Security and Fraud Prevention Conditions of the Ennoos Network

Global model. People and organizations. Common conditions of the service. Fraud correlations with delimited data.

R.1 · Common conditions

Security is part of Ennoos. Security and fraud prevention conditions of the Ennoos network. They apply to people and organizations within the scope defined in this document.

R.1.1 Purpose and scope. ENNOOS LLC (“Ennoos”) builds security and fraud prevention measures into the accounts, identities, access and operations carried out on its platform or through services expressly integrated with it. These conditions govern that common network protection function. They do not create a separate anti-fraud subscription and do not require a company to purchase an additional module in order to take part in the common protection.

R.1.2 Included correlations. The function comprises correlations of signals between people, accounts, devices and organizations in order to detect and prevent impersonation, account takeover, abusive use of credentials, fraudulent automated requests, manipulation of verifications and coordinated attacks. The correlations are part of standard operation for lawfully enabled data and flows, exclusively for those purposes and within R.3 to R.5.

R.1.3 People and companies. These conditions are incorporated into the Terms of Service for people and into the business contract through the valid acceptance and amendment mechanisms of each relationship. The Privacy Policy explains the processing, its bases and rights. People without an account are informed through the corresponding notice; appearing in an operation does not mean they have accepted a contract with Ennoos.

R.1.4 Scope of acceptance. Contractual acceptance covers the common security operation described here. By itself it is not consent to all processing and does not replace the authorizations, information, assessments or instruments that are required. Ennoos will maintain data admission controls by origin, purpose, territory and legal basis. A flow that is not enabled is excluded from the correlation; this does not turn network protection into a commercial option per customer.

R.1.5 Limits and documents. The ordinary scope is limited to the R.3 catalog and the R.5 outputs. It is not widened by an administrative instruction, a plan or a generic policy. Additional business features, their volume, price and support are contracted under the business contract and do not alter these limits. Mandatory rules apply and, for companies, so does the precedence of the Master Agreement and its Annex F. These conditions only modify the clauses expressly identified in the incorporation instrument.

Common protection, delimited data

Ennoos correlates security signals between participants to protect the network. It does not sell those signals, does not open one company's files to another and does not use the private content of vaults to build a general database of profiles.

R.2 · Roles and provenance

Who is responsible for each use. The same platform can carry out different processing. The role depends on the purpose and on the functions actually performed.

R.2.1 Common network protection. Ennoos determines the purpose and the essential means of the processing of the Network Signals delimited in R.3 in order to protect its service and the operations of its participants. It answers for that processing as an independent controller where the applicable law so provides, including its legal basis, transparency, security, retention and handling of rights. This classification is not imposed against a territorial rule that requires a different allocation of obligations.

R.2.2 Organization file. The Organization determines the purposes of its applications, products and files. Ennoos continues to act as processor or sub-processor to host, manage and evaluate that data on its behalf, under Annex D or the applicable DPA. This relationship does not allow Ennoos to move complete files into its own processing. Only the fields admitted by R.3 may enter the network, through a lawful, identified and separate flow.

R.2.3 Direct origin and business origin. Signals may come from a person's interaction with Ennoos or from an operation of an Organization integrated with the service. The Organization will give notice of the communication of the signals to Ennoos for the network's own purpose and will demonstrate that it is entitled to make that communication. Ennoos will check that the flow is enabled and its own legal basis. If the Organization is a processor for another controller, its administrator cannot unilaterally extend the instructions: valid enablement from the ultimate controller is required.

R.2.4 No fictitious acceptance. A company's acceptance is not equivalent to the consent of its employees, customers or applicants. Where consent is appropriate, it will be obtained from whoever must give it, validly, specifically and on an informed basis. Where another legal basis is invoked, its requirements and the associated rights will be documented. People without an account may contact Ennoos about the signals that Ennoos processes as controller, in addition to exercising their rights with the Organization.

