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PRIVACY AT ENIGMA

Date of Last Update: May 10, 2023

We at Enigma (“we,” “us,” or “our”) understand that you care about protecting
your information. This privacy policy (“Privacy Policy”) explains how Enigma
collects, shares, and protects information about companies and individuals that
may include your information. This includes the information we collect when you
visit our website, www.enigma.com, or purchase and/or use our services
(“Services”), as well as the information we collect to enable our Services. When
you visit our website and use our Services, you agree to this Privacy Policy. 

Use of our website or Services is governed by our Terms of Service. Capitalized
terms not defined in this Privacy Policy shall have the meaning set forth in our
Terms of Service. 

Applicability – Legal Entities

For purposes of this Privacy Policy, “Enigma” includes Enigma Technologies,
Inc., a Delaware corporation, and its affiliates.

Our Purpose for Collecting Information

Enigma collects information to provide business intelligence products to our
customers. Our Services primarily enable our customers to better understand who
their existing and prospective customers are, verify the identity, health, and
risk profile of third party companies, improve their sales and marketing
outreach to existing and prospective customers, meet their compliance and
regulatory obligations, and manage their financial and operational risks.

Enigma also collects information to provide customer support, maintain and
improve our website and Services, solicit your feedback, and inform you about
new Services or changes to existing Services.

Some of the information collected and provided may be considered personal
information under applicable privacy laws, and the information is described in
greater detail below.

The Information We Collect:  What We Collect and How We Collect It

In general, Enigma collects information regarding U.S. businesses and users of
our website and Services. The information we collect is (a) provided directly by
you through visits to our website, use of our Services, or engagement with our
marketing or sales activities, (b) acquired or licensed from third-party data
providers, and/or (c) government record, public domain, and other publicly
available information.

The specific categories of information Enigma collects, and their sources, are
described below.

 * Information About U.S. Businesses:  Through publicly available information,
   such as government records, and licensed data from third-party data
   providers, Enigma collects information about U.S. companies, such as their
   business name, business aliases, business addresses, business phone numbers,
   corporate registrations, registered agents and other associated persons, 
   business email addresses, and other business contact information, revenue and
   transaction information, and other business-related information. More
   information about our business data can be found in product documentation.

 * Information You Provide Through Our Website:  When you visit our website, we
   automatically collect certain information that, on its own, cannot be used to
   identify you. Examples of such information include IP address, browser type
   and language, referring and exit pages and URLs, the particular pages of our
   website that you visit and the time spent on each, and similar information
   concerning your use of the website. We also collect “cookies” - small data
   files that a website stores on the hard drive of your computer or mobile
   device to “remember” information about your visit. If you do not want us to
   place a cookie on your hard drive, you may be able to turn that feature off
   on your computer or mobile device. Please consult your Internet browser’s
   documentation for information on how to do this and how to delete persistent
   cookies. Please note, however, that if you decide not to accept cookies from
   us, our website and/or Services may not function properly.

 * Personal Information You Provide Through Our Website:  When you engage with
   our website by, for example, choosing to contact us, you may be asked to
   provide additional information, such as your name and email address. When you
   provide this information, Enigma may link it to the information we collect
   automatically through our website (described above).

 * Personal Information You Provide Through Your User Account:  To purchase
   and/or use our Services, including both free and paid Services, you may be
   required to create a User Account. Upon creation of a User Account, Enigma
   collects certain account-level information, including your name, email
   address, your organization name, and a password. As with the rest of our
   website, Enigma will automatically collect information associated with any
   subsequent use of your User Account, such as features used, billable events,
   IP address, and other account-related and logging information. 

 * Payment Information:  To purchase our Services, you may be required to submit
   credit card and other payment information (e.g., billing zip code). This
   information is collected and processed by our third-party payment processor
   operating as our agent (See, Onward Transfers to Third-Party Service
   Providers). Enigma does not obtain or store your full payment information.

 * Information You Provide Through Using Our Services: If you use Enigma
   Services, we may also obtain information directly from you in connection with
   your use of the Services (e.g., through searches, queries, or requests for
   matching business information). Our use of such data in general includes use
   of the data as needed to provide services to the customer providing it,
   providing customer service, maintaining required audit records for legal,
   financial, and operational controls, and improving our products and services.
   Notwithstanding our use of such data in general, our use of data obtained in
   this way from you is subject to applicable service agreement(s) between you
   and us, including personal information data processing agreements as
   applicable.

 * Personal Information You Provide Through Marketing or Sales Activities: 
   Enigma may collect your personal information, including name, company, and
   email address, when you engage with marketing activities, such as subscribing
   to company updates or alerts or downloading a white paper. Enigma may collect
   similar information through sales activities, such as phone conferences or
   meetings. 

