ENHENCER PRIVACY POLICY

Enhencer is the next generation of ad optimization tool specialized in finding the best target audience.

We value your data and we are committed to being transparent about the data we collect from you. In order to provide our services, we collect personal data from our users.

Enhencer, Yazılım A.Ş.

ODTU Teknokent İkizler Binası K1-2 Çankaya Ankara

https://enhencer.com/

This Privacy Policy applies to Enhencer INC (hereinafter‘’Enhencer’’), that provides a SaaS solution to improve your online ad campaigns and to help you reach people that guarantee more campaign sales on Meta, Google, and TikTok Ads. The terms ‘’we’’, or ‘’our’’ used in this Policy mean Enhencer as the context requires.

Enhencer places a strong emphasis on respecting the privacy of all individuals. We are dedicated to safeguarding the information of visitors to our website (hereinafter "Visitors"), where Enhencer functions as the data controller. Additionally, for entities that register to use Enhencer products and services via the website, referred to as (hereinafter "Customer"), we also prioritize data protection, extending this commitment to their visitors or customers, (hereinafter"Customer's Users)."

We function as the exclusive facilitator of transactions and operate as a data processor, strictly following the instructions provided by our customers. If you are a visitor or user of one of our customers, your inquiries and requests regarding data privacy should be directed to the customer, who serves as your data controller while you interact with their websites.

In order to ensure transparency, this privacy policy ("Privacy Policy") governs how we process personal data we collect or receive from or about you including, but not not limited to the following use cases:

• When you visit our Website
• When you create an account and when you log in to our product
• When we use the personal data of our Customers (e.g. contact details, payment information)
• When you embed Javascript snippet and set up your Google Tag Manager
• When you integrate Enhencer with your Ads Platforms
• AI Based Prediction Engine
• When you subscribe to the Enhencer Lookalike Feature
• When we acquire your personal data from third-party sources
• Providing Customer Support
• When you interact with us on our social media profiles and our blog (e.g., Facebook, Twitter, LinkedIn)

Table of contents:

1. Information We Collect and How We Process It
2. Retention and Security of Personal Data
3. Transfers of Personal data
4. Third Party Services
5. Your Rights
6. Use by Children
7. How we handle California Residents Personal Information
8. How to Contact Us

1. Information we collect and how we process it

When you visit our Website

Personal Data:

• IP address
• Browser type
• Operating system
• Referring URLs
• Your use of our website, and other clickstream data

Source:

• We obtain the personal data directly from you
• We obtain personal data from third parties

Purpose of Collecting:

• To provide certain features of the Website
• To enhance your user experience

Legal Basis:

• Legitimate interest (e.g., activity and session logs)
• Consent (e.g., marketing cookies)

Third Parties We Share Data With:

When you create an account and when you log in to our product

Personal Data:

• First name
• Last name
• Company
• Email address
• Phone number
• Google Account Name
• Shopify Account Name
• User Password
• Any other information that you provide us (e.g. in the context of product support)

Source:

• We obtain the personal data directly from you

Purpose of Collecting:

• To be able to create a user account / profile
• To be able to log in and use the service
• To perform activities within the product
• To receive notifications and to collaborate within the product
• To provide you with our services

Legal Basis:

• Processing is necessary for the performance of a contract

Retention Period:

Please refer to our cookie policy in order to see details regarding how we keep your data.

Retention Period:

Personal information that Enhencer processes on behalf of its Customers as a processor is retained for the period of time set forth in the Data Processing Agreement executed between Enhencer and its Customers.

Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

When we use the personal data of subscribers

Personal Data:

• Full name
• Email address
• Phone number
• Company
• Payment information
• Any other information that you decide to provide/supply us

Source:

• We obtain the personal data directly from you

Purpose of Collecting:

• To provide our products and services
• To perform the applicable agreement
• To communicate with our subscribers

Legal Basis:

• Processing is necessary for the performance of a contract to which the data subject is a party
• Compliance with a legal obligation

Third Parties We Share Data With:

Retention Period:

Personal information that Enhencer processes on behalf of its Customers as a processor is retained for the period of time set forth in the Data Processing Agreement executed between Enhencer and its Customers. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

AI Based Prediction Model Training to improve ROAS

We gather first-party behavioral data from our Customers' websites to enable real-time purchase predictions and the creation of exceptionally effective audience segments.

