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DATA PRIVACY


FREQUENTLY ASKED QUESTIONS

Enlyft, Inc. (“Enlyft,” “us” or “we”) provides a platform with a data interface
and integrations for sales and marketing (the “Platform”) to offer our clients
rich, deep, and reliable data (the “Enlyft Data”) to find their ideal customers
and support their business goals. This page provides answers to frequently asked
questions about Enlyft’s processing and your options to opt out.

HOW DID ENLYFT GET MY INFORMATION?

Enlyft collects your information within Enlyft Data is either directly from you
or 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. You can learn more about our trusted data sources
in our Privacy Policy.

HOW DOES ENLYFT PROCESS MY INFORMATION?

Enlyft collects professional contact information that professionals post about
themselves online for access and use by the public. Enlyft curates that data for
inclusion on the Platform for our Clients to identify professional contacts at
companies that they may wish to prospect as part of a sales or marketing
campaign.  

WHAT IS ENLYFT’S LEGAL BASIS FOR THIS PROCESSING?

Enlyft has a legitimate interest in its processing of this information to enable
Enlyft customers to engage in more effective and meaningful direct marketing, as
established by our Legitimate Interest Assessment.

HOW MIGHT THE PROCESSING IMPACT ME?

Enlyft designed the processing to minimize the impact on data subjects. The
information is processed and used for the same purposes for which the data
subject originally posted the information online and in a manner that minimizes
impact on the data subject so that all parties to the processing may benefit
from its results. You may experience increased professional visibility, or you
may be contacted by other professionals for business opportunities. Data
subjects can opt out at any time. As such, the processing will produce a minimal
impact and should have a positive or neutral outcome for all involved.

HOW DO I OPT OUT OF THIS PROCESS?

 * Visit our Check Email page to learn whether Enlyft holds your data
 * Enter your email and click to submit.  
 * If Enlyft holds your data, you will be notified via email and provided with a
   link to Opt-out or have your data removed from our databases. 
 * You will receive a confirmation that the data has been removed within 30
   days.

Questions? For more information, please contact privacy@enlyft.com.  


LEGITIMATE INTEREST ASSESSMENT

‍Enlyft, Inc. conducted a Legitimate Interest Assessment (LIA) for processing
data in accordance with the General Data Protection Regulation (GDPR).
‍
Key points from the LIA include:

‍Purpose of Processing:
‍Enlyft designed its sales and marketing data platform (the "Platform") to offer
Clients - rich, reliable company data for business goals. This LIA demonstrates
Enlyft's compliance with GDPR accountability obligations when processing
personal data as a controller. This LIA confirms that Enlyft’s processing of
business profile information satisfies the grounds for the processing of
personal data for a legitimate interest. It also determined that this legitimate
interest is not overridden by the interests or fundamental rights and freedoms
of the data subject which requires protection of personal data.

Description of Processing:
‍Enlyft collects and curates professional contact data from online sources to
offer Clients enriched information for direct marketing campaigns. Data is
obtained from public profiles, databases, and third-party vendors after thorough
due diligence.

Legal Basis:
‍Enlyft relies on Article 6(1)(f) of GDPR, which allows processing for
legitimate interests pursued by the controller or a third party unless
overridden by the data subject's rights. A three-part test from the Information
Commissioner's Office is used to assess legitimacy:


 * Purpose Test: Enlyft processes data to enable more effective direct marketing
   for Clients.
 * Necessity Test: Processing automates and streamlines marketing efforts,
   benefiting both Clients and professionals.
 * Balancing Test: Enlyft's processing is reasonably expected by professionals
   who posted data publicly for similar purposes.


Purpose Test:
‍Enlyft's processing provides Clients with valuable data for prospecting and
direct marketing. The processing benefits Clients, Enlyft, professionals whose
data is processed, and fosters business connections.

Necessity Test:
‍Automated processing is essential for efficient and effective direct marketing.
Enlyft's approach is proportionate, minimizes data collection, and enhances
meaningful connections.

Balancing Test:
‍Enlyft's processing respects professionals' expectations, control, and privacy
rights. Professionals are notified and can opt-out of processing. Impact is
minimal, and Enlyft implements safeguards to protect data according to industry
standards. Enlyft only processes Personal Data in a manner that is reasonably
expected by the professionals that posted it publicly online. Enlyft limits the
processing only to professional contact information. We never process sensitive
or private information.

Enlyft's Legitimate Interest:
‍Enlyft establishes that legitimate interest is a legal basis for processing
personal data. The processing aligns with professionals' expectations and
original intentions. Automated technologies are used responsibly, and
professionals have control over their data. Enlyft's processing is justified by
the benefits and protections provided.

This summary captures the core aspects of Enlyft's Legitimate Interest
Assessment, highlighting their compliance with GDPR while ensuring transparency
and respect for individuals' rights and interests.

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