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PRIVACY NOTICE

Privacy notice
* Terms and conditions
* Privacy notice
* Coupon terms and conditions
* Gift card notice
* Affiliate Terms and Conditions
* Affiliate Privacy policy
* Vendor Fee and Commission Terms and Conditions
* Cashback Terms and Conditions
* Enebium Club Loyalty Program Terms and Conditions
* Auto Renew Terms and Conditions
* Mystery Gift Terms and Conditions
* Snakzy Terms and Conditions

Version 1.7, last amended 2023-01-11

In this privacy Notice we, UAB Helis Play, legal entity’s code 304923415, with
our registered office at Gyneju St. 4-333, Vilnius, the Republic of Lithuania
(“ENEBA”), explain how we handle your personal data when you visit ENEBA website
(www.eneba.com) and use ENEBA Mobile app (together referred to as “Platform”)
and use our services. All personal data are processed in accordance with the
General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable local
EU Member State and/or other national data protection law.

We will ask you to consent (or not – it’s up to you) to our use of cookies in
accordance with the terms of this notice when you first visit our platform.

Our platform incorporates privacy controls which provide you with controls on
deciding how we will process your personal data. By using privacy controls, you
can specify whether you would like to receive direct marketing communications.

In this notice you will find the answers to the following questions:

1. how we use your data;
2. when we provide your data to others;
3. how long we store your data;
4. what is our marketing policy;
5. what rights related to personal data you possess;
6. how we use cookies;
7. other issues that you should take into account.

In case of any inquiries or if you would like to exercise any of your rights
provided in this notice, you may submit such inquiries and requests by means
provided in Contacts section.

You may contact us regarding all privacy-related issues by
email: privacy@eneba.com.

In the event, Privacy Notice is translated into other languages and if there are
differences between the English version and such translation, the English
version shall prevail, unless otherwise provided.

Please also note that when you use ENEBA Mobile App, Mobile App Privacy Policy
also applies.

General data protection principles and confidentiality

ENEBA shall process all personal data adhering to the general data processing
principles:

* lawfully, fairly and in a transparent manner in relation to the data subject
(lawfulness, fairness, and transparency);
* collect and process personal data only for specified, explicit, and
legitimate purposes and not further processed in a manner that is
incompatible with those purposes (purpose limitation);
* ensure that personal data is adequate, relevant and limited to what is
necessary for relation to the purposes for which they are processed (data
minimization);
* ensure that personal data is accurate and, where necessary, kept up to date
(accuracy);
* ensure that personal data is kept in a form which permits identification of
data subjects for no longer than is necessary for the purposes for which the
personal data are processed (storage limitation);
* process personal data in a manner that ensures appropriate security of the
personal data, including protection against unauthorized or unlawful
processing and against accidental loss, destruction or damage, using
appropriate technical or organizational measures (integrity and
confidentiality).

All and any information processed by ENEBA is treated as strictly confidential.
All information is stored securely and is accessed by qualified and authorized
personnel only.

1. How we use your personal data?

This section provides the following information:

* categories of personal data, that we process;
* in case the personal data that we did not obtain directly from you, the
source and specific categories of that data;
* the purposes for which we may process your personal data; and
* the legal bases of the processing.

So, what personal data do we collect and why?

