or other verification methods.

  • We will acknowledge your request within 72 hours

  • We will respond substantively within 30 days of receipt

  • Complex requests may require an extension of up to 60 additional days, in which case we will notify you

**Fees:** We do not charge a fee for processing legitimate data subject requests. However, we reserve the right to charge a reasonable fee for manifestly unfounded or excessive requests.

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CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

  • Right to Know: Request categories and specific pieces of personal information we collected

  • Right to Delete: Request deletion of your personal information (with legal exceptions)

  • Right to Correct: Request correction of inaccurate personal information

  • Right to Opt-Out of Sale/Sharing: Opt out of sale or sharing for cross-context behavioral advertising

  • Right to Non-Discrimination: We will not discriminate for exercising your rights

We may sell or share personal information for cross-context behavioral advertising.

We collect sensitive personal information and use it only as necessary to provide the Service.

How to Exercise Your Rights: Submit a request to info@enaka.co. We will verify your identity and respond within 45 days.

Authorized Agents: You may designate an authorized agent to make a request on your behalf. We will require proof of authorization.

  • Identifiers

  • Internet activity

  • Commercial information

  • Provide and maintain the Service

  • Review access requests and issue invite codes

  • Analytics and service improvement

  • Payment processing

  • Security and fraud prevention

  • Customer support

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ADDITIONAL STATE PRIVACY RIGHTS

STATE-SPECIFIC PRIVACY RIGHTS

We comply with the following state privacy laws:

Virginia - Virginia Consumer Data Protection Act (VCDPA) Effective: January 1, 2023

If you are a resident of Virginia, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out of Targeted Ads

  • Right to Opt-Out of Sale

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Colorado - Colorado Privacy Act (CPA) Effective: July 1, 2023

If you are a resident of Colorado, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out of Targeted Ads

  • Right to Opt-Out of Sale

  • Right to Opt-Out of Profiling

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Connecticut - Connecticut Data Privacy Act (CTDPA) Effective: July 1, 2023

If you are a resident of Connecticut, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Utah - Utah Consumer Privacy Act (UCPA) Effective: December 31, 2023

If you are a resident of Utah, you have the following rights:

  • Right to Access

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Texas - Texas Data Privacy and Security Act (TDPSA) Effective: July 1, 2024

If you are a resident of Texas, you have the following rights:

  • Right to Confirm

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Oregon - Oregon Consumer Data Privacy Act (OCDPA) Effective: July 1, 2024

If you are a resident of Oregon, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Montana - Montana Consumer Data Privacy Act (MTCDPA) Effective: October 1, 2024

If you are a resident of Montana, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Delaware - Delaware Personal Data Privacy Act (DPDPA) Effective: January 1, 2025

If you are a resident of Delaware, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Iowa - Iowa Consumer Data Protection Act (ICDPA) Effective: January 1, 2025

If you are a resident of Iowa, you have the following rights:

  • Right to Access

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

New Jersey - New Jersey Data Privacy Act (NJDPA) Effective: January 15, 2025

If you are a resident of New Jersey, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

New Hampshire - New Hampshire Privacy Act (NHPA) Effective: January 1, 2025

If you are a resident of New Hampshire, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Kentucky - Kentucky Consumer Data Protection Act (KCDPA) Effective: January 1, 2026

If you are a resident of Kentucky, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Maryland - Maryland Consumer Data Privacy Act (MCDPA) Effective: October 1, 2025

If you are a resident of Maryland, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Minnesota - Minnesota Consumer Data Privacy Act (MNDPA) Effective: July 31, 2025

If you are a resident of Minnesota, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

  • Right to Opt-Out of Profiling

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Nebraska - Nebraska Data Privacy Act (NDPA) Effective: January 1, 2025

If you are a resident of Nebraska, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Tennessee - Tennessee Information Protection Act (TIPA) Effective: July 1, 2025

If you are a resident of Tennessee, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

Indiana - Indiana Consumer Data Protection Act (INCDPA) Effective: January 1, 2026

If you are a resident of Indiana, you have the following rights:

  • Right to Access

  • Right to Correct

  • Right to Delete

  • Right to Portability

  • Right to Opt-Out

To exercise these rights, please contact us using the information provided in this Privacy Policy. We will respond to your request within the timeframe required by applicable law.

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UK GDPR RIGHTS

UK GDPR - RIGHTS FOR UNITED KINGDOM RESIDENTS

If you are a resident of the United Kingdom, you have specific rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018:

Your Rights Under UK GDPR:

  • Right to Be Informed: You have the right to be informed about how we collect and use your personal data

  • Right of Access: You can request a copy of the personal data we hold about you

  • Right to Rectification: You can request correction of inaccurate or incomplete personal data

  • Right to Erasure: You can request deletion of your personal data (the "right to be forgotten")

  • Right to Restrict Processing: You can request that we limit how we use your data

  • Right to Data Portability: You can request to receive your personal data in a structured, commonly used format

  • Right to Object: You can object to certain types of processing, including direct marketing

  • Rights Related to Automated Decision Making: You have rights regarding automated decision-making and profiling

  • Your consent

  • Performance of a contract with you

  • Compliance with legal obligations

  • Protection of vital interests

  • Performance of a task in the public interest

  • Our legitimate interests (where not overridden by your rights)

  • Standard Contractual Clauses (SCCs)

  • Transfers to countries with UK adequacy decisions

  • Other appropriate safeguards as required by UK GDPR

Supervisory Authority: Information Commissioner's Office (ICO) Website: https://ico.org.uk Helpline: 0303 123 1113

To exercise any of these rights, please contact us at info@enaka.co. We will respond to your request within one month. You also have the right to lodge a complaint with the ICO if you believe your rights have been violated.

