Fenergo Data Privacy Policy

Fenergo recognizes and respects your right to data transparency and to be able to control your data and how we interact with it. We believe that making you aware of how we use your personal information, including sensitive personal information, as discussed further below, and to whom it is disclosed, will form the basis our trustworthy and valuable relationship. Your data privacy has always been to the fore of how Fenergo interacts with our community and we are compelled to safeguard your privacy rights with respect to any data or information we receive that identifies you or is identifiable to you. For purposes of this notice, we will call such data or information “personal data”. Personal data will always be collected, used, and disclosed by Fenergo in accordance with the requirements and prohibitions of applicable laws or regulations.

This Notice explains how we collect, use, store and share the personal data you provide us on www.fenergo.com, Client Portal, at our events, with our team members or downloading any of our valuable thought leadership pieces.

GDPR and the Lawful Basis for Processing your Data.

We want to be open and honest with regards to what data we capture, what we use it for, how you can interact with that data and how you can control that data.

When we use your personal information, we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

  • consent: where you have given us clear consent for us to process your personal information for a specific purpose
  • legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information, which overrides our legitimate interests)

Fenergo collects, uses, stores and otherwise processes personal data where necessary to provide a service which you request, where necessary to comply with a legal obligation, and where necessary pursuant to Fenergo’s legitimate interests and where these interests are not overridden by your data protection rights. For example, Fenergo has a legitimate interest in ensuring the security and integrity of its systems and facilities and in ensuring that relevant information for the conduct of our business is available across the Fenergo group. Fenergo may also process your personal data where you have given consent or provided your “opt-in”. For example, when you fill in an online form or request more information about Fenergo products or services, you consent to Fenergo using your personal data as requested. Where Fenergo asks for consent, you are free to withhold or revoke it.

We have set up a personalised Preference Center where you can control what you receive based on topic, stream and thought leadership.

Your rights

 Under the General Data Protection Regulation you have a number of important rights free of charge. 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
  • object in certain other situations to our continued processing of your personal information
  • otherwise restrict our processing of your personal information in certain circumstances

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 data on behalf of its clients and subject to the control and instructions of its clients. If you believe Fenergo may have personal data about you due to services Fenergo is providing or has provided to a Fenergo client with whom you have a relationship, it may not be possible for Fenergo to respond to your request. In that circumstance, it would be more appropriate for you to direct your request to the Fenergo client with whom you have the relationship.

For further information on each of those rights, including the circumstances in which they apply, see the Irish Data Protection Commission’s guidance here

If you would like to exercise any of those rights, please:

  • email, call or write to our Data Protection Officer whose contact details are listed below.
  • let us have enough information to identify you
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill)

Data Protection Officer – Contact Details

Title:  Fenergo Data Protection Officer

Address: Fenergo Limited, Castleforbes House, Mayor Street, Dublin 1, D01 A8N0

Phone: + 353 901 3776

Email: [email protected]

What kind of personal information does Fenergo collect online?

In the course of our business, Fenergo may collect personal data about you from the following sources:

  • From applications or other forms, we receive from you;
  • From our internet websites;
  • From public sources such as vendors who may provide personal data;
  • From events that we either attend or host ourselves (digital or on-the-ground).

How does Fenergo safeguard the personal data we collect?

Fenergo maintains electronic and procedural safeguards designed to protect your personal data from unauthorized access or intrusion. Fenergo limits access to the personal data only to those employees, contractors and agents who need such access in connection with providing products or services to you, to clients with whom you have a relationship, or for other legitimate business purposes. Some of these measures may include encryption, physical access security, user access security measures or other technologies and tools which Fenergo believes may enhance the security of its systems and facilities. However, Fenergo has no responsibility or liability for the security of information you provide to Fenergo transmitted via the Internet.  Fenergo employees and contractors receive annual training regarding Fenergo’s privacy and information security policies and procedures. Fenergo understands that protecting consumer privacy is an integral part of protecting our relationship with our clients.

How does Fenergo use the personal data collected?

