Enquero Inc. and our affiliated companies worldwide (“Enquero”, “we” or “us”) are a global professional services firm focused on delivering digital transformation for our customers. The reason we collect your personal data is to improve our services to you. We respect you and we are committed to honoring and protecting your privacy. This Customer’s Privacy Notice describes our approach to privacy and explains why we collect your personal data, what data we are collecting, how we collect, receive, use, share, transfer and process your personal data in connection with our services in the Netherlands, Canada, the United States and India. It also describes the choices you have regarding the use of your personal data, as well as your rights and how you execute these rights.
Where we determine the purpose and means of processing personal data, Enquero will be the data controller. Please note that the local Enquero entity you may interact with is the data controller for such interactions.
What Personal Data We Collect and How We Collect It
Enquero, may at times collect your personal data in one of the following ways:
By providing us with information such as your name, and email address, country of residence, company you represent, industry and details of an inquiry on our Contacts page as well as other forms throughout our website, you enable us to respond to a general/ business inquiry made by you or on behalf of the company that you represent. If you wish to be contacted by telephone, we may also collect your provided phone number(s).
You may provide Enquero with information when subscribing to our newsletters, thought leadership content and/or marketing collateral on the website through contact us form. This data may include for example your name, email address and the company you represent. The form also keeps track of your areas of interest that you may have either opted into or opted out of.
E-mail Communications: If you are a recipient of our marketing communications, we may track whether you receive, open, click a link, or share an e-mail you receive from Enquero. To unsubscribe from Enquero marketing communications, please email us at [email protected]
Information from other sources:
Enquero might receive information about you from other sources, such as public sources, social media, directories, registries to ensure the accuracy and completeness of your personal data.
- Information when you access Enquero content on our Third-Party Partner Website(s): From time to time, Enquero publishes thought leadership, marketing collateral and webinars on third-party website platforms. By accessing Enquero content, we may collect your name, email address, contact number, designation/job role, company you represent and any other Enquero content/ links accessed.
- Corporate Marketing and Thought Leadership Events: From time to time, Enquero may host various sales, marketing and thought leadership events. Enquero may collect your name, email address, contact number, designation/job role and the company you represent from such events. Additionally, Enquero sales executives and business leaders may visit similar events conducted by other companies or forums. As part of these events, Enquero sales executive and business leaders may receive business cards from you in order to establish a working relationship with you on behalf of the customer you represent.
- Information obtained from Third-Party Business Contact Directory and Services: Enquero has carefully selected and contracted with third-party agencies providing business contact directory services and may obtain the name, title, company you represent, work phone number, work email address and work address of potential business contacts.
- Information obtained from our Business Leaders: Enquero may receive information related to your name, company you represent, designation/job role and email address from business leaders who have established professional/ personal connections with you.
- Information obtained from public sources and professional networking platforms: Enquero may also collect information related to your name, company you represent, designation/job role, and email address from public sources (where available) or professional network platforms such as LinkedIn. .
- Information received prior to/during fulfilment of contractual services: This may include for example your name, designation/job role, company you represent, telephone number and email address that you provide Enquero with during the Request for Proposal stage, proposal discussions, contract negotiations and/or the duration of time for which Enquero provides the customer with services.
- Information to facilitate visits, travel and lodging: from time to time, Enquero also provide assistance to our customers’ representatives visiting our premises by facilitating travel and accommodation. In such cases, Enquero would collect your name, date of birth, contact number, company you represent, email address, travel and accommodation preferences, passport and visa details. Enquero may engage carefully selected third-party vendors or applications to collect & process these details, as permitted under and in accordance with applicable laws.
Purpose and Lawful Basis for Processing Personal Data
Enquero will only process personal data if this is in accordance with applicable laws. The legal bases listed below are based on the European Union General Data Protection Regulation, Canada, and the United States, but may differ pursuant to local laws in Canada, United States and India.
- We rely on your consent for example to send you marketing communications. Where we require your consent, you will find opt-in mechanisms. Subject to exceptions, such as when personal data is necessary to satisfy a legal requirement or provide the service, you have the ability to withdraw consent.; see the section “Data Subject Rights” below. Please note that the withdrawal of consent may restrict our ability to provide a particular service.
- Where we need to perform the contract, we are about to enter into or have entered into with you. For example, when we perform our services to you. Entering into a contract with us may include is having to verify your identity, communicating with you and arranging the provision of services and managing our internal administration. To carry out the services for which Enquero has been contracted by the customer you represent to deliver, and to contact you for customer care related purposes including regular communication regarding project status, notifying issues/concerns, sharing project deliverables and carrying out day-to-day project activities, in order to comply with Enquero contractual obligations towards the customer you represent.