1. We process data about your use of our Platform and services (“usage
data”). The usage data may include your IP address, geographical
location, browser type, and version, operating system, referral source,
length of visit, page views, and platform navigation paths, as well as
information about the timing, frequency, and pattern of your service
use. We obtain such data through the use of cookies and similar
technologies. We process such data to have a better understanding of
how you use our Platform and services. The legal basis for this
processing is our legitimate interest, namely monitoring and improving
our Platform, following usage trends, performing business analytics and
accommodating the services for the individual interests of every user.
2. We process your account data (“account data”). The account data may
include your name and email address, phone number, and other data that
you provide while registering as well as your purchase history. We
obtain such data directly from you. We process account data for the
purposes of operating our Platform, providing our services, ensuring
the security of our Platform and services, and communicating with you.
The legal basis for this processing is the performance of a contract
between you and us and/or taking steps, at your request, to enter into
such a contract as well as our legitimate interest, namely monitoring
and improving our Platform and services.
3. We process information relating to the provision of services by us to
you on our Platform (“transaction data”). The transaction data may
include your contact details, bank account details, and transaction
details. The transaction data is processed to assist in you supplying
or purchasing goods and provide services and keep proper records of
those transactions. The legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at
your request, to enter into such a contract and our legitimate
interests, namely the proper administration of our Platform and
business.
4. We process information related to anti-money laundering prevention
measures (“AML data”). AML data may additionally include address or
residence, ID documentation, including your photo, documents regarding
your source of wealth, utility bill, and others. In some cases, we are
required by the law to request such information to carry out “know your
client” obligations, and it is our legitimate interest to ensure, that
only trusted merchants are allowed to sell their products on the
Platform.
5. We have a dedicated fraud detection process in place to detect and
prevent any fraudulent transactions (“fraud detection data”). To ensure
timely risk and fraud detection, effective prevention of fraudulent
transactions and to improve our fraud detection process we collect and
process various account data, transaction data technical browser and
device information, usage data which allows us to determine whether
user’s actions demonstrate suspicious behavior (e. g. whether the user
is a bot, has attempted to defraud us in the past and similar
indications related to fraudulent behavior). Our internal system may
generate additional information such as unique identifiers in addition
to collected transaction, account, usage or other data. The legal basis
for this processing is our legitimate interests, namely to reduce
amount of fraudulent transactions and to comply with requirements of
payment service providers and card scheme operators.
6. We may process information that you provide to us for the purpose of
subscribing to our email messages and newsletters (“direct marketing
data”). The direct marketing data is processed to send you the relevant
messages and newsletters. The legal basis for this processing is your
consent. Also, if we have already sold goods or provided services for
you on our Platform and you do not object, we may also process
messaging data on the basis of our legitimate interest, namely seeking
to maintain and improve customer relations
7. We may process information relating to any communication that you send
to us (“correspondence data”). The correspondence data may include the
communication content and metadata associated with the communication.
In case of communication through our Platform, the Platform will
generate the metadata associated with communications made using the
Platform contact forms. The correspondence data is processed for the
purposes of communicating with you and record-keeping. The legal basis
for this processing is our legitimate interests, namely the proper
administration of our Platform and business, ensuring uniform and
high-quality consultation practice, and investigating disputes between
you and our employees.
8. When using our Eneba Chat feature, we process information on how you
use the feature and the content of your chats (“chat data”). The chat
data is processed in order to enable you the use of Eneba Chat feature,
as well as to ensure proper functionality of automatic chat filters,
used to detect language forbidden by the Eneba Chat Rules. The legal
basis for this processing is your consent, as the Eneba Chat feature is
completely optional, and you may use the Platform in its full capacity
without enabling the Eneba Chat feature.
9. We may process any of your personal data identified in this notice
where necessary for the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or
out-of-court procedure. The legal basis for this processing is our
legitimate interests, namely the protection and assertion of our legal
rights, your legal rights and the legal rights of others.
10. We may process any of your personal data identified in this notice
where necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks, or obtaining professional advice. The legal
basis for this processing is our legitimate interests, namely the
proper protection of our business against risks.
11. In addition to the specific purposes for which we may process your
personal data set out in this Section, we may also process any of your
personal data where such processing is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your
