Enlyft’s Privacy Promise
Our Services are built to offer the richest, deepest, and most reliable company data to support your business goals, while respecting the privacy of everyone whose Personal Information is captured within the Enlyft Data. To ensure you have complete confidence in the Enlyft Data and our privacy practices, we offer this privacy promise to you:
· Your Personal Information within Enlyft Data is either submitted by you or is professional information from publicly available resources or our trusted data vendors.
· We carefully vet our data vendors and other third-party data sources for lawful privacy practices and data integrity.
· Our Services will never collect or disclose Personal Information that was meant to remain private.
· Enlyft brings the human element back into marketing and sales. Human users leverage Enlyft technology to build target profiles unique to each Client’s needs.
· Our Services are designed to support tailored, personalized sales messages and marketing campaigns to the right accounts at the right time. Enlyft does not use mass communications or spamming techniques, and we prohibit our Services from being used in this manner.
· You can always control the information associated with your Platform account.
· As part of our commitment to data integrity, we encourage you to submit requests to correct or delete Personal Information within the Enlyft Data.
· Enlyft welcomes your requests to restrict our use or processing of your Personal Information in accordance with your privacy rights.
· Enlyft will always notify you if this promise changes in any way.
2. Personal Information
a. Identifiers (e.g., name, email, telephone number, address, username);
b. Sensitive Personal Information (e.g., government identification number; precise geolocation; racial or ethnic origin; religious beliefs; health information; contents messages when Enlyft is not the recipient);
c. Legally protected information (e.g., race, citizenship, marital status, sex);
d. Employment-related information (e.g. current or past employment);
e. Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
f. Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;
g. Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes;
h. Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); and
i. Internet or other similar activity (e.g., browsing history; content interactions).Information that is not protected as Personal Information includes:
i. Publicly available information, like Enlyft Data collected or generated from a professional’s publicly available online profile;
ii. Aggregated information, meaning data summaries or reports with the Personal Information removed;
iii. De-identified information that cannot be easily linked back to the individual.
3. Collection and Use of Personal Information
a. Categories of Personal Information Collected
Enlyft may collect Personal Information (a) with your consent; (b) if we have a legitimate interest in doing so; or (c) as authorized or required by law. We only collect, use, retain, and disclose Personal Information as reasonably necessary and proportionate to provide our Services or for other purposes that we disclose to you and are compatible with the context of how we collected your Personal Information.
b. Sources of Collection
During the preceding 12 months, we have collected Personal Information in the following categories: (i) identifiers; (ii) employment-related information; (iii) commercial information, and (iv) internet or similar activity. Our sources of collection include:
· You as a Client, with your consent. If you become a subscribing Client, Enlyft will collect the Personal Information you choose to submit to our Platform, such as your identifiers (e.g., name, email, username), employment-related information (e.g., company, title, work history) as part of your Platform account profile, and any information you include in your communications with Enlyft. If you choose to link your Platform account with your social media or another third-party account, you consent to Enlyft automatically collecting your Personal Information from your third-party account. We collect this information with your consent, and we use it to provide you with the Services you request from Enlyft.
· Your use of the Platform, with a legitimate interest. When a Client uses the Platform to discover, prioritize, and engage prospects, Enlyft collects commercial information like the Client’s prospect profiles and interactions and internet and similar activity like your search history and content interactions. In addition to your consent for these activities, Enlyft collects this information to achieve our legitimate interests of providing you with the Services to which you subscribe and improving our technology and ability to market and deliver our Services to Clients.
· Our Data Sources, with a legitimate interest. Enlyft uses trusted third-party data vendors and public data sources (each a “Data Source”) to collect employment-related information about professional contacts at companies our Clients may wish to prospect as part of a sales or marketing campaign. Enlyft executes contracts with each vendor Data Source after a rigorous due diligence process focused on lawful privacy practices and data integrity. In all other cases, we collect and generate data using publicly available sources and methods, such as online databases or public APIs that are made available to the public. We collect this information to achieve our legitimate interest of improving and providing the Services to our Clients. In many cases, the data collected from these sources is not protected as Personal Information under applicable privacy laws, but is nonetheless highly valuable to our Clients.