R.2.5 Functional separation. Ennoos will keep personal and business files, the evaluation carried out on behalf of an Organization, and the minimum set of Network Signals separate. Exceptional linking for anti-fraud purposes will be carried out through a controlled process; it does not grant general access between vaults and does not modify existing Grants. Providers operating on behalf of Ennoos may not use those signals for their own purposes.

R.2.6 Responsibility for the communication. Each participant answers for its part of the flow. The Organization's warranties of lawfulness do not release Ennoos from its own obligations. The documentation will identify origin, ultimate controller, categories, notice, legal basis, receipt by Ennoos, purpose and limits on the return of results. Flows between controllers will not automatically be presented as mere sub-processing.

R.3 · Closed data catalog

What information is correlated. Only fields that are necessary for the operation and enabled by their origin and jurisdiction are incorporated. Not every category of every person is collected by default.

Permitted Network Signals

• Email and phone. Pseudonymized representations of the data used in the registration or the operation. They make it possible to detect abnormal reuse and coordinated attacks. The source data, and its presence in any particular entity, is not disclosed to another organization.
• Document identifier. Code derived from the type, issuing country and number of the document when the operation requires it and enablement exists. No image, chip, photograph, signature, address or other fields of the document are incorporated into the network set.
• IP and connection. Event IP, approximate country, ASN, technical indicators of proxy or abuse, and date. They serve for velocity, abnormal access and coordination; not for tracking browsing outside Ennoos or for precise geolocation.
• Device and session. Pseudonymized technical identifier, device type, system or user agent, and strictly necessary session events. Files, contacts, camera, microphone or device content are not accessed. Local permissions and rules on device access apply.
• Operation event. Date, channel, generic class of operation, opaque reference and internal issuer. They allow sequences, frequency and patterns. They do not include amount, balance, payment history, specific financial product, counterparty or content of the request.
• Technical security status. Code of an access attempt, additional verification, technical failure, account compromise or impersonation verified with evidence. Suspicion, verification, dispute and correction are distinguished. Convictions, criminal accusations and commercial ratings of customers are not incorporated.
• Derived signal. Match, velocity, anomaly, reason and recommendation resulting from the fields above. They are protected data when they refer to an identifiable person; an aggregate or score is not considered anonymous by default.

R.3.1 Excluded data. The following do not enter the network correlation: content of vaults, Brain, files, documents, communications or calendars; financial or credit data; biometrics, health or other specially protected categories; data of minors; passwords, private keys or OTP codes; creditworthiness labels, credit approval, default, blocklists or commercial outcomes of other companies. The information strictly listed above is obtained from the enabled event, not by exploring the content of the vault.

R.3.2 New categories. Incorporating other categories, sources or purposes requires assessing their necessity, legal basis and risks, updating the documents and obtaining the corresponding acceptances or authorizations before using them. It is not enabled by a generic broadening of “security”.

R.4 · Controlled correlation

Detecting patterns without opening files. The anti-fraud exception allows minimal signals to be linked between participants. The remaining content keeps its separation.

R.4.1 Permitted operations. Ennoos may compare enabled identifiers, associate technical events, calculate frequencies within time windows and detect coordinated patterns between organizations. It may use those results to protect network access and operations and to provide the minimum permitted recommendation to the participant who is legitimately involved in the operation. Querying a person with no relation to a real operation is not permitted.

R.4.2 Precise purposes. The scenarios covered are: coordinated account takeover attempts; use of an identifier or device in sequences incompatible with a legitimate interaction; abusive automation of requests; manipulation of verifications; and propagation of a documented technical compromise or impersonation. The match of an identifier across companies is, by itself, legitimate and does not establish fraud.

R.4.3 Example of use. An unusual sequence of attempts from a device, combined with authentication failures in operations of different organizations, may justify additional verification. The Organization that receives that recommendation knows the security reason needed for its own operation; it does not receive the list of the other organizations, their applicants or the detail of their files.

