Enrich Layer - Data API for People and Companies

# Privacy Policy **Privacy Policy for [enrichlayer.com](http://enrichlayer.com/)** **Effective Date: June 9, 2025** **Last Updated: June 9, 2025** **1. Introduction** This Privacy Policy ("Policy") explains how [enrichlayer.com](http://enrichlayer.com/) ("[enrichlayer.com](http://enrichlayer.com/)," "we," "us," or "our") collects, uses, shares, and protects information obtained from and about individuals and companies ("you," "your") when you visit our website (the "Site"), use our data enrichment services, application programming interfaces (APIs), or other offerings (collectively, the "Services"), or otherwise interact with us. [Enrichlayer.com](http://enrichlayer.com/) is committed to protecting the privacy of individuals and the confidentiality of company information. We strive to handle all data responsibly, ethically, and transparently, in accordance with applicable privacy laws and best practices. This commitment to ethical data stewardship is fundamental to our operations and is designed to foster trust with our users, clients, and the individuals whose data we may process. This Policy outlines our practices and your rights concerning your information. Building this trust from the outset is a priority, as it influences how users perceive and engage with services that handle significant amounts of data. **2. Scope of This Policy** This Policy applies to: - **Visitors to our Site:** Individuals who browse or interact with [enrichlayer.com](http://enrichlayer.com/). - **Registered Users:** Individuals or entities that register for an account to use our Services ("Clients"). - **Data Subjects:** Individuals whose personal information is included in our databases and processed as part of our Services, even if they do not directly interact with [enrichlayer.com](http://enrichlayer.com/). This includes publicly available information about individuals and information about individuals associated with companies. - **Company Representatives:** Individuals who represent companies whose data we process or who interact with us on behalf of a Client or prospective Client. This Policy covers all Services operated by [enrichlayer.com](http://enrichlayer.com/) where this Policy is posted or referenced. It is important to clearly delineate these categories because the nature of data collected, the basis for processing, and the applicable rights can vary. For instance, an individual whose publicly available professional information is part of our enrichment database will have different interactions and expectations compared to a Client who actively subscribes to our Services. This clarity ensures that data protection measures and rights are applied appropriately to each group. This Policy does not apply to third-party websites, services, or applications that may be linked from our Services; their data practices are governed by their own privacy policies. **3. Information We Collect** [Enrichlayer.com](http://enrichlayer.com/) collects various types of information to provide and improve our Services, for analytical purposes, and to communicate with you. The information we collect can be broadly categorized as Personal Data and Company Data. **3.1. Categories of Personal Data** We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household ("Personal Data"). The specific categories of Personal Data we may collect include: - **Identifiers:** Such as a real name, alias, postal address, unique personal identifier (e.g., a persistent identifier), online identifiers (e.g., cookie IDs, mobile ad IDs), Internet Protocol (IP) address, email address, account username, telephone numbers, or other similar identifiers. - **Professional or Employment-Related Information:** Including current and past job titles, department, company or organizational affiliation, work history, educational background, professional skills, certifications, and professional network information. - **Commercial Information (for Clients):** Records of Services purchased, obtained, or considered from [enrichlayer.com](http://enrichlayer.com/), billing and payment information (processed by our secure payment processors), and other purchasing or consuming histories or tendencies related to our Services. - **Internet or Other Similar Network Activity:** Information regarding your interaction with our Site and Services, such as browsing history on our Site, search queries, access logs, features used, referring/exit pages, date/time stamps, clickstream data, and other usage data collected automatically. This may include information about the device you use to access our Services, such as device type, operating system, browser type, and device identifiers. - **Geolocation Data:** We may collect general location information derived from your IP address. We do not collect precise geolocation data (e.g., GPS coordinates) without your explicit consent, and generally, our services focus on business-related location information such as office addresses rather than precise personal locations. - **Inferences Drawn from Other Personal Data:** We may generate inferences from any of the information we collect to create a profile about an individual reflecting their professional characteristics, preferences, or likely business interests. - **Sensitive Personal Information:** [Enrichlayer.com](http://enrichlayer.com/) deals with business-related data. We do not intentionally seek to collect or process "Sensitive Personal Information" as defined by laws like the California Privacy Rights Act (CPRA) or "special categories of personal data" under the General Data Protection Regulation (GDPR) Article 9 for the individuals in our database, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person's sex life or sexual