· Your communications with Enlyft, with your consent. If you request information about our Services or other resources we offer, we collect your name, email address and other contact information through an online form, email, or other Site feature. If you complete a survey, we will collect your responses. If you register as a Client, we will also collect information about your company and use a payment processor to collect and store your subscription fee payment information. We collect this information with your consent and use it for the purposes stated at the time of collection, to provide you with our Services, and to communicate with you or send you marketing information.
· From Resellers and Clients of our Services, with a legitimate interest. Resellers of our Services or our Clients may provide Enlyft with identifiers like professional contact information about their subsidiaries, affiliates or others that may be interested in learning about our Services (“Contacts”). Enlyft receives information about Contacts according to the disclosing Reseller’s or Client’s own privacy practices, over which Enlyft has no control. We may combine Contacts’ information with Personal Information we previously collected about the Contact from other sources. Enlyft collects this information to achieve our legitimate interest of marketing our Services to potential new Clients. You have the right to unsubscribe from Enlyft’s marketing communications at any time.
4. Children’s Privacy
Our Services are designed for adults, not children. Enlyft does not knowingly collect Personal Information from children under 16. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. Please contact [email protected] if you believe we have received information from a child under 16 or any unauthorized information.
5. Retention of Personal Information
It is Enlyft’s policy to collect the richest and most reliable data to support our Clients’ efforts to achieve efficient and highly valuable sales and marketing campaigns. Enlyft Data offered to Clients on our Platform is retained as an essential asset to our provision of Services as long as it serves a legitimate interest. If we learn that any Enlyft Data is inaccurate or stored or used unlawfully, we will correct or delete that Enlyft Data as required by law and our company policies.
Personal Information associated with a Client’s account is retained while that account remains active and is deleted within 90 days after account closure. We retain data collected from cookies and similar technologies for trends analysis and data security purposes for up to 24 months or according to the cookie hosting company’s own policies. Enlyft reserves the right to retain data, including Personal Information, for longer periods if it is critical to our business and securely stores that retained data. Enlyft regularly reviews and deletes or deidentifies unnecessary data.
6. Disclosing Personal Information
Enlyft will only disclose Personal Information to the third parties described in this section, with your permission, or as required by law. In the preceding 12 months, Enlyft has disclosed identifiers, employment-related information, commercial information, and internet or similar activity to third- party recipients for a business purpose. We may disclose this information to the following recipients:
a. Our Clients. A core element of our Services is the provision of rich, deep, and reliable data about companies as prospects for Client sales and marketing campaigns. If a Client’s prospect profile matches with Personal Information we collected about you from publicly available sources, that Client may access Personal Information within the Enlyft Data available on the Platform. Clients control their prospect profiles and choose which Enlyft Data to access and how to use that data subject to the Client’s privacy practices.
b. Service Providers. Enlyft’s third-party service providers may have access to your Personal Information to perform their contractual obligations to us. We use a variety of service providers including data hosting companies, analytics services, fraud prevention vendors, and payment processors. The type of information that we disclose to a service provider will depend on the service that they provide to us. Our service providers are subject to contractual agreements that protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.
c. Affiliates. Enlyft may disclose the information we collect from you to our affiliates or subsidiaries in accordance with applicable privacy laws.
d. Other Third Parties, as permitted by applicable law. For example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
e. Law enforcement, and other governmental agencies, at our sole discretion in connection with an investigation of any matter that is illegal or that could expose Enlyft or our affiliates or subsidiaries to liability.
7. Aggregated and De-Identified Information
Enlyft reserves the right to disclose aggregated, anonymized, or de-identified information about any individuals with non-affiliated entities for research, product development, marketing, or other purposes, without restriction.
8. Your Privacy Rights
a. Controlling Your Personal Information
Enlyft provides you a variety of methods and options to directly control how we collect and use your Personal Information, including but not limited to:
· Platform Account. If you are a Client with an account on the Platform, you have the option to access, correct or update, or delete the Personal Information associated with your account at any time. If you require assistance, please contact [email protected]
· Marketing Communications. If you inquire about our Services, we may use your contact information to send you marketing communications in compliance with applicable law. As part of our policy to provide you total privacy, you may opt-out of receiving these communications at any time by clicking the “Unsubscribe” button contained in any email or by sending a request to [email protected].