 

LGPD RIGHTS (BRAZIL)

LGPD - DIREITOS DOS TITULARES DE DADOS (BRAZIL)

If you are a resident of Brazil, you have specific rights under the Lei Geral de Proteção de Dados (LGPD):

Your Rights (Direitos do Titular):

  • Right to Confirmation (Confirmação): Confirm whether we process your personal data

  • Right to Access (Acesso): Access your personal data held by us

  • Right to Correction (Correção): Request correction of incomplete, inaccurate, or outdated data

  • Right to Anonymization/Blocking/Deletion (Anonimização/Bloqueio/Eliminação): Request anonymization, blocking, or deletion of unnecessary or excessive data

  • Right to Data Portability (Portabilidade): Transfer your data to another service provider

  • Right to Deletion (Eliminação): Request deletion of data processed with your consent

  • Right to Information (Informação): Know which entities your data has been shared with

  • Right to Information on Consent (Informação sobre Consentimento): Be informed about the consequences of denying consent

  • Right to Revoke Consent (Revogação): Revoke your consent at any time

  • Consent provided by you

  • Compliance with legal or regulatory obligations

  • Execution of contracts or preliminary procedures

  • Exercise of rights in judicial, administrative, or arbitration proceedings

  • Protection of life or physical safety

  • Health protection procedures

  • Legitimate interests (when not overriding your rights)

  • Credit protection

Data Protection Officer (Encarregado): info@enaka.co

Supervisory Authority: Autoridade Nacional de Proteção de Dados (ANPD) Website: https://www.gov.br/anpd

To exercise any of these rights, please contact us at info@enaka.co. We will respond within the timeframe established by LGPD.

 

PIPEDA RIGHTS (CANADA)

PIPEDA - CANADIAN PRIVACY RIGHTS

If you are a resident of Canada, you have specific rights under the Personal Information Protection and Electronic Documents Act (PIPEDA):

Your Rights Under PIPEDA:

  • Right to Know: Understand what personal information we collect, why we collect it, and how it will be used

  • Right to Access: Request access to your personal information in our possession

  • Right to Correct: Request correction of inaccurate or incomplete information

  • Right to Withdraw Consent: Withdraw your consent to our collection, use, or disclosure of your information (subject to legal or contractual restrictions)

  • Right to Challenge Compliance: Challenge our compliance with PIPEDA

  • Right to Complain: File a complaint with the Office of the Privacy Commissioner of Canada

PIPEDA's 10 Fair Information Principles:

We are committed to the 10 fair information principles that form the basis of PIPEDA:

Accountability: We are responsible for personal information under our control

Identifying Purposes: We identify the purposes for collecting personal information

Consent: We obtain meaningful consent for collection, use, and disclosure

Limiting Collection: We limit collection to what is necessary

Limiting Use, Disclosure, and Retention: We use information only for stated purposes

Accuracy: We keep personal information accurate and up-to-date

Safeguards: We protect personal information with appropriate security measures

Openness: We make our privacy policies and practices available

Individual Access: We provide access to personal information upon request

Challenging Compliance: We have procedures to address complaints and challenges

Consent: Under PIPEDA, we obtain your consent before collecting, using, or disclosing your personal information. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.

Privacy Officer Contact: info@enaka.co

Supervisory Authority: Office of the Privacy Commissioner of Canada Website: https://www.priv.gc.ca

To exercise your rights or file a complaint, contact us at info@enaka.co. We will respond to access requests within 30 days.

 

CALOPPA RIGHTS (CALIFORNIA)

CALOPPA - CALIFORNIA ONLINE PRIVACY PROTECTION ACT

If you are a California resident visiting our website, you have rights under the California Online Privacy Protection Act (CalOPPA):

CalOPPA Requirements We Comply With:

  • Conspicuous Privacy Policy: Our privacy policy is conspicuously posted on our website

  • Categories of PII: We identify the categories of personally identifiable information collected

  • Third-Party Sharing: We disclose the categories of third parties with whom we share your information

  • Policy Changes: We describe our process for notifying users of material changes to our privacy policy

  • Effective Date: Our privacy policy includes its effective date

Do Not Track (DNT) Disclosure: We honor Do Not Track signals and do not track, plant cookies, or use advertising when a DNT browser mechanism is in place.

Supervisory Authority: California Attorney General Website: https://oag.ca.gov

To exercise your rights, contact us at info@enaka.co.

 

CHILDREN'S PRIVACY

Our Website is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. 

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CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of any changes by:

  • Posting the new Privacy Policy on this page

  • Updating the "Last Updated" date at the top

We encourage you to review this Privacy Policy periodically. Changes are effective immediately upon posting.

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CONTACT US

If you have any questions about this Privacy Policy or our data practices, please contact us:

info@enaka.co

https://enaka.co/contact

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