Personal Data:

• Merchant Domain
• Merchant Email
• Merchant Timezone
• Merchant Country
• Merchant Product
• Merchant Orders
• Meta Business Manager ID
• Meta Ad Account ID
• Meta User Token
• Meta Pixel ID
• Google ID Token
• Google Merchant Account
• Google Ads Account ID
• Campaign Information (Daily budget, campaign text)
• Campaign Results (Cost, Reach, Impressions, Purchases, CTR, CPM, ROAS)

Source:

• We obtain the personal data from the Pixel Tag and Javascript code running on your website
• We acquire personal data from advertising platforms through APIs that you have established.

Purpose of Collecting:

• To be able to run advertising campaigns on merchant’s behalf
• To be able to create an ad account
• To be able to track all the conversions achieved by Enhencer
• To send transactional and informational emails to the User
• To be able to set up the correct timezone and currency for ad accounts
• To be able to create and update the product catalog and improve ROAS by coming up with relevant audience suggestions
• To be able to create advertising campaigns on Meta, Instagram, Google, and Youtube on behalf of the user

Legal Basis:

• Processing is necessary for the performance of a contract to which the data subject is party

Retention Period:

Personal information that Enhencer processes on behalf of its Customers as a processor is retained for the period of time set forth in the Data Processing Agreement executed between Enhencer and its Customers. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

AI Based Prediction Model Training to improve ROAS

We gather first-party behavioral data from our Customers' websites to enable real-time purchase predictions and the creation of exceptionally effective audience segments.

Personal Data:

• Enhencer Unique ID
• Session Time
• User Country
• Home page scroll & clicks
• Listing page scroll & clicks
• Product page scroll & clicks
• Product categories and prices
• AddtoCart product lists
• Purchased product lists
• Custom Attributes (determined solely by Customer)
• Any other information that provided by the Customers

Source:

• We obtain the personal data from the Pixel Tag and Javascript code running on your website
• We acquire personal data from advertising platforms through APIs that you have established.

Purpose of Collecting:

• To utilize your customer information to optimize and enhance your advertising campaigns across various channels
• To be able to utilize predictive algorithms and real-time data analysis
• To be able to refine ad strategies based on real-time purchase propensity data
• To be able to achieve better results with the same budget or reduce ad spend while maintaining performance
• To be able to leverage your customer data to create custom targeting segments that enable precise audience targeting and tailored marketing efforts.
• To be able to offer tips, suggestions, and recommendations to help you optimize your advertising performance and achieve better results.
• To be able to analyze the collected data to provide you with valuable insights regarding your advertising and store performance.
• To optimize ads towards a conversion outcome

Legal Basis:

• Processing is necessary for the performance of a contract
• If the user chooses to transfer any personal data to Enhencer, he/she guarantees that a proper consent for data collection, storage, and transfer has been obtained from the data subjects.

Retention Period:

Personal information that Enhencer processes on behalf of its Customers as a processor is retained for the period of time set forth in the Data Processing Agreement executed between Enhencer and its Customers.

When you subscribe to the Enhencer Lookalike Feature

At Enhencer Lookalike Feature, when you grant us permission to utilize Enhencer Lookalike, we implement an additional pixel tag to collect aggregated information. Enhencer is authorized to aggregate Customer Data for the purpose of research and development for new products and services. This data helps us fine-tune our optimization algorithms, ultimately delivering more effective conversion audiences to you.

