ENSKAI PRIVACY POLICY

Last updated: January 5, 2026

This Privacy Policy explains how EnskAI Ltd ("EnskAI", "we", "us") processes personal data in connection with the EnskAI platform, website, and related services ("Services").

This Policy applies to website visitors, Platform users, Trial Users, Contracted Customers, and individuals whose data is uploaded to the Platform by customers.

1. Who we are

Company: EnskAI Ltd

Address: 71 Struga Str., Sofia 1000, Bulgaria

Email: support@enskai.com

2. Our role under GDPR

2.1 EnskAI as data processor

When customers upload or manage data relating to players, staff, contacts, contracts, notes, files, or similar content, EnskAI acts solely as a data processor on behalf of the customer organization. Processing is governed by the applicable Data Processing Agreement.

2.2 EnskAI as data controller

EnskAI acts as a data controller for:

  • Platform user accounts and authentication
  • Website and sales communications
  • Billing and compliance records
  • Security, audit, and access logs

3. Categories of personal data

3.1 Platform user data

  • Name
  • Email address
  • Phone number (optional)
  • Login credentials (hashed)
  • User activity logs

3.2 Customer-uploaded data (processed on behalf of customers)

  • Player and staff information
  • Contact details
  • Contracts and documents
  • Notes, tasks, activities, messages
  • Uploaded files

3.3 Technical data

  • IP addresses
  • Device and browser metadata
  • Login timestamps
  • Security logs

4. Purposes of processing

Personal data is processed to:

  • Provide and operate the Platform
  • Authenticate users and control access
  • Store and organise data on behalf of customers
  • Ensure platform security and integrity
  • Provide support and customer communications
  • Meet legal and regulatory obligations
  • Improve reliability and performance

5. Legal bases

Processing is based on:

  • Performance of a contract
  • Legitimate interests
  • Legal obligations
  • Consent, where required

Customers are responsible for identifying lawful bases for the data they upload to the Platform.

6. AI and automated processing

The Platform includes AI-assisted features that help structure, summarise, or analyse information.

  • Customer data is not used to train general AI models without explicit opt-in
  • AI outputs may be inaccurate or incomplete and must be reviewed by users
  • AI Features do not perform automated decision-making under Article 22 GDPR unless explicitly stated
  • Where a user connects the Platform to an external AI assistant, the data they request is sent to that provider at their initiative and processed under the provider's own terms

7. Data sharing and subprocessors

EnskAI may use subprocessors for hosting, authentication, messaging, and analytics, subject to contractual data protection obligations. EnskAI does not sell personal data.

8. International data transfers

Customer data is hosted primarily within the European Union. Any limited international transfers are protected by appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms.

9. Data retention

  • Customer data is retained for the duration of the customer relationship
  • Trial data may be deleted after trial expiry
  • Logs and security data are retained for limited periods
  • Data may be retained longer where required by law

10. Data subject rights

Individuals have rights including access, rectification, erasure, restriction, portability, and objection.

Where EnskAI acts as processor, requests must be directed to the relevant customer organization. EnskAI will assist as required.

Requests may be sent to support@enskai.com

11. Security

EnskAI implements appropriate technical and organisational security measures, including access controls, encryption, monitoring, and incident response procedures.

In the event of a personal data breach affecting customer data, EnskAI will notify the relevant customer as required under applicable law and the applicable Data Processing Agreement.

12. Children and minors

The Platform may process data relating to minors where uploaded by customers. Customers are solely responsible for ensuring lawful processing and obtaining required consents. EnskAI does not independently collect data from children.

13. Changes to this Policy

This Privacy Policy may be updated from time to time. Material changes will be communicated via the Platform or website.

14. Contact

For questions about this Privacy Policy or data protection practices, contact:

Email: support@enskai.com