orientation. Our data collection focuses on professional and business-related attributes. Should any data inadvertently collected be identified as sensitive under applicable law and not relevant to our services, we will take steps to delete it. For Clients using our services, we may collect account login credentials, which are protected with robust security measures. The careful definition and handling of any data that might be deemed "sensitive" is critical. Regulatory frameworks impose stringent requirements for such data, often mandating explicit consent or specific legal bases and heightened security. By clearly stating our position and focusing on business-related data, we aim to meet high standards of data protection and manage risks effectively. Providing a detailed and granular list of data categories is essential not only for transparency but also for effectively fulfilling individuals' rights, such as the "right to know" what specific personal information is being collected about them. This level of detail supports internal data governance and demonstrates a commitment to facilitating these rights. **3.2. Categories of Company Data** We collect information about companies and other business entities, which may include: - Company name, legal structure, and aliases. - Business contact information (addresses, phone numbers, email addresses, website URLs). - Industry classifications, size (e.g., employee count, revenue estimates). - Financial information (e.g., reported revenue, funding rounds, if publicly available). - Organizational structure, including parent companies, subsidiaries, and key leadership. - Technographics (technologies used by the company). - Publicly available news, press releases, and regulatory filings related to the company. **3.3. Information We Do Not Intentionally Collect** As stated above, we do not intentionally collect Sensitive Personal Information for individuals in our database. Furthermore, our Services are not directed at children, and we do not knowingly collect personal information from children (see Section 11: Children's Privacy). We also avoid collecting data from sources known to be private or that require unauthorized access. **4. How We Collect Your Information** [Enrichlayer.com](http://enrichlayer.com/) obtains information from various sources, ensuring that we differentiate between data you provide directly when using our platform and data we gather to build our comprehensive business information database. **4.1. Information You Provide Directly to Us** We collect information that you voluntarily provide to us when you: - Register for an account or use our Services (e.g., name, email, company name, payment information). - Fill out forms on our Site, such as contact forms or requests for information. - Subscribe to our newsletters or other marketing communications. - Communicate with us, such as by sending an email to our support team or to [[email protected]](mailto:[email protected]). - Participate in surveys, promotions, or events. **4.2. Information Collected Automatically When You Use Our Services** When you visit our Site or use our Services, we automatically collect certain information about your device and your interaction with our Services: - **Usage Data:** This includes your IP address, browser type and version, operating system, device identifiers (if applicable), the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, links clicked, and other diagnostic data. - **Cookies and Similar Tracking Technologies:** We use cookies, web beacons (or pixels), and similar tracking technologies to collect and track information and to improve and analyze our Service. For more detailed information on the cookies we use and your choices regarding cookies, please see Section 7: Cookies and Tracking Technologies. **4.3. Information from Third-Party Sources** A significant portion of the data that comprises our Services is obtained from third-party sources. This is fundamental to our ability to provide comprehensive data enrichment. Our sources include: - **Publicly Available Sources:** We collect information from publicly accessible sources such as government records and websites (e.g., business registries, regulatory filings), company websites, professional networking platforms, news articles, press releases, blogs, and open data initiatives that license data for public use. - **Data Partners and Data Compilers:** We may license or otherwise acquire information from third-party data providers, data brokers, and strategic partners who specialize in compiling business and professional information. These partners are contractually obligated to ensure they have the legal right to collect and share this data with us. - **Our "Data Contributor Network" (if applicable):** Similar to models like People Data Labs' "Data Union", [enrichlayer.com](http://enrichlayer.com/) may engage with a network of contributors who provide data they have permission to share, often for mutual benefit in accessing enriched datasets. All contributors in such a network warrant that their data is compliant with applicable data privacy regulations and that they have the necessary permissions to share it. **Our Commitment to Source Compliance:** [Enrichlayer.com](http://enrichlayer.com/) is committed to ethical data sourcing. We conduct due diligence on our third-party data sources to assess their compliance with applicable laws and regulations. We evaluate the permissions under which the data was originally collected and the context in which it was obtained. We strive not to use data from sources that do not meet our compliance standards or from sites designated as private. This rigorous approach to data sourcing is paramount for building trust and ensuring the legality of our