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ENLYFT, INC. PRIVACY POLICY



LAST UPDATED: AUGUST 29, 2023

At Enlyft, we take pride in the accuracy and integrity of the data we offer to
our clients (each a “Client”). This Privacy Policy explains how we collect and
treat information through our sales and marketing data interface and
integrations (the “Platform”), enlyft.com and other online channels we own or
operate (collectively, the “Site”), as well as other services we offer
(altogether, with the Platform and Site, our “Services”). This Privacy Policy is
governed by and part of our Terms of Service. Any terms defined in the Terms of
Service have the same meaning when used in this Privacy Policy.

You consent to our privacy practices described in this Privacy Policy by
accessing our Site, registering on our Platform, providing us with your Personal
Data, or allowing us to process your Personal Data following receipt of a notice
from Enlyft that your Personal Data is included in our records. If you do not
agree with this Privacy Policy, do not access or use our Services. To learn
whether your Personal Data is included on our Platform, or to opt-out of
processing by Enlyft, please visit our Verify Information page.

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 Data is captured within the data collected and made available via
our Platform (the “Enlyft Data”). To ensure you have complete confidence in the
Enflyt Data and our privacy practices, we offer this privacy promise to you:

·       Human Element: 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.

·       Trusted Data Sources: Your Personal Data within Enlyft Data is either
provided to Enlyft by you or is professional information collected 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.

·       Privacy is Key: Enlyft will never collect or disclose Personal Data that
was meant to remain private.

·       No Mass Marketing: 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’re In Control: You can always control your Personal Data on Enlyft.
As part of our commitment to data integrity, we encourage you to submit requests
to privacy@enlyft.com to correct or delete Personal Data within the Enlyft Data.

·       Enlyft as Controller: When we collect Personal Data from your visit to
our Site or to include in the Enlyft Data for use by our Platform Clients, we do
so as a data controller. This Privacy Policy describes how Enlyft treats that
Personal Data..

·       Enlyft as Processor: When our Custom Solutions Clients use Enlyft Data,
we act as a processor or service provider to the Custom Solutions Client.

·       Your Rights: Enlyft welcomes your requests to restrict our use or
processing of your Personal Data in accordance with your privacy rights (see
Section 6).

If you have questions about this Privacy Policy or any of our Services, please
contact us at privacy@enlyft.com.

1.     Personal Data

As used in this Privacy Policy, “Personal Data” means information that
identifies, relates to, describes, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular
consumer or household. Personal Data falls within certain categories, for
example:

·       Identifiers (e.g., name, email, telephone number, address, username);

·       Sensitive Personal Data (e.g., government identification number; precise
geolocation; racial or ethnic origin; religious beliefs; health data; contents
messages when Enlyft is not the recipient);

·       Legally protected information (e.g., race, citizenship, marital status,
sex);

·       Employment-related information (e.g., current or past employment);

·       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);

·       Biometrics (e.g., DNA, face/voice prints, health data) and audio,
electronic, visual, thermal, or olfactory information;

·       Commercial information (e.g., products or services purchased, obtained,
or considered, or other purchasing or consuming histories or tendencies);

·       Internet or other similar activity (e.g., browsing history; content
interactions); and

·       Inferences drawn from Personal Data to create a profile about
preferences, characteristics, trends, predispositions, behavior, attitudes,
intelligence, and aptitudes.

Not all information is protected as Personal Data under privacy laws.
Information may not be covered by the privacy laws applicable to you if it is:
(a) publicly available; (b) aggregated information, meaning data summaries or
reports with the Personal Data removed; or (c) anonymized or de-identified.  

2.    Collection and Use of Personal Data

a.    Categories of Personal Data Collected

Enlyft may collect Personal Data: (i) with your consent; (ii) if we have a
legitimate interest in doing so; or (iii) as authorized or required by law. We
only collect, use, retain, and disclose Personal Data as is adequate and
relevant to the specific, express purposes described below or 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 Data.

b.   Sources of Collection

During the preceding 12 months, we have collected Personal Data in the following
categories: (i) identifiers; (ii) employment-related information; (iii)
commercial information, (iv) internet or similar activity; and (v) inferences.
Our sources of collection include:

·      Client’s use of the Platform. When a Client uses the Platform to
discover, prioritize, and engage prospects, Enlyft collects commercial
information such as the Client’s prospect profiles and interactions with
prospects, and internet and similar activity like 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.

·      Custom Solutions Clients. If you are a Custom Solutions Client, Enlyft
will collect the Personal Data 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 Data 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.