· Device Settings. You can control the data we collect through automated means by adjusting your device settings, such as blocking cookies or installing a third-party plugin to control how cookies interact with your device.
· Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed below.
b. Consumer Privacy Requests
If you wish to exercise your rights under your applicable privacy laws beyond the methods described above, or if you want to express concerns, lodge a complaint, or request information, please submit a verifiable consumer privacy request to [email protected].
Enlyft collects Personal Information as a controller or business, and most of that Personal Information is collected from publicly available sources and/or in a business-to-business context in the performance of your job duties to your employer. Please note that your privacy rights may not extend to Personal Information collected and used under these circumstances.
Enlyft cannot fulfill a request related to a Client’s use of your Personal Information.
Enlyft can only fulfill a Consumer Privacy Request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Information, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. 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. We endeavor to respond to Consumer Privacy Requests in accordance with the requirements of the law applicable to your jurisdiction.
c. California and Certain Other U.S. States
This section provides the disclosures and notices required under the California Consumer Privacy Act of 2018 (“CCPA”) and offers informational notices to residents of Virginia, Colorado, Nevada, and other U.S. states with laws providing similar protections. The following paragraphs apply solely to residents of the State of California and other states to the extent the same legal protections apply (each a “Consumer”). Consumers may exercise the following rights over their Personal Information, subject to our receipt of a verifiable Consumer Privacy Request and any exceptions and limitations that may apply:
· Right to Disclosure. You may request that we disclose information to you about our collection and use of your Personal Information over the past 12 months, such as: (a) the categories of Personal Information we have collected about you; (b) the categories of sources for the Personal Information we have collected about you; (c) our business purpose for collecting or selling that Personal Information; (d) the categories of third parties with whom we share that Personal Information; and (e) if we sold or disclosed your Personal Information for a business purpose, two separate lists stating: (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Under the CCPA, Enlyft is only required to respond to two disclosure requests within a 12-month period.
· Right to Correct. You have the right to request that we correct inaccurate Personal Information about you on our systems. If you become aware that the Personal Information that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
· Right to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you over the past 12 months (also called a data portability request). If you submit an access request, we will provide you with copies of the requested pieces of Personal Information in a portable and readily usable format. Please note that Enlyft is prohibited by law from disclosing copies of certain pieces of Personal Information because the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our business systems, or your account. Under the CCPA, Enlyft is only required by law to respond to two access requests within a 12-month period.
· Right to Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, with certain exceptions. Enlyft may permanently delete, deidentify, or aggregate the Personal Information in response to a request for deletion. If you submit a Consumer Privacy Request to delete your Personal Information, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.
· Right to Opt-Out of Profiling. Enlyft uses algorithms to help Clients prioritize target profiles, which may include evaluation, analysis, or prediction of an individual’s preferences or choices. However, all Client or prospect profiling on our Services is ultimately the result of human decision-making. If in the future our Services include automated profiling absent human decision-making, we will update this posting to describe our use of profiling and your methods to opt-out.
· Right to Nondiscrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; or (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under the CCPA.
· Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.
Consumers may exercise these rights by submitting a verifiable Consumer Privacy Request as instructed above. We endeavor to respond to a verifiable Consumer Privacy Request from a California Consumer within 45 days of receipt. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. If we cannot comply with part or all of your request, we will explain the reasons in our response.
d. Canadian Privacy Rights
We adopted this section to provide supplemental information in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”). This section applies solely to residents of Canada where PIPEDA applies (“Canadian Consumers”). PIPEDA gives Canadian Consumers specific rights regarding Personal Information offering details on an identifiable person without the inclusion of name, title, telephone number, and business address of an employee of a business or organization. The following paragraphs describe PIPEDA rights and explain how to exercise those rights.
· Right to accuracy of your Personal Information. We take steps to reasonably ensure that your Personal Information we are using is accurate. In most cases, we rely on you to ensure that your information is current, complete, and accurate. We provide methods for you to correct, update, and delete inaccurate Personal Information in your account, and we will provide you with reasonable assistance to ensure that your Personal Information is accurate in our systems and with our service providers.