data, reflecting the high standards set by sophisticated data providers. **4.4. Information We Generate** We may also generate new information by analyzing and processing the data we collect. This includes: - **Inferences and Derived Data:** We may create profiles, scores, or other attributes by making inferences from existing data points (e.g., inferring a company's likely industry based on its activities, or an individual's professional skills based on their job history). - **Aggregated and Anonymized Data:** We may aggregate and anonymize data for statistical analysis, research, and service improvement. This data does not identify individual persons or specific companies. It is crucial to distinguish between data collected directly from users of our platform (e.g., account information, usage logs) and the extensive datasets compiled about other individuals and businesses from external sources or generated by us. The legal basis for processing, user rights, and notification requirements can differ significantly for these two categories. For instance, consent might be the primary basis for platform user data, while legitimate interests (supported by robust assessments and opt-out mechanisms) might be the basis for publicly sourced or partner-provided data that forms our enrichment database. This distinction is vital for a sophisticated and transparent privacy policy. **5. How We Use Your Information** [Enrichlayer.com](http://enrichlayer.com/) uses the information we collect for various purposes, grounded in lawful bases such as the necessity to perform our Services, our legitimate business interests, compliance with legal obligations, or your consent where required. - **To Provide, Maintain, and Improve Our Services:** - To operate and maintain our Site and Services, including enabling access, delivering data, and ensuring functionality. - To personalize your experience with our Services. - To monitor the usage of our Services, analyze trends, and gather demographic information for aggregate use. - To develop new products, features, and functionalities, and to enhance the accuracy and comprehensiveness of our data. - **To Manage Your Account and Provide Customer Support (for Clients):** - To create and manage your account, process transactions, and send you related information, including confirmations and invoices. - To respond to your comments, questions, and requests, and to provide customer service and support. - **For Research and Development:** - To conduct research and analysis to understand market trends, improve our data models, and innovate our Service offerings. - **For Marketing and Communications:** - To send you technical notices, updates, security alerts, and support and administrative messages. - To communicate with you about products, services, offers, promotions, rewards, and events offered by [enrichlayer.com](http://enrichlayer.com/) and others, and provide news and information we think will be of interest to you, in accordance with your communication preferences and applicable law. You will have the option to opt-out of receiving marketing communications at any time. - **To Enforce Our Terms and Comply with Legal Obligations:** - To enforce our terms and conditions or other policies. - To comply with applicable laws, regulations, legal processes, or governmental requests (e.g., subpoenas, court orders). - To protect the rights, property, or safety of [enrichlayer.com](http://enrichlayer.com/), our users, or the public as required or permitted by law. - To prevent, detect, and investigate potentially prohibited or illegal activities, including fraud and security breaches. - **In Connection with a Business Transfer:** - We may use or share your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. We will notify you if your information becomes subject to a different privacy policy. - **For Other Purposes with Consent or Legitimate Interest:** - We may use your information for other purposes that are disclosed to you at the time we collect the information, for which we obtain your consent, or which are compatible with the original purpose of collection. - Where we rely on "legitimate interests" as a lawful basis for processing under GDPR principles, such as providing B2B intelligence services to facilitate commerce or helping businesses identify and connect with relevant prospects, these interests are carefully considered and balanced against the rights and freedoms of individuals. We conduct internal assessments to ensure this balance is maintained, and individuals typically have the right to object to such processing. This careful articulation and internal assessment of legitimate interests is a key aspect of responsible data handling. **6. How We Share Your Information** [Enrichlayer.com](http://enrichlayer.com/) may share information under the following circumstances, always striving to do so in a manner consistent with this Policy and applicable law: - **With Service Providers (Sub-processors):** - We engage third-party companies and individuals to perform services on our behalf (e.g., cloud hosting providers, data analytics providers, payment processors, customer support services, email delivery services) ("Sub-processors"). These Sub-processors may have access to your Personal Data or Company Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. - We maintain contractual agreements with our Sub-processors requiring them to protect the information shared with them and to process it only in accordance with our instructions and for the purposes for which it was disclosed. We conduct due diligence on our Sub-processors' security and privacy practices. - Transparency regarding Sub-processors is important for trust and compliance. A list of our current Sub-processors, detailing