個人情報保護方針
Fenergoは、データの透明性に対するお客様の権利、ならびにお客様のデータとその取り扱い方法を制御できる権利を認識して尊重します。以下で詳しく説明するように、機密性の高い個人情報を含む、お客様の個人情報をどのように使用するか、そして誰にお客様の個人情報を開示するかをお客様に知らせることが、信頼できる貴重な関係の基礎を形成すると考えています。
お客様のデータプライバシーは、Fenergoがコミュニティとやり取りするうえで常に重要視されてきました。当社には、お客様を特定するか、特定可能なデータ・情報について、お客様のプライバシー権を保護する義務があります。この通知では、そのようなデータまたは情報を「個人データ」と呼びます。個人データは、常に適用される法規制の要件および禁止事項に従って、Fenergoによって収集、使用、および開示されます。
Fenergoデータプライバシー方針
Contents
- Purpose and Scope
- Collection Of Personal information We Collect and Process
- Sources of Personal information
- Purpose and Lawful Basis for Processing Your Data
- Disclosures of Personal information
- Security of Processing
- Retention of Personal information (including Use in AI Systems)
- Cookies and Tracking Technologies (Including Use in AI Systems)
- お客様の権利
- International Data Transfers
- 通信設定の管理
- お問い合わせ方法
- Changes to this Notice
1. Purpose and Scope
At Fenergo, privacy is a priority. Personal information will always be collected, used, and disclosed by Fenergo in accordance with the requirements and prohibitions of applicable laws and regulations. This includes personal information processed using Artificial Intelligence (“AI”) technologies, which we may leverage in our products, services, and operations. Where AI is used, we are committed to ensuring it is implemented responsibly, transparently, and in a way that upholds individual privacy and data protection rights. We recommend that you read this Notice in full to ensure you are informed about the ways we collect, use, store, share, or otherwise process your personal information, including when supported by AI.
The primary purpose of this document is to set out how Fenergo Limited and its affiliates (“us,” “our,” or “we”), acting as a Data Controller, collect, use, store, or otherwise process personal information about individuals (collectively "you") who access or use fenergo.com, our document portal, our client portal, and/or any of our other products or services that link to this Privacy Notice (the “Services”). This includes the use of AI to enhance decision-making processes, automate communications, tailor experiences, and support our teams in delivering services with greater efficiency.
In some cases, we may process your personal information pursuant to an agreement with a third-party organisation. In those cases, the terms of that agreement may govern how we process your personal information. If you believe a third-party organisation has asked us to process your personal information on their behalf, please consult with them in the first instance, as they will be responsible for how we process your personal information.
This Privacy Notice (“Notice”) does not apply to any third-party websites and apps that you may use, including those to which we link in our SaaS Service. You should review the terms and policies for third-party websites and services before they are used.
2. Personal information We Collect and Process
The following section outlines the categories of personal information we may collect and process about you, including data obtained using Artificial Intelligence (“AI”) technologies deployed to support and enhance the functionality of our Services:
- Basic identity information such as your name, address, date of birth, and nationality.
- Personal contact information such as your personal contact number(s) and email address.
- Business contact information (“Relationship Data”) such as your organization, work address, work phone number(s), and work email address.
- Commercial information such as purchasing history and transactional details, including billing or banking information.
- Communication records such as inquiries, messages, or feedback you send via email, web forms, customer surveys, or support channels. If you use chat or virtual assistant features, including those powered by AI, we may collect any personal information you choose to share during those interactions, such as contextual details about your inquiry.
- Online identifiers such as device identifiers, IP address, advertising IDs, social media handles, and usernames.
- Usage data such as log files, page views, time spent on pages, clicks, content accessed, error logs, and navigation history across our Services.
- Internet or network activity such as your interactions with our websites, Services, emails, and digital tools including those enhanced by AI for personalization or service automation.
- Location data such as your general location derived from your IP address or information you voluntarily provide (e.g., city or region via forms).
- Audio, electronic, visual, or other sensory information such as CCTV footage (e.g., if you visit our offices or events), call or chat recordings with support or sales teams, and other digital message logs.
- Marketing and advertising data including your expressed preferences, engagement with marketing content, interest profiles derived from digital interactions, and communications settings. Certain AI-based systems may be used to tailor communications and recommend relevant products or services based on your engagement.
Personal information Processed on Behalf of Fenergo Clients
When our business clients use certain Services, we may act as a data processor or subprocessor by processing personal information on their behalf. In such cases, Fenergo’s client is the Data Controller (or Processor, as applicable) and is primarily responsible for decisions about how that personal information is used. Regarding providing customer support, Fenergo acts as an Independent Controller of Business Contact Information (aka Relationship Data).