·       Our Data Sources. Enlyft uses trusted third-party data vendors and
public data sources (each a “Data Source”) to collect data about professional
contacts at companies that our Platform Clients may wish to prospect as part of
a sales or marketing campaign. Enlyft executes contracts with each Data Source
after a rigorous due diligence process focused on lawful privacy practices and
data integrity. In all other cases, Enlyft uses automated technology to collect
and generate Enlyft Data from publicly available online sources and methods,
such as publicly available professional profiles and other online databases. All
Personal Data collected in this manner is processed in alignment with the
purposes for which the professional posted it online, and Enlyft processes the
Personal Data in the same manner as if a human user manually views and analyzes
the information. Enlyft processes the Personal Data included in this data with a
legitimate interest to provide our Platform customers with the richest, deepest,
and most reliable company data to support Clients’ business goals.

·       Our Clients or Resellers. Clients and Resellers of our Services may
provide Enlyft with professional contact information about their subsidiaries,
affiliates, or other organizations (“Contacts”). Contacts’ information is shared
with Enlyft according to the privacy practices of each Client or Reseller.
Enlyft may combine this information with Personal Data we previously collected
about the Contact from other sources. Enlyft receives Contacts information only
for processing as instructed by the Client or Reseller. If Enlyft uses Contact
information as a controller, we provide supplemental notice and ensure a lawful
basis for processing the information.

·       Your communications with Enlyft. 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.

·       Automatically from your Site visit, with a legitimate interest. Enlyft
may automatically collect details about your interactions through the Site or
Platform, including your (i) browsing history; (ii) content interactions; (iii)
device information (e.g., IP address, operating system, browser type, device ID,
mobile network information, caller ID); (iv) usage details (e.g., traffic data,
communication data and the features or resources you access and use); and (v)
stored information (e.g., metadata). Like most commercial online services,
Enlyft use cookies and other technologies to track use of our Site. Please read
our Cookie Notice for more information about how we use cookies. We collect this
information to achieve our legitimate interest of providing and improving our
Services. We may also use this information to deliver targeted advertising
according to your communication preferences.

Enlyft will not collect additional categories of Personal Data or use already
collected Personal Data for purposes that are materially different, unrelated,
or not reasonably necessary or compatible with the original purpose without
notice and consent to you as required by law. Enlyft might also use your
Personal Data to (i) monitor your compliance with any of your agreements with
us; (ii) protect your privacy and enforce this Privacy Policy; (iii) if we
believe it is necessary, to identify, contact, or bring legal action against
persons or entities who may be causing injury to you, to us, or to others; (iv)
comply with a law, regulation, legal process, or court order; or (v) fulfill any
other purpose to which you consent.

3.    Children’s Privacy

Our Services are designed for adults, not children. Enlyft does not knowingly
collect Personal Data from children under 16, and we will delete that
information if we learn we have collected it. If you believe we have received
information from a child under 16 or other unauthorized information, please
contact privacy@enlyft.com.

4.    Retention of Personal Data

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 Data 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 Data, 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.

5.    Disclosing Personal Data

Enlyft will only disclose Personal Data 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 for a sales or marketing
campaign matches with your Personal Data contained in Enlyft Data, that Client
may access your Personal Data on the Platform. Clients control their own
prospect profiles and choose which Enlyft Data to access and how to use that
data subject to the Client’s own privacy practices.

b.   Service Providers. Enlyft’s third-party service providers (e.g., data
hosting companies, analytics services, fraud prevention vendors, and payment
processors) may have access to your Personal Data to perform their contractual
obligations to us. 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 Data,
and we require all service providers to maintain confidentiality standards and
organizational measures to ensure the security of your Personal Data. Our
service providers are prohibited from selling or disclosing the Personal Data we
provide.

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.

f.     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.

6.    Your Privacy Rights

a.    Controlling Your Personal Data

Enlyft provides you a variety of methods and options to directly control how we
collect and use your Personal Data, including but not limited to:

·       Client 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 Data
associated with your account at any time. If you require assistance, please
contact privacy@enlyft.com.

·        Check Email. To learn if you are included in the Enlyft Directory,
visit our Check Email page and follow the instructions.

·       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
privacy@enlyft.com.

·       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.   Privacy Requests

To express concerns, lodge a complaint, or request information, please contact
Enlyft at privacy@enlyft.com. To exercise your rights under your applicable
privacy laws beyond the methods described above, please follow the instructions
below:

·       When Clients use Enlyft, If a Client contacts you as part of a sales or
marketing campaign or for any other reason, please submit your request directly
to the Client. ENLYFT CANNOT FULFILL A REQUEST RELATED TO A CLIENT’S USE OF YOUR
PERSONAL DATA. In these cases, Enlyft acts a service provider or processor only,
and the Client is the controller. The Client is solely responsible for its own
use of our Services, including all processing of Personal Data by the Client
using our Services.