their services and locations, is provided below and will be updated as necessary. This practice aligns with the transparency goals of regulations like GDPR and the expectations of our Clients. **Our Sub-processors** | Sub-processor Name (Legal Entity) | Purpose of Processing / Service Provided | Location of Processing (Country/Region) | | --------------------------------- | -------------------------------------------- | --------------------------------------- | | Google LLC (Google Analytics) | Website Usage Analytics | United States | | Google LLC (Google Workspace) | Email, Document Collaboration, Cloud Storage | United States | | PostHog, Inc. | Product Analytics and User Behavior Tracking | United States | | Intercom, Inc. | Customer Messaging and Support Platform | United States | - **With Our Clients (as part of our Services):** - The core of our Services involves providing enriched data about individuals and companies to our Clients for their business purposes, such as sales, marketing, recruiting, and analytics. The information shared is as described in Section 3 and is provided under contractual terms that include data protection obligations. - **For Legal Requirements and Safety:** - We may disclose your information if we believe it's necessary to comply with a valid legal process (e.g., subpoena, court order, government inquiry), a statute, rule, or regulation. - We may disclose information to protect the rights, property, and safety of [enrichlayer.com](http://enrichlayer.com/), our users, or the public, including to prevent or stop activity we consider to be, or to pose a risk of being, illegal, unethical, or legally actionable. - **In Case of Business Transfers:** - If [enrichlayer.com](http://enrichlayer.com/) is involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. - **With Your Consent:** - We may share your information with third parties when we have your explicit consent to do so. - **Aggregated or De-identified Information:** - We may share information that has been aggregated or de-identified so that it cannot reasonably be used to identify an individual or company. We may use and share such information for our own business purposes, such as for research and analysis, and to improve and promote our Services. The proactive management and transparent disclosure of Sub-processors, including robust contractual safeguards, are key indicators of a mature privacy program. This approach not only meets user expectations for transparency but is also crucial for Clients who are themselves data controllers and need this information for their own compliance obligations under laws like GDPR. **7. Cookies and Tracking Technologies** [Enrichlayer.com](http://enrichlayer.com/) uses cookies and similar tracking technologies (such as web beacons, pixels, tags, and scripts) to collect information about your interaction with our Site and Services, to remember your preferences, to enhance security, and to help us improve our offerings. - **What are Cookies?** Cookies are small text files placed on your device (computer, tablet, or mobile phone) when you visit a website. They allow the website to recognize your device and store some information about your preferences or past actions. - **Types of Cookies We Use and Why:** - **Necessary/Essential Cookies:** These cookies are crucial for the basic functioning of our Site and Services. They enable core functionalities such as user authentication, account management, security features, and ensuring compliance with legal requirements. Our Services may not function properly without these cookies. - **Performance and Analytics Cookies:** These cookies collect information about how you use our Site and Services, such as which pages you visit most often, how much time you spend on those pages, and if you encounter any errors. This information is used to improve how our Services work and to understand user engagement (e.g., through services like Google Analytics). - **Functionality Cookies:** These cookies allow our Site and Services to remember choices you make (such as your username, language, or the region you are in) and provide enhanced, more personalized features. - **Targeting or Advertising Cookies (if applicable):** If we engage in online advertising, these cookies may be used by us or our third-party advertising partners to deliver advertisements that are more relevant to you and your interests. They may also be used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. - **Your Choices Regarding Cookies:** - **Browser Settings:** Most web browsers allow you to control cookies through their settings. You can typically set your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept certain cookies, you may not be able to use some parts of our Service, or some features may not function properly. - **Cookie Consent Management:** Where required by law, we will obtain your consent before placing non-essential cookies on your device. We may provide a cookie consent banner or a preference center on our Site that allows you to manage your choices for different categories of cookies. - **Opting Out of Interest-Based Advertising:** You may be able to opt out of receiving interest-based advertising from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. A sophisticated approach to cookies involves not just stating their use but providing users with granular control over non-essential cookies and clear, accessible information about each cookie's purpose and duration. This demonstrates respect for user autonomy and helps meet the stringent requirements of regulations like the ePrivacy Directive in the EU and the opt-out rights under CCPA/CPRA. **8. Data Security** [Enrichlayer.com](http://enrichlayer.com/) takes the security of your information seriously. We