3. Sources of Personal information
The following describes the sources from which we collect or obtain your personal information, including through the use of Artificial Intelligence (“AI”) technologies to support our operations, communications, and service delivery:
- Information you provide directly, such as when you register with us, communicate via email or chat, visit our offices, attend our events, or engage in marketing or outreach activities (e.g., downloading white papers). Interactions via AI-powered tools (e.g., chatbots or virtual assistants) may also capture personal information you voluntarily share during the exchange.
- Information automatically collected, including technical data and usage patterns related to your interactions with our websites and digital services. This may include online identifiers (e.g., device ID, IP address), and usage data such as page views, navigation history, and system logs. AI technologies may be applied to analyze these data points to improve our services, personalize your experience, or detect anomalies.
- Information from public sources, such as publicly available records and information you choose to make public on social media platforms, forums, or other open-access environments. This information may be enriched or classified using AI-based tools if permitted by law.
- Information from third parties, including third-party services, content providers, marketing or commercial partners, and social media platforms. These partners may share information with us under contractually agreed conditions. AI may be used to associate or categorize this information with other data for analytics, insights, or communication targeting.
We may combine information from these sources whether collected directly, automatically, publicly, or via third parties and use or disclose it for the purposes outlined in this Notice. Where AI is used, we apply appropriate governance and safeguards to ensure it aligns with applicable laws and respects your individual rights.
4. Purpose and Lawful Basis for Processing Your Data
When Fenergo uses your personal information, we are required to have a specific purpose and a legal basis for doing so. In certain contexts, Fenergo may use Artificial Intelligence (AI) or Machine Learning (ML) systems to process personal information for purposes such as data categorization, predictive analytics, process automation, or improving service delivery.
Where applicable, Fenergo ensures:
- That personal information processed by AI systems is subject to appropriate safeguards, including transparency, fairness, and accountability,
- That any automated processing with legal or significant effects is subject to human oversight, and
- That individuals are informed where they interact with AI systems or are subject to profiling.
The lawful basis for AI supported processing may include our legitimate interests, your consent (where required), or performance of a contract, depending on the context.
Other Uses. We may aggregate the personal information we collect, or insights generated or derived from the use of our Services or remove pieces of personal information to limit or prevent identification of any user or device to help with goals like research and product development. Where such information has been aggregated and anonymised so that it is no longer considered personal information under applicable data protection law, this Privacy Notice does not apply.
Fenergo will honour data subject rights to the extent required by law. You may have the right to access, correct, update, and, in some cases, request deletion of your personal information (subject to exceptions).
You may submit a request here. For more information, see section 9
5. Disclosures of Personal information
Subject to applicable law and appropriate technical and organisational measures, we may disclose personal information as follows:
- Service Providers. We disclose your personal information to service providers we use to support our business.
- Strategic Partners. We disclose your personal information to partners that help us to support, maintain, configure or sell our products and services.
- Affiliates. We may disclose your personal information to other companies in the Fenergo group. These companies use your personal information as described in this Notice.
- Marketing and Advertising Partners. We may allow third-party advertising and marketing technologies on our websites that use cookies and similar technologies to deliver relevant and targeted content and advertising to you on the websites and other websites you visit and applications you use.
- Marketing Partners. We may provide your personal information to sponsors of events, webinars, or sweepstakes for which you register, or other parties with whom we may engage in joint marketing activities.
- Public or Government Authorities. We may disclose your personal information to comply with our legal obligations, regulations, administrative, or judicial process, such as a subpoena, government audit, or search warrant where we are legally compelled to do so.
- Corporate Transactions. We may share or transfer your personal information with relevant third parties if, or as part of the investigation for, any planned or actual change, sale, joining, combination, partnership, assignment, transfer, or other movement of all or some of our business, assets, or stock (including with any insolvency or similar process).
- Consent. We may disclose your personal information in other ways if you have asked us to do so or have given consent. For example, with your consent, we post user testimonials that may identify you.
Where Fenergo engages third-party AI service providers to support data processing or enrichment, such providers are contractually obligated to adhere to data protection requirements equivalent to those set out in this Notice.
6. Security of Processing
We maintain state of the art technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, disclosure, alteration, or use.
Where AI or ML systems process personal information, Fenergo implements additional technical and organisational measures to protect against unintended inferences, discriminatory outputs, or unauthorised disclosures from model interactions.
7. Retention of Personal information
We keep your personal information for no longer than necessary for the purposes for which it is processed. This includes retention necessary to comply with statutory obligations, legal retention requirements, or to fulfil contractual obligations with you.