 * Personal Information Accessible Through Third-Party Providers: If you
   register for the Services and grant Enigma access to accounts you have with
   third-party providers (e.g., data brokers, third party partners,
   co-branding/marketing partners, service providers), including providers of
   social networking services (“Third-Party Providers”), we may receive personal
   information that you provided to such Third-Party Providers, or information
   that is posted on your accounts with them which is viewable on or through the
   Services, subject to the privacy policies of such Third-Party Providers and
   privacy settings you have chosen in your accounts with them. If applicable,
   by granting us access to your Third-Party Provider accounts, you are
   authorizing Enigma to collect, store, and use, in accordance with this
   Privacy Policy, any and all information that you have authorized the
   Third-Party Provider to provide to Enigma. 

How We Use and Disclose Your Information

Enigma collects the categories of information described above to operate our
website and Services, including delivering intelligence on U.S. businesses to
customers, providing business-to-business contact information for sales and
marketing purposes, responding to user inquiries, providing customer service,
performing administrative functions, and personalizing your user experience. 
Enigma also uses and discloses personal information as further described in this
section.

Third-Party Analytics and Remarketing: We use one or more third–party analytics
services to evaluate your use our website and the Services, compile reports on
activity (based on their collection of IP addresses, Internet service provider,
browser type, operating system and language, referring and exit pages and URLs,
data and time, amount of time spent on particular pages, what sections of the
website you visit, number of links clicked while on the website, search terms
and other similar usage data), and analyze performance metrics. These
third-party vendors may combine this data across multiple sites to improve
analytics for their own purpose and others. For example, we use Google Analytics
on our website to help us understand how users interact with our website; you
can learn how Google collects and uses information at
www.google.com/policies/privacy/partners. Additionally, these third parties use
cookies and other technologies to help analyze and provide us with the data. By
visiting our website, and accessing and using the Services, you consent to the
processing of data about you by these analytics providers in the manner and for
the purposes set out in this Privacy Policy. 

We also use one or more third-party marketing services to advertise on
third-party websites. These third-party marketing service providers may use
cookies to serve ads. For example, we use Demandbase in connection with our
advertising activity; you can learn more about Demandbase by reviewing their
privacy notice and more about opting out from third party ad cookies here:
https://optout.aboutads.info/. Any data collected by such third-party marketing
service providers will, to the extent relating to our website and Services, be
used in accordance with this Privacy Policy and, in general, the privacy policy
of such third-party marketing services provider. 

We disclose personal information with your consent, or as we determine necessary
to provide Services or complete your transactions and requests. In addition, we
may disclose each of the categories of personal information described in The
Information We Collect: What We Collect and How We Collect It section above, to
the types of third parties described below, for the following business purposes:

 * Disclosures to Customers: Because we license business data to our customers
   as part of our products and Services, this may include information that is
   considered personal information under applicable privacy laws. While our
   focus is on business information, certain types of information, including
   business-to-business contact information, may be considered personal
   information under applicable privacy laws. In such a case, fulfillment of
   such products and Services may necessitate or constitute a disclosure of
   personal information to our customers, and depending on applicable privacy
   laws, may also be considered a sale or sharing of personal information under
   such laws. More information about our business data that we license can be
   found in product documentation.

 * Sharing of Aggregate Data:  We may analyze the information you provide
   through our website and Services in aggregate form in order to operate,
   maintain, manage, and improve the site and Services. This aggregate
   information does not identify you personally. We may share this aggregate
   data with agents and business partners. We may also disclose aggregated user
   statistics in order to describe our Services to current and prospective
   business partners and other third parties for other lawful purposes. In
   addition, we may provide aggregated statistical collective user information
   to our partners so that they understand how often people use specific
   components of our Services.

 * Onward Transfer to Third-Party Service Providers:  Like many businesses, we
   contract with other companies to perform certain business-related services.
   We may disclose information, including personal information in some cases, to
   certain types of third-party companies, to the extent needed to enable them
   to provide such services, including, without limitation, monitoring and
   analyzing website activity, operations and marketing assistance, hosting
   provider, and payment processing. We may also disclose your information,
   including any personal information, to any of our parent companies,
   subsidiaries, joint ventures, or other companies under common control with us
   in order to support delivery of our products and Services.

 * Business Transfers: In the event of a merger, dissolution, or similar
   corporate event or the sale of all or substantially all of our assets, we
   expect that the information that we have collected and/or received, including
   personal information, would be transferred to the surviving entity in a
   merger or to the acquiring entity.  All such transfers shall be subject to
   our commitments with respect to the privacy and confidentiality of such
   personal information as set forth in this Privacy Policy.

 * Disclosures to Public Authorities: In certain situations, we may be required
   to disclose personal information in response to lawful requests by public
   authorities, including to meet national security or law enforcement
   requirements. We may also disclose personal information to other third
   parties when compelled to do so by government authorities or required by law
   or regulation, including, but not limited to, in response to court orders and
   subpoenas. 