implement and maintain reasonable and appropriate technical, administrative, and physical security measures designed to protect the personal information and company data we process from unauthorized access, use, disclosure, alteration, or destruction. These measures are chosen based on the sensitivity of the information we collect, process, and store, and the current state of technology. Our security measures include, but are not limited to: - Encryption of data in transit and at rest, where appropriate. - Access controls to limit access to information to authorized personnel based on job function and need-to-know. - Secure network architectures, including firewalls and intrusion detection/prevention systems. - Regular security assessments, vulnerability scanning, and penetration testing (as appropriate). - Employee training on data security and privacy obligations. - Incident response plans to address potential security breaches. - Adherence to recognized security standards and frameworks where applicable (e.g., principles from NIST guidelines, consideration of SOC 2 compliance for relevant systems). **Disclaimer:** Despite our efforts, it is important to understand that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. You are also responsible for maintaining the confidentiality of your account credentials. **Data Breach Notification:** In the event of a data breach that compromises your Personal Data and is likely to result in a risk to your rights and freedoms, we will notify you and relevant authorities as required by applicable law, including Wyoming's data breach notification statute (W.S. 40-12-502). Balancing robust security claims with realistic disclaimers is crucial. Referencing adherence to recognized standards or certifications, when applicable, can add credibility to security commitments without overstating guarantees. Explicitly mentioning compliance with Wyoming's data breach notification law is essential for a Wyoming corporation and demonstrates adherence to local legal obligations. **9. Data Retention** [Enrichlayer.com](http://enrichlayer.com/) will retain Personal Data and Company Data only for as long as is necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include: - **The duration of our relationship with you:** For Clients, we generally retain information for the duration of your active account and for a reasonable period thereafter to allow for account reactivation or to address any outstanding issues. - **The purposes for which we collected the information:** We retain information as long as needed to provide our Services, including maintaining the accuracy and relevance of our data enrichment products. - **Legal and regulatory obligations:** We are required to retain certain information to comply with applicable laws and regulations (e.g., tax and accounting requirements, record-keeping obligations, legal holds in anticipation of litigation). - **Resolution of disputes and enforcement of agreements:** We may retain information as necessary to resolve disputes, enforce our agreements, and protect our legal rights. - **The nature and sensitivity of the information:** More sensitive information may be subject to shorter retention periods or more stringent anonymization/deletion protocols. - **Legitimate business needs:** We may retain data for legitimate business needs, such as for archival, audit, and analytical purposes, provided these needs are balanced against the privacy interests of individuals. When information is no longer needed for these purposes, we will take reasonable steps to securely delete or anonymize it in accordance with applicable laws and our internal data disposal policies. Moving beyond vague statements like "as long as necessary," outlining the _criteria_ used to determine retention periods demonstrates a considered approach to data lifecycle management, aligning with principles like GDPR's storage limitation and FTC guidance on data minimization. **10. Your Privacy Rights and Choices** [Enrichlayer.com](http://enrichlayer.com/) is committed to providing you with control over your Personal Data. Depending on your jurisdiction and our relationship with you, you may have certain rights regarding the Personal Data we hold about you. We aim to provide a high standard of privacy protection consistent with principles found in major data privacy laws. - **Rights Available to You May Include:** - **Right to Access/Know:** You may have the right to request access to the specific pieces and categories of Personal Data we have collected about you, the sources of the information, the purposes for collecting it, and the categories of third parties with whom we have shared it. - **Right to Correction (Rectification):** You may have the right to request that we correct inaccurate Personal Data that we maintain about you. - **Right to Deletion (Erasure):** You may have the right to request that we delete Personal Data we have collected from or about you, subject to certain exceptions (e.g., where the information is necessary to provide our Services, comply with legal obligations, or for other legitimate internal uses). - **Right to Opt-Out of Sale or Sharing of Personal Data:** If [enrichlayer.com](http://enrichlayer.com/) is deemed to "sell" or "share" Personal Data as defined under applicable laws (such as the CCPA/CPRA), you may have the right to opt-out of such activities. We provide information on how to exercise this right if applicable. - **Right to Limit Use and Disclosure of Sensitive Personal Information (if applicable):** If we collect Sensitive Personal Information, you may have the right to limit its use and disclosure to certain permitted purposes. - **Right to Object to Processing:** In certain circumstances, you may have the right