vital interests or the vital interests of another natural person.
2. When we provide your data to others?
1. We may disclose your personal data to your contracting party (Vendor,
Selling User or Buying User, depending on the case) insofar as
reasonably necessary for the performance of contract between you and
these third-parties or to comply with legal obligations.
2. We may disclose your personal data to any member of our group of
companies (including our subsidiaries, our ultimate holding company and
all its subsidiaries) insofar as reasonably necessary for the purposes
set out in this notice. Such may include internal administration
purposes as well as provision/sharing of IT services or data centres in
the group.
3. We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining
or maintaining insurance coverage, managing risks, obtaining
professional advice, or the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or
out-of-court procedure.
4. We may disclose your personal data to our anti-fraud, risks, and
compliance providers insofar as reasonably necessary for the purposes of
protecting your personal data and fulfilling our legal obligations.
5. We may disclose your personal data to our payment service providers. We
will share transaction data with our payment services providers only to
the extent necessary for the purposes of processing your payments,
transferring funds and dealing with complaints and queries relating to
such payments and transfers.
6. We may disclose your personal data to our shipping service providers. We
will share relevant delivery data (e.g. recipient’s name, contact
information and delivery address) only to the extent necessary for the
purposes of delivering purchased products and dealing with complaints
and queries relating to such deliveries. For more information, you can
access the service providers’ privacy policies or terms and conditions.
For example, if your shipment is processed using Vinted Go solutions,
then their Privacy Policy applies to the processing of your personal
data. If your shipment is delivered by Mondial Relay, then their General
Terms and Conditions apply to the processing of your personal data.
7. We may disclose your personal data to other service providers insofar as
it is reasonably necessary to provide specific services (including,
providers of servers and maintenance, email service providers,
newsletter sending service providers, consumer review websites and other
service providers). We take all the necessary measures to ensure that
such subcontractors would implement proper organisational and technical
measures to ensure security and privacy of your personal data.
8. In addition to the specific disclosures of personal data set out in this
Section, we may disclose your personal data where such disclosure is
necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital
interests of another natural person..
9. Some service providers indicated in this Section may be established
outside the Republic of Lithuania, European Union, and European Economic
Area (EEA). However, we always try to ensure that all of your data is
processed within EEA. Please note that personal data may be less
protected in non-EEA countries than in EEA countries. We closely monitor
the evolving case we law and guidelines of the Court of Justice of the
European Union and data protection supervisory authorities on transfers
outside the EEA, and carefully assess the conditions under which your
data is transferred and may be further processed and stored after
transfer to the above entities. To ensure the appropriate level of data
security and to guarantee the lawful transfer of data, we conclude
Standard Contractual Clauses approved by the European Commission or
ensure other grounds and conditions established by legal acts. We will
take all the necessary measures to ensure that your privacy will remain
properly secured and protected. To find out more information regarding
appropriate safeguards you may contact us via email: privacy@eneba.com.
3. How long we store your data?
1. Your personal data that we process for any purpose or purposes shall not
be kept for longer than is necessary for that purpose or those purposes.
In any case it shall be kept for no longer than:
1. account data will be retained for no longer than 5 (five) years
following your last action on the account;
2. transaction data will be retained for no longer than 10 (ten) years
following the end of provision of services
3. AML data will be retained as long as it is necessary to comply with
the related legal requirements;
4. fraud detection data will be retained as long as account data, or
longer if the User Account has been deemed as likely to commit fraud;
5. direct marketing will be retained for as long as your Account is
active unless you withdraw your consent earlier;
6. correspondence data will be retained for no longer than 6 (six)
months following the end of such communication.
7. chat data will be retained for as long as your Account is active
unless you withdraw your consent earlier
2. In some cases, it is not possible for us to specify in advance the
periods for which your personal data will be retained. I. e. usage
data will be retained for as much as will be necessary for the relevant
processing purposes.
3. Notwithstanding the other provisions of this Section, we may retain your
personal data.for a longer period of time than indicated, in cases
where:
1. it is necessary for our legitimate business interests, such as fraud
detection and prevention and enhancing safety. If ENEBA suspends your
User Account for safety and fraud prevention reasons, we may retain
certain information from that User Account to prevent that User from
opening a new User Account in the future;
2. it is necessary to comply with our legal obligations. ENEBA may keep
some of your information for tax, legal reporting and auditing
obligations;
3. it is necessary to resolve legal disputes;
4. it is necessary to enforce our agreements and/or pursue or protect
our legitimate interests;
5. as we protect Platform from accidental or malicious loss and