· Right to access your Personal Information. Upon written request and identity authentication, we will provide you with your Personal Information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfil the request. If limited by law or potential infringement on another’s privacy rights, we may not be able to provide access to some or all of the Personal Information you request. If we must refuse an access request, we will notify you in writing, document the reasons for refusal, and outline further steps that are available to you.
e. European Economic Area and United Kingdom
We adopted this section to comply with the General Data Protection Regulations (“GDPR”) and its counterpart regulation applicable to residents of the United Kingdom. This section applies solely to residents of the EEA and the United Kingdom (“Data Subjects”). Enlyft collects and processing Personal Information of Data Subjects as a controller. If you are a Data Subject, you have the following rights in relation to the Personal Information we hold about you:
· Right to access your Personal Information. You can request to access your Personal Information. Upon request, we will provide you with a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example, to protect the rights of other individuals.
· Right to restrict processing of your Personal Information. You can request that we restrict the processing of your Personal Information if: (a) the data is inaccurate; (b) the processing is unlawful; (c) we no longer need the Personal Information; or (d) you exercise your right to object.
· Right to rectify your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.
· Right to data portability. In some circumstances, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.
· Right to erasure (a.k.a. the “right to be forgotten”). Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.
· Right to object to certain processing of your Personal Information. Upon your request, and in certain circumstances and where we are required to do so by law, we will limit our processing of your Personal Information as you request.
· Right to not be subject to Automated Decision-Making (“ADM”). Enlyft uses algorithms to prioritize Client target profiles, but our technology does not use ADM in a manner that produces legal effects concerning or significantly affecting any individual. If this changes in the future, we will update this posting to describe our use of ADM and your options to exercise your privacy rights related to your Personal Information processed using ADM. If you are a resident of the EEA and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. If you are a resident in Switzerland, you have the right to complain to the Swiss data protection authorities.
9. Cookie Notice
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
10. Data Security
Enlyft employs reasonable and appropriate security procedures and practices to help protect your Personal Information from unauthorized or illegal access, destruction, use, modification, or disclosure. The Platform and our other Services are designed with data security in mind to continuously protect your data and our systems. Enlyft maintains internal policies to govern the collection, processing, and handling of data.
Access to Personal Information is limited to employees and contractors as needed to perform their job functions. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. We also ensure that our employees, contractors, and agents responsible for handling privacy inquiries are informed of applicable legal requirements and we restrict access to those who need that information to process it.
However, no transmission of data over the Internet is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes. Clients that create an account on the Platform are responsible for maintaining the confidentiality of their username and password. We encourage you to take steps to protect against unauthorized access to your account and device by choosing a robust password and signing off after each session. Enlyft is not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized activity.
11. Cross-Border Data Transfers
Enlyft is owned and operated in the United States. We use technical infrastructure in the United States and other jurisdictions to provide our Services to Clients wherever they are located. As such, we must sometimes transfer data across jurisdictional boundaries. If you access our Site or use our other Services from outside of the U.S., please be aware that the Personal Information we collect about you may be transferred to, processed, stored, and used in the U.S. or other jurisdictions.
When your information is moved from your home country to another country, the laws and rules that protect your Personal Information in the country to which your information is transferred may be different from those of the country where you live. For example, if your information is in the United States, it may be accessed by government authorities in accordance with U.S. law.
Enlyft is dedicated to ensuring lawful mechanisms are employed for all cross-border data transfers. To the extent that Enlyft is deemed to transfer Personal Information from the Economic Area (“EEA”) to outside of the EEA, we do so on the legal basis that such transfer is necessary to provide you with the Services you choose to use.
By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph. We do not warrant that our Services are appropriate or authorized for use in any other jurisdictions. Clients and other users are solely responsible for determining whether their use of our Services complies with applicable laws.
12. Third-party Platforms and Social Media
We may provide links to third-party websites or platforms or allow you to link to our Services from social media. Enlyft offers this as a convenience, but we are not responsible for and have no ability to control the privacy and data collection, use, and disclosure practices of any third party. When you click on links that take you to external websites or platforms, you will be subject to their privacy policies and practices and not ours. You are encouraged to review and understand the privacy policies of such websites or platforms before submitting any information.
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