to object to our processing of your Personal Data, particularly if we are processing it based on our legitimate interests. - **Right to Restrict Processing:** You may have the right to request that we restrict the processing of your Personal Data under certain conditions. - **Right to Data Portability:** You may have the right to receive a copy of your Personal Data in a structured, commonly used, and machine-readable format, and to request that we transmit this data to another controller where technically feasible. - **Right to Non-Discrimination:** We will not discriminate against you for exercising any of your privacy rights. - **Opt-Out of Marketing Communications:** You can opt-out of receiving promotional emails from us by following the unsubscribe instructions provided in those emails or by contacting us directly. If you opt-out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations. - How to Exercise Your Rights: To exercise any of these rights, or if you have questions about your rights, please contact us by email at [[email protected]](mailto:[email protected]) or by mail at the address provided in Section 15 (Contact Us). We may also provide an online portal or specific web forms for submitting requests, similar to practices at other data providers. - Verification Process: For your protection, we will need to verify your identity before processing your request to ensure the security of your Personal Data. The verification process may vary depending on the nature of your request and may require you to provide certain information to confirm your identity. - Response Time: We will respond to your request within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing. For requests under CCPA/CPRA, we generally aim to respond within 45 days. Operationalizing these rights by providing clear instructions, accessible contact points, and information on verification and response times is crucial. This demonstrates a commitment to respecting these rights and builds user trust, moving beyond merely listing potential entitlements. By adopting a broad set of user rights inspired by comprehensive regulations like CCPA/CPRA and GDPR, even as a Wyoming corporation, [enrichlayer.com](http://enrichlayer.com/) enhances the policy's robustness and sophistication, preparing for potential expansion and aligning with global best practices. **11. Children's Privacy** [Enrichlayer.com](http://enrichlayer.com/)'s Site and Services are not directed to, and we do not knowingly collect Personal Data from, children. - **Age Limit:** We do not knowingly collect or solicit Personal Data from anyone under the age of 16. Some regulations, like the Children's Online Privacy Protection Act (COPPA), define "child" as an individual under 13. By setting our threshold at 16, we aim for a higher standard of protection and simplify compliance across various legal frameworks that may have differing age requirements for minors. - **No Knowing Collection:** If we learn that we have inadvertently collected Personal Data from a child under 16 without verification of parental consent (though our policy is not to collect such data in the first place), we will take steps to delete that information as quickly as possible. - **Parental Contact:** If you are a parent or guardian and believe that your child under 16 has provided us with Personal Data, please contact us immediately at [[email protected]](mailto:[email protected]) so that we can take appropriate action. COPPA imposes specific obligations on operators of websites or online services directed to children under 13, or operators that have actual knowledge that they are collecting personal information online from a child under 13. This includes requirements for parental notice and verifiable parental consent. Given that our services are business-to-business and focus on professional data, they are not intended for children. Adopting a clear "do not collect" policy for individuals under 16 provides a straightforward and protective stance. **12. International Data Transfers** [Enrichlayer.com](http://enrichlayer.com/) is based in the United States, and our Services are primarily hosted and operated in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other countries where our servers or Sub-processors are located. Data protection laws in these countries may differ from those in your country of residence. - **Safeguards for Transfers:** When we transfer Personal Data across borders, we take steps to ensure that the information receives an adequate level of protection in the jurisdictions in which it is processed. These safeguards may include: - Relying on adequacy decisions adopted by relevant authorities (e.g., the European Commission for transfers from the EEA). - Implementing Standard Contractual Clauses (SCCs) or equivalent data transfer agreements with third parties, including our Sub-processors, where required. - Obtaining your consent for the transfer, where applicable. - Ensuring that any Sub-processor involved in international data transfers provides adequate controls and security for the data. By using our Services or providing us with your information, you acknowledge that your information may be transferred to and processed in countries outside of your country of residence. Addressing international data transfers proactively, even if initial operations are primarily domestic, demonstrates foresight and preparedness for growth, aligning with the practices of sophisticated global data companies and ensuring awareness of global privacy standards like GDPR. **13. Links to Other Websites** Our Site and Services may contain links to other websites or online services that are not operated or controlled by enrichlayer.com. If you click on a third-party link, you will be directed to that third party's site or service. We strongly advise you to review the privacy policy of every site you visit. [Enrichlayer.com](http://enrichlayer.com/) has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third-party sites or services. This Policy does not apply to such third-party websites or services. This is a standard but necessary clarification to manage user expectations and limit liability. **14. Changes to This Privacy Policy** [Enrichlayer.com](http://enrichlayer.com/) may update this Privacy Policy from time to time to reflect changes in our practices, Services, or applicable laws. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this Policy. For material changes to this Privacy Policy, we may provide more prominent notice, such as by sending an email notification to our registered Clients or by posting a notice on our Site prior to the change becoming effective. Specifying how users will be notified of _material_ changes, beyond simply updating the policy date, enhances transparency and user trust. We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of our Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy. **15. Contact Us (How to Raise Privacy Concerns)** If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, or if you wish to exercise your privacy rights, please contact us using the following details: - **Email:** [[email protected]](mailto:[email protected]) - **Mailing Address:** Vertical Int, Inc 61G Avenida de Orinda Orinda, California 94563 USA Providing multiple contact channels and a dedicated privacy email address signals a commitment to addressing privacy concerns effectively and facilitates users' ability to exercise their rights. **16. Specific Information for Residents of Certain Jurisdictions** While [enrichlayer.com](http://enrichlayer.com/) is a Wyoming corporation, we recognize that individuals accessing our services or whose data we process may reside in various jurisdictions with specific privacy laws. We are committed to upholding high standards of data protection. - **Wyoming Residents:** - **Data Breach Notification:** [Enrichlayer.com](http://enrichlayer.com/) is committed to complying with Wyoming's data breach notification law, W.S. § 40-12-502. In the event of a data breach involving "personal identifying information" of a Wyoming resident, as defined by W.S. § 40-12-501(a)(vii) (which cross-references W.S. § 6-3-901(b)(iii) through (xiv)), we will provide notice as required by this statute. "Personal identifying information" under Wyoming law includes a first name or first initial and last name in combination with data elements such as a social security number, driver's license number, account number with access codes, tribal identification card, government-issued ID, biometric data, or individual taxpayer ID number, when not redacted. - **Wyoming Consumer Protection Act:** [Enrichlayer.com](http://enrichlayer.com/) strives to conduct its business in compliance with the Wyoming Consumer Protection Act (W.S. § 40-12-101 et seq.), which prohibits unfair or deceptive trade practices. We aim for transparency and accuracy in our communications regarding our data practices. - **California Residents (CCPA/CPRA Considerations):** The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants California residents certain rights regarding their personal information. While [enrichlayer.com](http://enrichlayer.com/) is a Wyoming corporation, we recognize the importance of these rights and aim to provide a high standard of privacy protection. If you are a California resident, you may have rights such as the right to know what personal information is collected, used, and shared; the right to delete personal information; the right to opt-out of the sale or sharing of personal information; the right to correct inaccurate information; and the right to limit the use of sensitive personal information. For inquiries regarding how these principles apply to your data, please contact us at [[email protected]](mailto:[email protected]). - **European Economic Area (EEA), United Kingdom (UK), and Switzerland Residents (GDPR Considerations):** If you are located in the EEA, UK, or Switzerland, your Personal Data may be protected by the General Data Protection Regulation (GDPR) or similar local laws. [Enrichlayer.com](http://enrichlayer.com/) is committed to processing such data in accordance with GDPR principles, including lawfulness, fairness, and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity and confidentiality; and accountability. If GDPR applies to our processing of your Personal Data, you have rights such as the right to access, rectification, erasure, restriction of processing, data portability, and the right to object to processing. For inquiries regarding these rights, please contact us at [[email protected]](mailto:[email protected]). Our processing activities are typically based on legitimate interests, performance of a contract, or consent, depending on the context. Including specific information for Wyoming residents, particularly referencing local statutes like the data breach notification law and its definition of "personal identifying information", demonstrates local legal adherence. Furthermore, proactively acknowledging key principles from major privacy regimes like CCPA/CPRA and GDPR, even if not directly and fully applicable to all operations initially, significantly enhances the policy's sophistication and thoroughness. This approach signals an awareness of the broader privacy landscape, prepares the company for future growth, and aligns with the practices of leading data providers. --- This Privacy Policy is intended to provide clear and comprehensive information about our data practices. We encourage you to read it carefully.