Personal Data:

• Enhencer Unique ID
• Session Time
• User Country
• Home page scroll & clicks
• Listing page scroll & clicks
• Product page scroll & clicks
• Product categories and prices
• AddtoCart product lists
• Purchased product lists
• Custom Attributes (determined solely by Customer)
• Any other information that provided by the Customers

Source:

• We obtain the personal data from the additional Lookalike Pixel Tag and Javascript code running on your website
• We acquire personal data from advertising platforms through APIs that you have established

Purpose of Collecting:

• To optimize and enhance your advertising campaigns across various channels by reaching broader and more diverse audiences
• To assist you in leveraging your customer data for improved audience targeting and ROAS optimization
• To provide you with even better audience targeting, ultimately improving your conversion rates
• To help you achieve better results with the same budget or reduce ad spend while maintaining performance

Legal Basis:

• Processing is necessary for the performance of a contract
• If the user chooses to transfer any personal data to Enhencer, he/she guarantees that a proper consent for data collection, storage, and transfer has been obtained from the data subjects

Third Parties We Share Data With:

Retention Period:

Personal information that Enhencer processes on behalf of its Customers as a processor is retained for the period of time set forth in the Data Processing Agreement executed between Enhencer and its Customers. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

When we acquire your personal data from third-party sources (such as analytics tools)

Personal Data:

• Unique ID
• Country
• City
• Session Information
• Usage Information
• Operating System

Source:

• We obtain personal data from third parties

Purpose of Collecting:

• To allow us to help show more targeted and relevant content
• To provide subscribers with our services
• To gather analysis or valuable information so that we can improve our product
• To monitor the usage of our Service
• To advertise to you on other sites

Legal Basis:

• Consent

Third Parties We Share Data With:

Retention Period:

Personal information that Enhencer processes on behalf of its Customers as a processor is retained for the period of time set forth in the Data Processing Agreement executed between Enhencer and its Customers. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

Providing Customer Support

Personal Data:

• Contact Information
• Problem Specifications
• Session Information
• Usage Information
• Any other information that you provide us (e.g., in the context of product support)

Source:

• We obtain the personal data directly from you

Purpose of Collecting:

• To enhance your user experience
• Troubleshooting and securing the platform
• To compile aggregate data about site traffic and site interaction so that we can offer better experiences

Legal Basis:

• Processing is necessary for the performance of a contract

Retention Period:

Personal information that Enhencer processes on behalf of its Customers as a processor is retained for the period of time set forth in the Data Processing Agreement executed between Enhencer and its Customers. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

When you interact with us through our marketing events, on our social media profiles, and our blog (e.g., Facebook, Twitter, LinkedIn)

Personal Data:

• Contact Information
• Company Name
• Job title
• Session Information
• Usage Information

Source:

• We obtain the personal data directly from you
• We obtain personal data from third parties

Purpose of Collecting:

• To help us show more targeted and relevant content
• To send weekly newsletters
• To gather analysis or valuable information so that we can improve our product
• To generate leads and contact prospective customers

Legal Basis:

• Consent to processing of personal data in events, accessing content & marketing communications

Third Parties We Share Data With:

Retention Period:

Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

Internal Logs

We may also use some other information like session and usage information for fraud prevention and security purposes. The information inside the log files includes IP addresses, browser type, Internet Service Provider, date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us. We use such information for security purposes and to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

Retention and Security of Personal Data

Personal information that Enhencer processes on behalf of its Customers as a processor is retained for the period of time set forth in Data Processing Agreement between Enhencer and its Customers, unless Enhencer is required to retain the Personal Data for a longer period of time to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

We have implemented commercially-reasonable technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers.

Transfers of Personal Data

The personal data collected are being stored on Amazon Web Services in the European Union and United States, pursuant to Standard Contractual Clauses for international transfers. When we transfer personal data outside of EU/EEA, we will obtain contractual commitments from the recipients of data.

In addition to the third parties mentioned above, we may share your personal data as follows: (i) with courts or competent authorities, to comply with applicable laws, regulations and requests of law enforcement; (ii) in case we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party; (iii) in the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy; (iv) where you have provided your consent to us sharing or transferring your personal data.

Third Party Services

We enable you to interact with third party websites, products or services that are not controlled by us (“Third Party Service”). Please be aware that Third Party Services can collect Personal Data from you. Therefore, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

We conduct due diligence on such third-party service providers prior to sharing your Personal Data with them. We share your Personal Data with such third-party service providers only on a contract basis where such service providers assure that they are and shall be in compliance with the applicable data protection laws.

We reserve the right to remove or add new sub-processors, which shall be notified to you and included in our Data Processing Agreement.