R.4.4 Pseudonymization and controls. The correlation service will use derived codes and dedicated access controls. The network correlation keys will have custody and permissions separate from the ordinary access to each tenant. Participants will not receive global tokens that allow relationships to be reconstructed. Measures will be applied against repeated queries, inference by differences and enumeration. HMAC, hashes and tokens reduce exposure but are not, in themselves, equivalent to anonymity.

R.4.5 No commercial expansion. Signals will not be used for advertising, commercial segmentation, sale of data, creditworthiness assessment, prospecting, general surveillance or reconstruction of private relationships. They will not be automatically connected to public reputation levels or to Ennoos ID. Identity verification keeps its own scope; a risk indicator does not replace it or attribute guilt.

R.4.6 Historical and external sources. A new acceptance does not retroactively legitimize historical data. Each source and period must be compatible with the purpose and have its own legal basis; otherwise, it does not enter and is not used in shadow testing. These conditions do not authorize buying files, sending identifiers to external reputation APIs or incorporating third-party databases. An additional external flow requires a specific assessment and specific transparency in accordance with R.10.

R.5 · Results and decisions

The signal has a limited scope. A recommendation can influence an operation. For that reason its purpose, its recipient and the possibility of review must be clear.

R.5.1 What is returned. Ennoos may return to the enabled participant a recommendation to continue, verify additionally or stop for review; its main reasons; the date, version and scope of the evaluation; and the status of insufficient data or technical error where applicable. If a score is offered, it expresses risk according to the documented methodology and not a calibrated probability unless there is specific evidence.

R.5.2 What is not returned. No files of other parties, clear-text data of third parties, names of other organizations, number of related entities, dates of other parties' operations, contracted products or fraud labels provided by another company are delivered. Explanations will not identify the issuer of another party's signal unless there is a specific legal obligation. A range such as “three or more entities” is also excluded when it reveals relationships about a person.

R.5.3 Destination of the recommendation. The recipient may use it only to protect the operation that prompted the evaluation and to handle its review or lawful evidence. It may not resell it, create shared lists or use it for another person or for commercial purposes. Ennoos will log and limit queries. Communications required by an authority will be analyzed separately, with minimum data and the applicable legal safeguards.

R.5.4 Ennoos measures. Ennoos may apply rate limits, additional authentication, closure of a compromised session or a proportionate temporary restriction. It will explain the main reason where possible without harming an investigation or security, and will offer review. A restriction that has legal effects or similarly significant effects will not be based solely on a score without meaningful human intervention, except for a documented legal exception with its safeguards.

R.5.5 Organization decision. The Organization decides on its product or application and answers for that decision. It will not use a result as the sole basis of a high-impact adverse decision without meaningful human review and compliance with the law. The reviewing person must be able to understand and change the result. An automatic approval of the recommendation does not constitute review.

R.5.6 Errors and quality. Technical failure, insufficient information and risk indication will be kept separate. A shared IP, a VPN, a leaked email address or a relationship between devices does not confirm fraud. The victim will be distinguished from the person carrying out an impersonation. Disputed data will be flagged and restricted while it is verified; false positives, the aging of signals and rectification will be handled in accordance with R.8.

R.6 and R.7 · Legal basis and AI

Part of the service, with enforceable limits. The inherent nature of the protection does not remove the legal conditions of the processing or widen the permissions over models.

R.6.1 Basis by purpose and territory. Ennoos will document the legal basis for the collection, correlation and communication of each flow. Where it can rely on legitimate interest, it will assess the specific purpose, necessity, less intrusive alternatives, expectations and impact on people. Where a legal obligation applies, it will identify the applicable rule. Where consent is necessary, it will request it in a specific, informed and valid manner. A European basis is not applied as a universal authorization.

R.6.2 No commercial security switch. The necessary and lawful common protection controls operate as part of the service; they are not offered as an optional plan upgrade or as a marketing preference. People keep their rights to object, to restrict processing and to withdraw consent where applicable. Ennoos will assess each request according to its legal basis. Using the service is not presumed to imply waiving those rights.