Where personal information is processed using Artificial Intelligence (AI) technologies, such as for analytics, automated decision-making, or machine learning purposes, we ensure that:
- Personal information is not used to train models.
- AI systems are designed to respect data minimisation and purpose limitation principles, including automated data expiry and pseudonymisation where feasible.
- We do not store personal information within AI models unless explicitly permitted and justified under applicable law.
Where there are technical limitations that prevent full deletion or anonymisation, we implement appropriate organisational, technical, and security measures to safeguard the data and restrict its active use.
8. Cookies and Tracking Technologies
We use cookies and other tracking technologies to enhance your user experience, analyse site usage, and deliver personalised content. You are offered the option to manage your cookie preferences as described in our Cookie Section, located in our Privacy Notice
Some tracking technologies may allow us to monitor your device activity over time and across different devices, browsers, and websites. This information may include unique identifiers, browsing behaviour, and interaction data.
Where permitted and applicable, data collected through cookies and tracking technologies may be used to:
- Analyse and improve user behaviour models,
- Personalise content or services,
- Detect fraud or unusual activity using automated patterns
For more detailed information about our use of cookies and tracking technologies, please refer to our Cookie Section located in our Privacy Notice
9. Your Rights
Subject to applicable law, you have several important rights. In summary, those include rights to:
- Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address.
- Require us to correct any mistakes in your information which we hold.
- Require the erasure of personal information concerning you in certain situations.
- Receive the personal information concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party in certain situations.
- Object at any time to processing of personal information concerning you for direct marketing.
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, including decisions supported by AI systems. Where applicable, you also have the right to obtain meaningful information about the logic involved, the significance, and the envisaged consequences of such processing, and to request human intervention.
- Object in certain other situations to our continued processing of your personal information.
- Otherwise restrict our processing of your personal information in certain circumstances.
For more detailed information about our use of cookies and tracking technologies, please refer to our Cookie Section located in our Privacy Notice
The above rights are not absolute rights and may be limited where it is necessary to protect the fundamental rights, human rights, or public and private interests of others. Fenergo reserves the right, where permitted by law, to verify your identity. In some circumstances, Fenergo processes personal information on behalf of its clients and subject to the control and instructions of its clients.
To exercise any of these rights, please contact us via the Privacy Request Portal.
10. International Data Transfers
Fenergo may need to store and process your personal information in countries outside the European Economic Area (EEA), including in jurisdictions where we operate or where our service providers operate. This may involve transferring your personal information to countries with differing levels of data protection. Where personal information is processed or accessed outside the EEA, we take additional precautions to ensure that such processing remains compliant with applicable data protection laws.
These include:
- Ensuring such transfers are subject to an adequacy decision, or in the absence of adequacy, safeguarded by Standard Contractual Clauses (SCCs) or other equivalent contractual controls.
- Conducting appropriate Transfer Impact Assessments (TIAs).
- Including specific data protection and AI terms with third-party service providers to govern how personal information may be processed.
- Restricting use of personal information in AI model development to purposes consistent with the original collection context and requiring pseudonymisation or anonymisation where possible.
Fenergo is committed to maintaining a high level of protection for your personal information, regardless of where it is processed. All transfers are subject to appropriate legal, contractual, and technical safeguards to protect your privacy rights.
11. Managing Your Communications Preferences
You can opt out of email marketing messages we send you by clicking on the “unsubscribe” link in the email message or unsubscribe here. Please note that we may send you one further message to confirm that you want to opt-out.
If you are a registered user of our SaaS, or if you have engaged in transactions with us, we may continue to send transactional or relationship messages (e.g., journey notifications) after you opt out of marketing messages.
If you would like your phone number added to our internal Do-Not-Call list to opt out of telemarketing messages, please contact us via the Privacy Request Portal. Please include your first name, last name, company, and phone number. You can also let us know at any time, including during a telemarketing call, that you do not want to be called again for telemarketing purposes
12. How to Contact Us
お客様の個人情報の使用または本通知に関するご質問または苦情については、以下の連絡先までお問い合わせください：
Attention: Emmett Carolan (Data Protection Officer)
Address: 4th Floor, North Dock 2, 93/94 North Wall Quay, Dublin 1, D01 V8Y6, Ireland
Phone: +353 01 901 3600
Email: dataprotection@fenergo.com
If you wish to contact an office that is local to you, please see Contact us | Fenergo.
To exercise any of your data subject rights, please contact us via the Privacy Request Portal.
13. Changes to this Notice
We may amend this Notice to reflect changes in the law, our companies, our Services, or advances in technology. Our use of the personal information we collect is subject to the Privacy Notice in effect at the time such personal information is processed. Depending on the type of change, we may notify you of the change by posting on this page.