·       When Enlyft is the controller, meaning we use your Personal Data for our
marketing or sales or we process your Personal Data via a Data Source, please
submit your request to privacy@enlyft.com.

Enlyft can only fulfill a 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 Data, and to properly understand,
evaluate, and respond to the request. We do not charge a fee to process or
respond to a request unless we have legal grounds to do so. We endeavor to
respond to Privacy Requests in accordance with the requirements of the law
applicable to your jurisdiction. Note that Enlyft collects Personal Data as a
controller or business from publicly available sources and/or in a
business-to-business context. As such, privacy rights may not extend to Personal
Data in some cases.

c.    United States Consumer Privacy Rights California and Certain Other U.S.
States

In the United States, consumer privacy is governed by federal privacy laws
covering specific industries or data uses and state privacy laws providing
general consumer privacy rights. This section provides general notices under
state privacy laws that require companies to inform consumers about their
privacy rights and provide a method to exercise those rights. Residents of
states offering privacy protections (each a “Consumer”) may have some or all the
following rights over their Personal Data:

·      Right to Correct. You have the right to request that we correct
inaccurate Personal Data about you on our systems. If you become aware that the
Personal Data that we hold about you is incorrect, or if your information
changes, please inform us and we will update our records.

·      Right to Deletion. You have the right to request that we delete the
Personal Data that we collected and retained, with certain exceptions. Enlyft
may permanently delete, deidentify, or aggregate Personal Data in response to a
request for deletion.

·      Right to Access. You have the right to request confirmation that we have
collected Personal Data about you and that we provide you with access to that
Personal Data. If you submit an access request, we will provide you with copies
of the requested pieces of Personal Data in a portable and readily usable
format. Please note that Enlyft may be prohibited by law from disclosing certain
pieces of Personal Data, and we may be limited in the number or frequency of
requests we must fulfill.

·      Right to Disclosure. You may request that we disclose information to you
about our collection and use of your Personal Data, such as: (a) the categories
of Personal Data we have collected about you; (b) the categories of sources for
the Personal Data we have collected about you; (c) our business purpose for
collecting, using, processing, sharing or selling that Personal Data, as
applicable; (d) the categories of third parties with whom we share that Personal
Data; and (e) if we sold or shared your Personal Data under the CCPA, two
separate lists stating: (i) sales or sharing, identifying the Personal Data
categories that each category of recipient purchased; and (ii) disclosures for a
business purpose, identifying the Personal Data categories that each category of
recipient obtained. Certain laws may limit the number or frequency of requests
we must fulfill.

·      Limited Use and Disclosure of Sensitive Personal Data. You have the right
to opt-out or limit our use of your sensitive Personal Data. Enlyft may collect
or receive Personal Data from you that qualifies as sensitive Personal Data
under privacy laws. Enlyft does not and will not disclose any sensitive Personal
Data for the purpose of inferring characteristics about you or otherwise use
your sensitive Personal Data without your consent. We only use this Personal
Data to provide the Services and, where we process the Personal Data for a
covered entity, in compliance with HIPAA controls. If this ever changes in the
future, we will update this Privacy Policy and provide you with methods to
opt-out or limit our use and disclosure of sensitive Personal Data.

·      No Selling or Sharing Personal Data. Some states entitle consumers to opt
out of the sale or sharing of Personal Data or targeted advertising practices.
Enlyft does not sell your Personal Data or share your Personal Data with third
parties for cross-contextual behavioral advertising purposes. If this changes in
the future, we will update this Privacy Policy and provide you with a method to
opt-out.

·      No Patient Profiling. You have the right to opt-out of automated
profiling. Enlyft does not process your Personal Data to evaluate, analyze, or
predict your interests and preferences or otherwise use automated profiling to
produce significant effects that concern you. If this changes in the future, we
will update this Privacy Policy and provide you with a method to opt-out.

·      Right to Nondiscrimination. We will not discriminate against you for
exercising your privacy rights. For example, 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; (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 applicable privacy laws.

·      Health Data Rights. Enlyft does not collect any health data. As a
courtesy notice, some state laws entitle consumers to certain details about
health data collected about them, including (i) confirmation of whether the
entity collects, shares, or sells the consumer’s health data and access that
data, including a list of all third parties and affiliates with whom the entity
has shared or sold the health data and a method to contact those third parties,
(ii) a method to withdraw consent related to use of health data, and (iii) the
right to have their health data be deleted.

·      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 Data sharing with affiliates
and/or third parties for marketing purposes.