destruction, residual copies of your personal information may not be
removed from our backup systems for a limited period of time.
4. Marketing messages
1. In case you consent, we will send you marketing messages via email
and/or leave a notification in an Account to inform you on what we are
up to.
2. Also, if we already have provided services to you and you do not object
we will inform you about our other products that might interest you
including other information related to such.
3. You may opt-out of receiving marketing messages at any time.
4. You may do so by:
1. choosing the relevant link in any of our marketing messages;
2. contacting us via means provided in the Contacts section.
5. Upon you having fulfilled any of the provided actions we will update
your profile to ensure that you will not receive our marketing messages
in the future.
6. Please be informed that as our business activities consists of a network
of closely related services, it may take a few days until all the
systems are updated, thus you may continue to receive marketing messages
while we are still processing your request.
7. The opt-out of the marketing messages will not stop you from receiving
messages directly related to the provision of services, updates to our
terms and policies or other important messages related to the
functioning of the Platform.
5. Your rights
1. In this Section, we have summarised the rights that you have under data
protection laws. Some of the rights are complex thus we only provide
the main aspects of such rights. Accordingly, you should read the
relevant laws and guidance from the regulatory authorities for a full
explanation of these rights.
2. Your other principal rights under data protection law are the
following:
1. the right to access data;
2. the right to rectification (note that you may exercise most of this
right by logging to your account here;
3. the right to erasure of your personal data;
4. the right to restrict processing of your personal data;
5. the right to object to processing of your personal data;
6. the right to data portability;
7. the right to complain to a supervisory authority; and
8. the right to withdraw consent.
3. The right to access data. You have the right to confirmation as to
whether or not we process your personal data and, where we do, access
to the personal data, together with certain additional information.
That additional information includes details of the purposes of the
processing, the categories of personal data concerned and the
recipients of the personal data. Providing the rights and freedoms of
others are not affected, we will supply to you a copy of your personal
data. The first copy will be provided free of charge, but additional
copies may be subject to a reasonable fee.
4. The right to rectification. You have the right to have any inaccurate
personal data about you rectified and, taking into account the purposes
of the processing, to have any incomplete personal data about you
completed.
5. In some circumstances you have the right to the erasure of your
personal data. Those circumstances include when: (i) the personal data
are no longer necessary in relation to the purposes for which they were
collected or otherwise processed; (ii) you withdraw consent to
consent-based processing and there are no other legal basis to process
data; (iii) you object to the processing under certain rules of
applicable data protection laws; (iv) the processing is for direct
marketing purposes; or (v) the personal data have been unlawfully
processed. However, there are exclusions of the right to erasure. Such
exclusions include when processing is necessary: (i) for exercising the
right of freedom of expression and information; (ii) for compliance
with our legal obligation; or (iii) for the establishment, exercise or
defence of legal claims.
6. In some circumstances you have the right to restrict the processing of
your personal data. Those circumstances are when: (i) you contest the
accuracy of the personal data; (ii) processing is unlawful but you
oppose erasure; (iii) we no longer need the personal data for the
purposes of our processing, but you require personal data for the
establishment, exercise or defence of legal claims; and (iv) you have
objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to
store your personal data, however we will only further process such
data in any other way: (i) with your consent; (ii) for the
establishment, exercise or defence of legal claims; (iii) for the
protection of the rights of another person; or (iv) for reasons of
important public interest.
7. You have the right to object to our processing of your personal
data on grounds relating to your particular situation, but only to the
extent that the legal basis for the processing is that the processing
is necessary for: the performance of a task carried out in the public
interest or the purposes of the legitimate interests pursued by us or
by a third party. If you make such an objection, we will cease to
process the personal information unless we can demonstrate compelling
legitimate grounds for the processing which override your interests,
rights and freedoms, or the processing is for the establishment,
exercise or defence of legal claims.
8. You have the right to object to our processing of your personal data
for direct marketing purposes (including profiling for direct
marketing purposes). If you make such an objection, we will cease to
process your personal data for this purpose.
9. You have the right to object to our processing of your personal data
for scientific or historical research purposes or statistical
purposes on grounds relating to your particular situation, unless the
processing is necessary for the performance of a task carried out for
reasons of public interest.
10. The right to data portability. To the extent that the legal basis for
our processing of your personal data is:
1. consent; or
2. performance of a contract or steps to be taken at your request prior
to entering into a contract, necessary to enter into such,