- Where we need to comply with a legal or regulatory obligation and for our legitimate purpose of protection our legal rights, for example, in connection with legal claims, compliance, regulatory, investigative purposes. This may include maintaining records, compliance checks or screening and recording (e.g. anti-money laundering, financial and credit checks, fraud and crime prevention and detection, trade sanctions and embargo laws). This may include automated checks of personal data you provide about your identity against relevant databases and contacting you to confirm your identity or making records of our communications with you for compliance purposes.
- We also process data for our legitimate interests of market research purposes, marketing purposes and appropriate controls to ensure our website, processes and procedures are running effectively for the prevention and detention of against fraud and for IT security purposes.
- To contact you in order to inform you of new products, services or promotions Enquero may offer including to keep you appraised of our thought leadership and marketing collateral and to better assist your needs, in pursuit of our legitimate business interests of conducting marketing and on occasion with your consent. If you are a prospective customer, we will seek your consent before we contact you with such information.
- To invite you to Enquero hosted or sponsored events in your geographical region that may be of interest to you based on your role within the company and/or industry, in pursuit of our legitimate business interests of business development and promotion. If you are a prospective customer, we will seek your consent before sending such invite to you.
- To conduct market research and to carry out marketing campaigns, in pursuit of Enquero, legitimate business interests of conducting marketing and research. If you are a prospective customer, we will seek your consent, if feasible, before conducting such market research and carrying out such marketing campaigns.
- In certain cases, Enquero may record the conversations/ interactions with you and Enquero representatives during Request for Proposal/ Proposal discussions, trainings, transition workshops or project discussions that may be carried out over Voice over IP (VoIP) sessions for future reference and training. Enquero will always inform you and obtain your verbal consent prior to recording any such sessions.
- Enquero engages carefully selected third-party vendors to conduct surveys to receive feedback from you on the services currently provided by Enquero to the company you represent. We may also share your information with such third-party vendors to conduct anonymous survey to understand your perception about our brand. Enquero uses your responses to better understand our strengths and identify improvement areas. This will help us serve the company you represent better and improve our overall service offerings and business strategies, in pursuit of our legitimate business interests.
- To develop new and improved products and services to help us serve the company you represent better and to improve Enquero overall service offerings in pursuit of our legitimate business interests.
Where we process your data on the basis of legitimate interests, you can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us via contact us form.
You also have the option to subscribe/opt-in to receive thought leadership content and/or marketing collateral. You can always write to [email protected] and we shall adhere to your preferences.
Enquero implements industry standard security measures to keep your personal data secure and confidential, including but not limited to:
- Restriction of access to your personal data to Enquero employees strictly on a need to know basis, such as responding to an inquiry or request.
- Implementation of physical, electronic, administrative, technical and procedural safeguards that comply with all applicable rules, laws, legislation and regulations to protect your personal data from unauthorized or inappropriate access, alteration, disclosure and/or destruction.
Who We May Share Your Personal Data With
- The personal data Enquero collects from you is stored in one or more databases hosted by service providers. These third-parties do not use or have access to your personal data for any purpose other than cloud storage and retrieval.
- Enquero has offices and operations in a number of international locations, and we share information between our group companies, including our parent company Genpact, for business and administrative purposes. Please visit about-us locations and about-us regions to see a list of the locations within our corporate group.
- Where required or permitted by law, information may be provided to others, such as but not limited to regulators, under legal process, enforceable government directives.
International and Group Company Transfers of Personal Data
We are part of an international group of companies and, as such, transfer personal data concerning you to countries outside the European Economic Area (EEA). Please visit about-us locations and about-us regions to see a list of the locations within our corporate group.
We transfer personal data between our group companies and data centers for the purposes described above. We may also transfer personal data to our third-party vendors outside of the EEA as described above.
Your personal data may be stored in databases located outside of the EEA including in India. The database is controlled by our administrative staff located outside of the EEA including in India and can be accessed electronically.
Where we transfer personal data outside of EEA, we either transfer personal data to countries that provide an adequate level of protection as determined by the European Commission or we have appropriate safeguards in place. Appropriate safeguards to cover these transfers are in the form of standard contractual/data protection clauses adopted by the European Commission. Please visit here to know more about standard contractual/data protection clauses.