Consumers may exercise these rights by submitting a verifiable Privacy Request
to Enlyft. We will respond within the legally required timeline to the extent
the applicable law applies to you and our business activities. If your Privacy
Request is not addressed in a timely manner, you can appeal it by contacting
privacy@enlyft.com.  

d.   Canadian Privacy Rights

We adopted this section to provide supplemental information in compliance with
Canada’s Personal Data 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
Data 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 know why we collect, use, and distribute the Personal Data we
process. We have set the required notices in this Privacy Policy. We may provide
you with additional notices about other ways we process your Personal Data, such
as by sending you a notice via email or by other means of communication.

·       Right to expect us to collect, use, or disclose Personal Data
responsibly and not for any other purpose other than which you consented. We set
your expectations in this Privacy Policy and collect express or implied consent
at various stages of collection or processing. If we collect or use your
Personal Data based on your consent, we will also notify you of any changes and
will request your further consent as needed. You may withdraw your consent at
any time with reasonable notice by contacting us at privacy@enlyft.com.

·       Right to accuracy of your Personal Data. We take steps to reasonably
ensure that your Personal Data 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 Data
in your account, and we will provide you with reasonable assistance to ensure
that your Personal Data is accurate in our systems and with our service
providers.

·       Right to access your Personal Data. Upon written request and identity
authentication, we will provide you with your Personal Data 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 fulfill 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 Data 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 Privacy Rights

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 European Union and the
European Economic Area and the United Kingdom (“Data Subjects”). If you are a
Data Subject, you have the following rights in relation to the Personal Data we
hold about you:

·       Right to know how we process your Personal Data. We have set the
required notices in this Privacy Policy. We may provide you with additional
notices about other ways we process your Personal Data, such as by sending you a
notice via email or by other means of communication. We notify Data Subjects via
email that their Contact Information has been added to the Enlyft Directory and
may be used by third parties to contact them. Learn more about Enlyft email
notification.

·       Right to access your Personal Data. You can request to access your
Personal Data. Upon request, we will provide you with a copy of your Personal
Data, along with details about the types of Personal Data we process, why we
process it, and any third parties we work with to collect Personal Data 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 Data. You can request that
we restrict the processing of your Personal Data if: (i) the data is inaccurate;
(ii) the processing is unlawful; (iii) we no longer need the Personal Data; or
(iv) you exercise your right to object.

·       Right to rectify your Personal Data. If you become aware that the
Personal Data 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 Data 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 Data. This right is not absolute, and we
may be entitled to retain and process your Personal Data 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 Data.

·       Right to object to certain processing of your Personal Data. 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 Data 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 Data processed using ADM.

If you are a resident of the EEA and you believe we are unlawfully processing
your Personal Data, 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.

‍7.     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.

We use Google Analytics and other software to understand the usage of our
service and improve the user experience. This applies to both pages where you
are signed into our service and pages where you are not signed in. For more
information on how Google Analytics collects and processes data, please visit
How Google uses data when you use our partners and the Smartlook Privacy Policy.
You may opt-out of Google Analytics by visiting the Google Analytics opt-out
page or by adjusting your device settings.

8.     Data Security

Enlyft has implemented and maintains reasonable and appropriate security
procedures and practices to help protect your Personal Data from unauthorized or
illegal access, destruction, use, modification, or disclosure. Our security
measures are appropriate to the volume, scope, and nature of the Personal Data
processed and designed to meet our duty of care with respect to your Personal
Data. 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 Data 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 Data 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.

9.    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
the Platform or any of our other Services from outside of the U.S., please be
aware that the Personal Data 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 Data 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 committed to transferring Personal Data using a lawful data transfer
mechanism. Specifically, when we transmit data from the European Economic Area
(“EEA”) to the U.S. or other jurisdictions, we do so pursuant to standard
contract clauses approved by the European Commission and employ those security
measures required by the country in question to secure the data. To the extent
that Enlyft is deemed to transfer Personal Data from the 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.

However, Enlyft does do not warrant that the Platform or our other Services are
appropriate or authorized for use in any other jurisdictions. Each Client and
other users are solely responsible for determining whether their use of our
Services complies with applicable laws. Your use of our Services constitutes
your consent to the transfer and processing of your Personal Data as described
in this section.

10.  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.

11. Changes to this Privacy Policy

Enlyft reserves the right to amend this Privacy Policy at any time by updating
this posting without notice and revising the last updated date. All changes are
effective immediately when posted and apply to all access to and use of our
Services. Your continued use of our Services following the posting of changes
constitutes your acceptance of such changes.

With regards to data privacy, please refer to:  Frequently Asked Questions
(FAQs).

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