11. If you consider that our processing of your personal information
infringes data protection laws, you have a legal right to lodge a
complaint with a supervisory authority responsible for data protection.
You may do so in the EU member state of your habitual residence, your
place of work or the place of the alleged infringement. Our data
processing is supervised by State Data Protection Inspectorate of the
Republic of Lithuania, registered office at L. Sapiegos St. 17,
LT-10312, www.vdai.lrv.lt.

12. To the extent that the legal basis for our processing of your personal
information is consent, you have the right to withdraw that consent at
any time. Withdrawal will not affect the lawfulness of processing
before the withdrawal.
13. In addition to specific measure provided in this Section or the
websitePlatform you may also exercise any of the rights indicated
herein by contacting us via Contacts. or via privacy@eneba.com.
6. About cookies

We use the cookies on our Platform, to customize the functioning of our
Platform as much as possible, and can contribute to ease of use when
navigating our Platform.

What is a cookie?
* A cookie is a small text file placed onto your device that enables our
Platform features and functionalities. For example, cookies enable us to
identify your device, secure your access to the Platform. They enable the
Platform to store the data, such as:
* Login data (IP address of the logging-in device, login time, location
from which the login is attempted);
* Type of browser;
* Demographic data (age group, gender);
* Data about the fact how you browse the Platform (which sections you
visit, what products are you interested in).
7. Cookies that we use

We use cookies of four main types, for the following purposes:

1. Necessary Cookies – these cookies are necessary for a website to
function and cannot be switched off in our systems. They are usually
only set in response to actions made by you which amount to a request
for services, such as setting your privacy preferences, logging in or
filling in forms. You can set your browser to block or alert you about
these cookies, but some parts of the site will not then work;
2. Analytical Cookies – these cookies allow us to count visits and traffic
sources, so we can measure and improve the performance of our site. They
help us know which pages are the most and least popular and see how
visitors move around the site. All information these cookies collect is
aggregated and therefore anonymous. If you do not allow these cookies,
we will not know when you have visited our site;
3. Preference cookies – these cookies enable a website to remember
information that changes the way the website behaves or looks, like your
preferred region.
4. Marketing cookies – these cookies may be set through our site by our
advertising partners. They may be used by those companies to build a
profile of your interests and show you relevant adverts on other sites.
They do not store directly personal information, but are based on
uniquely identifying your browser and internet device. If you do not
allow these cookies, you will experience less targeted advertising.
8. Cookies used by our service providers
1. Our service providers use cookies (third party cookies), and those
cookies may be stored on your computer when you visituse our
websitePlatform.
2. Complete list and description of cookies used on www.eneba.com may be
found by clicking Cookie Preferences link in the footer of the page.
9. How can you control cookies?
1. Most browsers allow you to refuse to accept cookies and to delete
cookies. The methods for doing so vary from browser to browser, and from
version to version. You can however obtain up-to-date information about
blocking and deleting cookies via information provided in the relevant
browser.support websites, for example Chrome; Firefox; Internet
Explorer; Safari; Edge. To learn more about how to manage cookies,
visit: http://www.allaboutcookies.org/manage-cookies/ or http://www.youronlinechoices.com/.
2. Blocking all cookies will have a negative impact upon the usability of
many websites.
3. If you block cookies, you will not be able to use all the features on
our Platform.
4. You can adjust your cookie preferences by clicking Cookie Preferences
link in the footer of the page.

10. Third Party Advertising

The Platform uses Google Adsense, an online advertising service provided by
Google. Google Adsense uses cookies, which are saved on your computer and
allow your usage of the Platform to be analyzed. Google Adsense uses "web
beacons" (small invisible graphics) to collect information. Web beacons
allow actions such as visitor traffic on the Platform to be recorded and
gathered. Information produced by the cookie and/or web beacon regarding
your use of this Platform (incl. your IP address) will be transferred to,
and saved on, a Google server in the US. Google will use this information
to evaluate your use of the Platform regarding ads shown on the Platform,
to compile for the Platform operator reports on Platform activity and ads,
and to provide further services related to Platform and Internet use.
Google may also make this information available to third parties insofar as
is statutorily required or where the third parties in question process this
data on Google's behalf. Google will never combine your IP address with
other data held by Google.

If you do not wish to receive any tailored advertising and/or wish to
opt-out of the capture and usage of your data, you can deactivate the use
of cookies by Google for such purposes by accessing Google's ad settings at
https://adssettings.google.com and adjusting the settings as required.
Please note that if you delete all cookies from your device, new cookies
may be stored by Google for these purposes, and you may therefore have to
renew your deactivation settings. Alternatively, you can deactivate the use
of third-party cookies by going to the deactivation page of the Network
Advertising Initiative at
http://www.networkadvertising.org/managing/opt_out.asp.

11. Third party websites

On the Platform you may find links to and from partner sites, information
sources and related party websites. Please take note that such third-party
website that you will visit by clicking on links have their own privacy
policies and we take no responsibility regarding such privacy policies. We
recommend familiarising with privacy policies of such websites before
providing any personal data to such.