R.6.3 Proportionate consequences. If a necessary processing cannot be carried out lawfully, Ennoos will assess a less intrusive alternative or will limit only the operation or function that it cannot provide securely, explaining its scope and respecting consumer regulations. It will not make unrelated services conditional on consent to unnecessary processing, nor penalize the withdrawal of a consent that must be freely given.

R.6.4 Mandatory rules. The restrictions on devices, communications, automated decisions, specially protected data and regulated sectors apply, as the case may be. Systems or flows that require an impact assessment, a transfer instrument, authorization or additional safeguards will operate only when those requirements are met. Transparent information is necessary, but it does not replace those requirements.

R.7.1 Inference and correlation. Existing rules and models may be run on enabled signals and the variables needed for the anti-fraud case may be calculated. Correlation between organizations does not grant permission to train, tune or improve models with personal data, Organization Data, signals, labels or derivatives of these. The training prohibitions of the personal terms and of clause 6.8 of the Master Agreement are preserved.

R.7.2 Validation and versions. Ennoos may measure errors and validate operation within the authorized purpose and time limits, without using that validation to tune model parameters with the protected data. Changes to rules and versions will be documented and tested before deployment. A language model will not by itself determine the anti-fraud result. Synthetic or aggregated data are not free of restrictions by virtue of their name.

R.8 · Transparency and rights

An explanation and a route for review. Anyone without an account can also exercise their rights with respect to the signals that Ennoos processes about that person.

R.8.1 Information before processing. Ennoos will inform about its own network purpose, the data used, sources, recipients of recommendations, retention, international mechanisms and rights. The Organization will provide the corresponding notice before communicating signals or at the time permitted by law. It will keep evidence of its delivery and of the authorizations required. A generic reference to “our providers” does not replace informing about Ennoos's own role.

R.8.2 Channels and roles. Requests concerning network security are handled by Ennoos through ennoos.com/contact or the current privacy channel. For files processed on behalf of an Organization, the Organization handles the request with Ennoos's assistance under the DPA. If a request affects both processing operations, its handling will be coordinated without requiring the data subject to identify the internal architecture on their own. Creating an account is not required in order to make a claim.

R.8.3 Applicable rights. Access, rectification, erasure, objection, restriction, portability, withdrawal of consent and review of decisions will be handled in the cases and within the time limits of the applicable law. The competent authority and how to lodge a complaint will be communicated. Ennoos will verify identity proportionately and will not require more information than necessary. No contractual limit of liability reduces those rights.

R.8.4 Correction in the network. A valid correction will be applied to the source signal and to its active derivatives. The affected indicators will be withdrawn or recalculated and recipients will be informed where appropriate so that they can review their decisions. The trace will flag the rectification without presenting the old statement as current. A fraud label will not be kept against a victim in order to preserve the usefulness of a signal.

R.8.5 Explanation and secrets. Ennoos will provide the main reasons and the information needed to understand and challenge the result. It will protect code, weights, sensitive detection rules, the identities of other people and trade secrets, to the extent legally permitted. That protection does not justify denying all explanation or obstructing authorities. Any required access restrictions will be accompanied by reasons, as the law provides.

R.8.6 Deletion of derivatives. Erasure reaches identifiers, tokens, relationships, variables, caches, results and identifiable links under Ennoos's control, except for a lawful and delimited exception. Deleting the clear-text value or writing a deletion marker does not establish anonymization. The dates, internal identifiers and graph relationships will also be assessed. Restricted preservation does not allow the person to continue to be scored.

R.9 · Common retention

Security has time limits. These maximums are part of the v2 model. A shorter period will apply when it suffices for the purpose or the law requires it; the entire history is not renewed by a new operation.