Your Rights

The following rights shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

• You can access the personal data we held about you. This can normally be exercised free of charge, however, we reserve the right to charge an appropriate fee where applicable;
• You can request that we correct any personal data we hold that is inaccurate;
• You can request the deletion of your personal data. Please note that in certain situations, we are required to keep your personal data where applicable;
• You can object to or request restriction of processing your personal data;
• You can request to receive your personal data in a structured, commonly used and machine-readable format, and transmit that data to another controller;
• You can object to profiling;
• You can withdraw your consent at any time;
• You can request certain details of the basis on which your personal data is transferred outside the European Economic Area;
• You have a right to lodge a complaint with your local data protection supervisory authority.

When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. You can exercise your rights by submitting a request here .

How long do we store your Personal Information?

We store your Personal Information for different time periods depending on the category of Personal Information and the nature of the relationship that you have with us. We determine how long we need Personal Information on a case-by-case basis, but our goal is to keep your Personal Information for as short a period as possible to achieve the purpose for which Personal Information is collected. We consider the following criteria when we are making decisions on how long we will retain your Personal Information:

• The category of Personal Information.
• Whether the Personal Information is typically deleted based on specific schedules, such as marketing information.
• Whether the Personal Information is necessary to operate or provide our services. For example, account information may be retained for a longer period of time based on the Agreement you have with us.
• How long we need to retain the Personal Information to comply with our legal obligations.
• Our legitimate interests or legal purposes, such as network improvement, fraud prevention, record-keeping, promoting safety, security and integrity, or enforcing our legal rights.

Additional information for consumers in the United States

Under the California Privacy Rights Act (‘CPRA’) residents of California have certain rights regarding the Personal Information that businesses collect and process about them. This includes the rights to request access or deletion of your Personal Information, as well as the right to direct a business to stop selling or sharing your Personal Information.

We are required to detail the categories of Personal Information that we collect and/or share for the purposes described in the “Information We Collect and How We Process It” section of this privacy policy.

While Enhencer does not engage in the sale of Personal Information in exchange for monetary compensation, we do share Personal Information for other benefits as outlined in Cal. Civ. Code 1798.140(ad)(2). We have detailed the data categories we collect and the associated "business purposes" in the "Information We Collect and How We Process It" section of our policies. This includes the sharing of personal identifiers, commercial information, and internet or other electronic network activity with entities such as payment processing providers, customer relationship management firms, consulting services, email service providers, product feedback management, customer success services, advertising networks, website analytics companies, and sponsors. You have the right to instruct Enhencer not to sell or share your Personal Information. Additionally, please note that Enhencer does not sell or share the Personal Information of individuals under 18 years of age.

For more information on how to exercise your rights, including the list of privacy rights that may be available to you, please see section “Your Rights” of this privacy policy. If you would like to access, review, update, correct, delete any Personal Information we hold about you, or exercise any other privacy rights available to you, including the right to opt out from selling or sharing your Personal Information, you can send your request to: info@enhencer.com.

We endeavor to respond to a Privacy Rights Request within the required timeframes. If we need more time, we will inform you of the reason and extension period in writing. If you submit your Privacy Rights Request electronically through our request form, we will deliver our written response to the verified email associated with the request. If you did not submit the request with us via the online webform, we will deliver our written response by mail or electronically, at your option. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Appeal

If Enhencer does not take action on your Privacy Rights Request within the 45 days response period, or in the event of an extension, within the maximum 90-day response period, we will inform you in writing of the reasons for not taking action, as well as provide an explanation of any rights you have to appeal the decision.

“Do Not Track” Disclosures

Privacy regulations in the United States, such as the laws of California and Delaware, require Enhencer to indicate whether it honors your browser’s “Do Not Track” and “Do Not Sell My Personal Information” signals concerning targeted advertising. Enhencer adheres to the standards set out in this Notice and does not track visitors who prefer not to be monitored.

Deleting your account

You may delete your account by submitting a request to info@enhencer.com. If you delete your account, any association between your account and personal data we store will no longer be accessible.

Use by children

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of 16. If you are under the age of 16, do not provide any personal data to us without the consent of a parent or a legal guardian.

Contact us

If you have any questions, concerns or complaints or if you wish to exercise your rights, we encourage you to contact us at info@enhencer.com.