Where we transfer personal data between our group companies, we have covered these transfers by entering into standard contractual clauses adopted by the European Commission. If you would like more information on any of the data transfer mechanisms on which we rely please contact our Data Protection Officer details available in the contact section below.
Data Storage and Retention
Enquero shall retain your personal data as required for the business purposes described above. We will only keep your personal data for as long as is reasonably necessary taking into consideration our purposes outlined above or to comply with legal, accounting or reporting requirements under applicable law(s).
For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact [email protected]
Data Subject Rights
Residents of California and Virginia:
Please note that Enquero does not sell or share personal information as defined in sections 1798.140(t) and 1798.140(ah)(1) of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act. Enquero also does not sell the personal information of children under age 16.
Depending on your state of residency, you may have the ability to exercise all or some of the following rights, subject to any exemptions or exceptions in applicable law:
- The right to access what personal information has been collected about you by making a proper Verifiable Consumer Request (VCR). Through a VCR, you may request:
- The categories of personal information collected about you in the preceding 12 months;
- The categories of sources from which personal information is collected;
- The business or commercial purpose for collecting personal information;
- The categories of third parties with whom Genpact shares personal information; and
- Specific pieces of personal information collected about you.
- The right to request deletion of personal information that has been collected about you, subject to certain exceptions.
- The right to request that your personal information be transferred to a third party.
- The right to correct inaccurate personal information, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- The right, if applicable, to restrict sensitive personal information processing.
- The right to non-discrimination against you for exercising any of the rights listed above.
You may exercise your rights with respect to your personal information by submitting a VCR by email to [email protected] or by calling 1 (888) 914-9661 and entering in the following ID: 112797. You may designate an authorized agent to make a request on your behalf if necessary. We will use reasonable methods to verify your identity when receiving a request. If collecting new information is necessary to verify your identity, it will only be used for identity purposes; and will be deleted as soon as practical after processing the request and to comply with recordkeeping obligations. To the extent possible, we will provide you with your personal information in a format that you can share with other businesses.
Enquero will respond to a VCR within 45 days. Should we require more time, Enquero will notify you of the extension period and the reason for the extension in writing. In some situations and subject to certain exemptions, we may decline a request to exercise the rights above, particularly if we are unable to validate your identity. Depending on your state of residency, you may have the ability to appeal a decision we have made in connection with your VCR.
Residents of Canada have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA) or if applicable, certain provincial laws:
- The right to know why your personal information will be collected, used, and/or disclosed.
- The right to withdraw consent (where consent was required) to the collection, use, disclosure of your personal information at any time, subject to legal and contractual restrictions and reasonable notice.
- The right to require that your personal information is accurate, complete, and up-to-date. If the information is inaccurate, incomplete and/or out-of-date, you have the right to request that it is corrected.
- The right to request access to your personal information.
- The right to address a challenge concerning compliance with the above rights to the designated individual accountable for Genpact’s compliance.
If you are a resident of the EEA , you may have certain rights relating to your personal data provided under the GDPR. These include the right to:
- Request access to your personal data and request details of the processing activities conducted by Enquero.
- Request that your personal data is rectified if it is inaccurate or incomplete
- Request erasure of your personal data in certain circumstances.
- Request restriction of the processing of your personal data in certain circumstances
- Object to the processing of your personal data in certain circumstances.
- Receive your personal data provided to us as a controller in a structured, commonly used and machine-readable format in certain circumstances.
- Object to, and not to be subject to a decision based solely on, automated processing (including profiling), which produces legal effects or significantly affects you and
- Where we have asked for your consent to process your personal data, withdraw your consent provided at any time by contacting us.
These rights may be limited in some situations – for example, where we can demonstrate that Enquero has a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.
Where Enquero requires personal data to comply with legal or contractual obligations, then provision of such data is necessary: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.
In the event you have unresolved concerns, you also have the right to lodge a complaint with the data protection authority where you work, normally live or where the alleged infringement of data protection laws has occurred. We hope this will not be necessary and would like to assure you we will do our best to resolve any dissatisfaction you may have.
To exercise the rights outlined above in respect of your personal data you may write to us at [email protected]
If you have any questions or about this Website Privacy Notice or (on how to exercise the rights outlined above in respect of) your personal data, please contact us at [email protected]
Changes to our Customer’s Privacy Notice
This Customer’s Privacy Notice was last updated in December 2022 and Enquero will notify you of changes we may make to this privacy notice where required, however we would recommend that you look back at this notice from time to time to check for any updates.