12. Children personal data
1. Our Platform and services are targeted at persons over the age of 16 or
another age under respective country’s law which allow you to assume
responsibility for obligations emerging from contractual relations and
have a full capacity to take legal actions.
2. If we have reason to believe that we hold personal data of a person
under that age in our databases without having consent from the parent
rights holder, we will delete that personal data.
13. Updating your data

Please let us know if the personal information that we hold about you needs
to be corrected or updated.

14. Changes to the notice

Any changes to this notice will be published on the Platform and, in case
of material changes, we may inform you about such via email

REGION SPECIFIC RULES

Annex 1: US Privacy Notice

Version 1.1, effective as of 2023-09-04

This Annex applies to all Users from the United States of America (“Territory”)
(“US User”) who use ENEBA Platform. The following provisions shall apply to the
processing of US User personal data by Eneba US in addition to Eneba Privacy
Notice (“US Annex”). In case of any discrepancies between this US Annex and
Eneba Privacy Notice, the US Annex shall prevail in relation to matters relating
to the processing of US Users’ personal data.

1. Data controller of US User personal data
1. When a US User makes a purchase on the Platform, ENEBA transfers their
transaction data to Eneba Inc., a Delaware corporation, with its offices
at 1000 N. West street, Suite 1200, Wilmington, Delaware 19801 (“Eneba
US”) who will act as a data controller of such data.
2. Transaction data transferred to Eneba US may include information about
your order (purchased products, amounts paid), your contact information,
information necessary to determine tax rate(s)(IP address, ZIP code),
payment details (of your chosen payment method) and other similar
information necessary to process the transaction.
3. ENEBA transfers personal data and Eneba US collects and processes that
personal data for the purposes of conducting transactions with US Users,
facilitating payments from the US Users, providing customer service,
addressing US User complaints. Eneba US processes personal data on the
basis of contract between the US User and Eneba US, as well as legitimate
interests (ensuring provision of its services) and to comply with its
legal obligations.
4. ENEBA transfers personal data to Eneba US on the basis of Standard
Contractual Clauses, approved and implemented by the European
Commission’s Decision (EU) 2021/914 of 4 June 2021, (Module One: Transfer
controller to controller), ensuring adequate safeguards in accordance
with Art. 46 of the GDPR.
2. Transfer of US User personal data to other third parties
1. Eneba US may transfer US User personal data to:
1. payment service providers, to the extent necessary for the purposes of
processing your payments, transferring funds and dealing with
complaints and queries relating to such payments and transfers.
Payment service providers may then request you to provide additional
information necessary to complete the payment in accordance with that
payment service provider’s terms and conditions and/or privacy policy;
2. your contracting party (Vendor) insofar as reasonably necessary for
the performance of contract between you and these third-parties or to
comply with legal obligations;
3. other service providers insofar as it is reasonably necessary to
provide specific services (including, providers of servers and
maintenance, email service providers, newsletter sending service
providers, consumer review websites and other service providers).
4. our professional advisers insofar as reasonably necessary for the
purposes of obtaining or maintaining insurance coverage, managing
risks, obtaining professional advice, bookkeeping, tax compliance or
the establishment, exercise or defence of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure.
2. Eneba US takes all the necessary measures to ensure proper organisational
and technical measures to safeguard the security and privacy of your
personal data.
3. In addition to the specific disclosures of personal data set out in this
Section, Eneba US may disclose your personal data where such disclosure
is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital
interests of another natural person.
3. California Consumer Privacy Act provisions
1. Selling your personal data. ENEBA and Eneba US do not sell your personal
data to any third parties.
2. US User rights. In addition to data subject rights described in the
Privacy Notice, US Users have the following rights, which may be
exercised by contacting privacy@eneba.com:
1. Right to Know: You have the right to request information about the
personal information we have collected, used, and disclosed about you
in the past 12 months.
2. Right to Delete: You have the right to request the deletion of your
personal information.
3. Right to Opt-Out: If we sell personal information, you have the right
to opt-out of the sale of your personal information.
3. Non-discrimination. ENEBA and Eneba US will not discriminate against you
for exercising your CCPA rights. This includes denying services, charging
different prices, or providing a different level of quality.
4. General provisions
1. This US Annex may be updated from time to time. Any changes to this US
Annex will be published on the Platform and, in case of material changes,
we may inform you about such via email.

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