Fenergo uses the data we collect to assist us in providing products or services to you, to our clients, to provide you with information about those products or for other legitimate business purposes;

  • Fenergo does not seek to determine your identity when you simply browse our site, however, if you provide Fenergo with your contact information, such as by completing an online form or providing information in a job application, Fenergo will know your identity;
  • Fenergo may use cookies to aggregate information about the web pages you visit, so Fenergo can update or enhance our services (such as retargeting). Fenergo does not provide your domain name to third parties, other than to the vendors, such as those with whom we contract for website design and maintenance. These vendors are under contractual confidentiality requirements;
  • Fenergo may disclose your personal data if regulatory obligations require Fenergo to do so, if Fenergo determines such disclosure is legally advisable or necessary in order to protect Fenergo’ rights, the rights of others, or in order to prevent harm;
  • We will only retain your data for as long as is necessary and in accordance with applicable law. We set out our retention periods within our company policies. In Fenergo’s case, we deem 48 months an acceptable amount of time to keep your consent and after such time will reseek your permission to communicate with you.

Who has access to the personal information Fenergo collects?

Fenergo limits access to personal information to those employees, contractors, business partners or agents who require such access in connection with providing products or services to you or for other legitimate business purposes.

With whom does Fenergo share the personal information we collect?

Fenergo houses our data in four main industry standard, data housing systems and they are:

  • Salesforce
  • Marketo
  • Engagio
  • MODX

These systems allow us to have the utmost confidence that your data is secure and helps us makes sure that we are not sending you communications regarding subjects that you are not involved in.

Fenergo website is not directed at persons under the age of 18. Fenergo does not knowingly collect, maintain or use personal data from persons under the age of 18 on any Fenergo website. If you are under the age of 18 years, please do not register or otherwise provide information to Fenergo.

International Data Transfers

Fenergo may need to store and process your personal data in a non- European Economic Area (EEA) country where we have operations or where our service providers are located. We may be required to send personal data to recipients in countries other than the country in which it is collected, including to the US. Where these non-EEA countries have different data protection laws, Fenergo will take measures to ensure your personal data remains protected.  These transfers are subject to an EU adequacy decision or in the absence of an adequacy decision, subject to Standard Contractual Clauses to provide an adequate level of protection under applicable data protection law. Data Processor Agreements are in place with our service providers and are designed to help safeguard your privacy rights.

Managing your communications preferences

You may opt-out of receiving communications about Fenergo products and services by visiting our Subscription Preference Centre at any time. For other valuable consumer information, including information on protecting yourself from identity theft and fraud, visit the following sites:

Fenergo’ use of Cookies on our website

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of your internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the Irish Data Protection Commission, www.aboutcookies.org or www.allaboutcookies.org.

Consent to use cookies and changing settings

We will ask for your permission (Consent) to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.

You can withdraw any consent to the use of cookies or manage any other cookie preferences by clicking on the cookie settings button at the bottom left of any page on our site. This will open our Cookie Preference Centre. You can then toggle the sliders as appropriate under each cookie type. It may be necessary to refresh the page for the updated settings to take effect.

Third party access to the cookies

Third party cookies are cookies set by someone other than the website owner for purposes such as collecting information on user behaviour. When using our website, you may encounter embedded content, such as YouTube videos or Twitter feeds. These websites and embedded content may use their own cookies. We do not have control over the placement of cookies by other websites, even if you are directed to them from our website.

How does Fenergo respond to “Do Not Track” signals?

Current “Do Not Track” initiatives are not recognized by our website.
Fenergo is not responsible for the content or privacy practices of other non-Fenergo websites to which Fenergo’ websites may link. If you are asked to provide information on one of these sites, we urge you to carefully review their privacy policies before sharing.

For further information on our use of cookies please see our cookie list below or our Cookie Policy.

Online Privacy Notice Updates

This Online Privacy Notice is subject to change. Please review this notice periodically. Any changes will become effective when we post the revised notice on the site (please note effective date listed at top). Your use of the site following these changes means that you accept the revised Notice.

Fenergo is a leading provider of Client Lifecycle Management, AML/KYC Compliance and Client Data Management solutions.