Ordinary maximums for Network Signals

• Normalization. Email, phone and document values received only to generate the signal are processed transiently and are not kept as a clear-text duplicate in the correlation set. Their derived representations follow the period of the event.
• IP and technical detail. Up to 30 days from the event for operational analysis. After that the detail is deleted; the necessary derivatives may remain only within the 90-day correlation maximum.
• Events, tokens and relationships. Up to 90 days from each event for network correlation. Variables expire with their source data; the period for earlier facts is not restarted by a later observation.
• Result and explanation. Up to 180 days from the evaluation, with the minimum necessary to inform, correct and review. After 90 days the data of that evidence is not used for new network correlations.
• Documented security case. Minimum data up to 180 days after the case is closed; review of necessity at least every 90 days while it is open. The case must be specific and its follow-up active. Files are not kept indefinitely because of a generic investigation.
• Backups. Maximum rotation of 14 days. A restoration reapplies deletions and restrictions to prevent the reactivation of expired or corrected signals.

R.9.1 Exceptional preservation. A legal obligation, a binding order or a specific or reasonably foreseeable claim may justify keeping minimum data with documented grounds, restricted access, an end date or condition for ceasing, and review at least every 90 days. It does not enable new evaluations, commercial exploitation or training. Technical convenience or a possible abstract claim is not enough.

R.9.2 Account closure or a company's exit. Collection linked to the relationship that is ending stops. Signals previously processed lawfully by Ennoos as controller will be kept only within these maximums and for as long as their basis subsists, respecting the data subject's rights. Closure does not create a right of retention or require keeping data up to the maximum. Files processed as processor are returned or deleted under the DPA; they do not become Ennoos's own data because of the exit.

R.9.3 Audit and chain. Integrity records will not retain identifiable data or links beyond the period applicable to that purpose. The seven-year audit rule of the framework or of the general policies does not apply automatically to Network Signals. The specific substitution will be set out in the incorporation instrument. An immutable chain is not an exception to deletion.

R.10 · Technical protection and third parties

Controls that accompany the exception. Allowing correlations requires protecting both the common signals and the content that remains separate.

R.10.1 Measures. Ennoos will apply encryption, key management, least privilege, segregation of files and of the correlation service, query control, access traceability and isolation testing. Ordinary logs will not dump unnecessary identifiers or content. Controls will be verified before a flow is enabled and maintained according to risk, without reducing the business security commitments.

R.10.2 Integrity and attestation. Evidence may attest to the sequence, version and integrity of an evaluation within the scope of its mechanism. It does not by itself prove that the input is true, that valid consent exists or that a person has committed fraud. No certification, qualified signature or regulated trust service is declared without express accreditation and contracting.

R.10.3 Providers. Signals may be processed by necessary infrastructure and support providers under appropriate contracts, a duty of confidentiality, security, assistance and restrictions on use. The current named list must identify function, countries and relevant categories. Recipients with their own commercial purposes and third-party anti-fraud networks are not enabled by these conditions. Additional queries to external sources require specific documentation before data is sent.

R.10.4 Transfers. Hosting remains in Canada, the United States or Europe within the contracted scope. Remote access and international communications are documented with their countries and required mechanisms. For the network's own flow, the processor instrument will not be used automatically: it will be determined whether a transfer between controllers or another structure applies, and its annexes and assessments will be completed. Mandatory instruments prevail over incompatible clauses.

R.10.5 Incidents and communications. Ennoos will meet the legal deadlines for notifying authorities and people regarding its own processing. For Organization data affected by an incident, the contractual notice is maintained without undue delay and at the latest 48 hours from becoming aware, with the information available, unless a shorter period is required. It will not wait for the investigation to close or confuse that notice with a universal deadline for notifying authorities.

R.10.6 Misuse. Enumeration, queries without a legitimate operation, reconstruction of relationships, extraction or replication of models, circumvention of controls, resale of signals and unlawful discriminatory use are prohibited. Ennoos may contain or suspend misuse proportionately under the applicable contract, with notice and review as appropriate. Suspension does not authorize preventing rights, destroying mandatory evidence or appropriating files.

R.11 · Commitments and liability

Real protection, without a promise of infallibility. These conditions delimit the service and its uses. They do not shift to Ennoos the economic risk of all the operations on the network.

R.11.1 Scope of the service. Ennoos will apply the measures and guarantees committed in the applicable relationship. Results may contain false positives or negatives and depend on incomplete or changing signals. It is not guaranteed that all fraud will be eliminated, honesty established, losses recovered, penalties avoided or an approval secured. Ennoos does not thereby become an insurer, a guarantor of transactions or a credit institution. It answers for its own obligations under the law and the contract.

R.11.2 Business relationships. The warranties, remedies, confidentiality, intellectual property, indemnities and limits of the Master Agreement are preserved, including its exceptions. These conditions do not create an additional, unlimited indemnity for fraud losses and do not limit the existing intellectual property indemnities. The status of network controller is not used to evade the contractual data protection regime that has been agreed.

R.11.3 Relationships with people. The accepted Terms of Service and the mandatory data protection and consumer rules apply. The caps, indemnities, arbitration or choice of forum of the business contract are not automatically transferred to a person. These conditions do not add a waiver of the right to claim, to object to the processing, to obtain review or to go to the competent authority or court.

R.11.4 Technology and data. Ennoos retains its rights over technology and methods lawfully developed. Data and results keep the regime of ownership and rights of the contract and the law; correlation does not make personal data or files the property of Ennoos. Participants may not use access or confidential information to replicate the service or infringe rights, without prejudice to mandatory exceptions.

R.11.5 Changes and continuity. Material changes will be notified within the periods of the applicable contract and the law. The necessary acceptances or authorizations will be obtained before the new processing. Publishing another policy is not enough to broaden the fields, sources, purposes, recipients or periods of existing contracts. Urgent containment measures do not enable commercial uses or processing unrelated to the legitimate protection of the network.

R.11.6 Local rules. The territorial modules of the business contract and the mandatory rights of people are maintained. The real function will be assessed against rules on data, AI, automated decisions, devices and regulated sectors. The label “anti-fraud” does not by itself exclude credit information or consumer reporting rules if the actual use falls within them. No contractual guarantee of automatic compliance in every country is offered.

R.12 · Visible information

What we explain on acceptance. Summary to incorporate into the registration and operation user journeys. It must be shown next to the access to the full conditions and to the applicable privacy notice.

Common text for people and companies

Security and fraud prevention are part of Ennoos. To protect accounts and operations, we correlate between participants and organizations minimal signals of email, phone, document identifier, IP, device and security or operation events, when they are necessary and legally enabled. We use them exclusively to detect and prevent fraud, impersonation and abuse. We do not open one company's file to another, and we do not use the content of your documents, conversations or vaults for those correlations. You can learn about the data, periods and recipients, ask for review and exercise your rights in our Security and Fraud Prevention Conditions of the Network and in the Privacy Policy.

R.12.1 Contextual information. At the point of the operation, the fields actually used will be identified, together with whether they are mandatory or optional, their purpose, origin and recipients. It is not enough to show a maximum list if the case uses other fields or produces other effects. A warning will be given when a recommendation may trigger additional verification or review of the operation.

R.12.2 When a company enters another person's data. The Organization must identify its role and explain the communication of the minimum signals to ENNOOS LLC for the purpose of network protection, in addition to the processing of the file on behalf of the Organization. It will provide the rights channel of both controllers, the required international information and the corresponding authorizations. The person does not have to open an account or accept personal terms in order to exercise their rights.

R.12.3 Separate acceptance and consent. The contractual record will keep the version, date, identity or capacity of the person accepting, and access to the text. If a flow requires consent, its collection must be distinguished from general acceptance and allow the exercise of the applicable rights. A pre-ticked box or the phrase “inherent part” will not be used to replace valid consent.

R.12.4 Date of application. The edition date of these conditions identifies the document. Their effect on each relationship depends on their valid incorporation and on compliance with the legal and technical requirements of the flow. Activation notices will describe the actual operation; a control or correlation that has not yet been verified will not be presented as operational.

Where to consult and exercise rights

ENNOOS LLC · ennoos.com/contact. The legal notice and the Privacy Policy must keep the address, the data protection officer and the contact channels up to date. For a business operation, the contact of the corresponding controller will also be provided.