Your Rights, Choice, and Control of Personal Information

Access, portability, correction, and deletion. If you wish to access, correct,
or delete personal information about you that we hold, you can make a request by
e-mailing privacy@enigma.com or sending a request to Enigma Technologies, Inc.
at 217 Centre Street, Suite 124, New York, NY 10013, ATTN: Legal.

Notice at Collection: At or before the time of collection, you have a right to
receive notice of our practices, including the categories of personal
information to be collected, the purposes for which such information is
collected or used, including whether such information is sold or shared, and how
long such information is retained. You can find those details in this Privacy
Policy by clicking on the above links. 

Opt-Out for Direct Marketing: You may opt out at any time from the use of your
personal information for direct marketing purposes by e-mailing the instructions
to this email address: privacy@enigma.com or by clicking on the “unsubscribe”
link located on the bottom of any Enigma marketing email.  Please allow us a
reasonable time to process your request. Please also note that we may continue
to send you transactional or service-related e-mails despite your desire not to
receive promotional or marketing related e-mails.

Right to Know: You may have a right to request that we disclose to you the
personal information we have collected about you. You also have a right to
request additional information about our collection, use, disclosure, or sale of
such personal information. Note that we have provided much of this information
in this Privacy Policy. You may make such a “request to know” by e-mailing
privacy@enigma.com or sending a request to Enigma Technologies, Inc. at 217
Centre Street, Suite 124, New York, NY 10013, ATTN: Legal.

Rights to Request Correction or Deletion: You may have the right to request that
we correct inaccurate personal information and that we delete personal
information under certain circumstances, subject to a number of exceptions.
Depending on the circumstances and nature of a correction request, we may offer
to delete personal information rather than correct it. You may make a request to
correct or delete by e-mailing privacy@enigma.com or sending a request to Enigma
Technologies, Inc. at 217 Centre Street, Suite 124, New York, NY 10013, ATTN:
Legal.

Right to Opt-Out / “Do Not Sell or Share My Personal Information”: You may have
a right to opt-out from future “sales” or “sharing” of personal information as
those terms are defined under applicable privacy laws. Some of these laws define
“sell,” and “share” very broadly, and some of our data disclosures described in
this Privacy Policy may be considered a “sale” or “sharing” under those
definitions. 

In particular, we may include personal information in certain of the products
and services we license to our customers so they can obtain insights about
businesses and individuals associated with the businesses. While our focus is on
business information, certain types of information, including
business-to-business contact information, may be considered personal information
under applicable privacy laws. These categories of personal information are
described in “The Information We Collect:  What We Collect and How We Collect
It” section above, under the “Information about Businesses” category. 
Disclosure information is further described in the “How We Use and Disclose Your
Information” section above, under the “Disclosures to Customers” category.

If you do not want us to “sell” or “share” personal information about you to our
customers and other third parties, please visit our Do Not Sell or Share My
Personal Information webpage. If you opt-out using these choices, we will not
share or make available such personal information in ways that are considered a
“sale” or “sharing” under applicable law. However, we may continue to make
available to our service providers some personal information to help us perform
customer support, payment processing, analytics, and other business functions on
our and our customers’ behalf. Further, using these choices may not opt you out
of the use of previously “sold” or “shared” personal information or stop all
solicitations, marketing communications or advertising.

You may designate, in writing or through a power of attorney, an authorized
agent to make requests on your behalf including for some of the rights described
in this section. Before accepting such a request from an agent, we will require
the agent to provide proof you have authorized it to act on your behalf, and we
may need you to verify your identity directly with us.

Further, to provide, correct, or delete specific pieces of personal information
we will need to verify your identity to the degree of certainty required by law.
We will verify your request by asking you to send it from the email address
associated with your information or requiring you to provide additional
information necessary to verify your identity. 

You will not be discriminated against for exercising the rights noted in this
section.

Information Security

Enigma takes commercially reasonable security measures to protect personal
information from unauthorized access and disclosure. These measures include the
implementation of reasonable technical, physical, and administrative data
security safeguards that are consistent with our business operations and
industry standards.

While we take reasonable precautions, no method of internet transmission or
electronic storage is 100% secure or error-free. We therefore cannot guarantee
your information’s absolute security and encourage you to take special care in
deciding what information you send to us via e-mail or other electronic means. 

Retention of Personal Information

We will retain your personal information in a form that identifies you for as
long as it serves the purposes for which it was initially collected as stated in
this Privacy Policy or subsequently authorized. We will retain and use your
information as necessary to comply with our legal obligations, resolve disputes,
and enforce our agreements. 

Links to External Websites 

Our website and the Services may contain links to third-party websites
("External Sites"). Enigma has no control over the privacy practices of these
External Sites. As such, we are not responsible for the privacy policies of
those External Sites. You should check the applicable third-party privacy policy
and terms of use when visiting any External Sites, and before providing any
personal information to such External Sites.

Children 

We do not knowingly collect any personal information from children under the age
of sixteen through our website and the Services. If you are under the age of
sixteen, please do not give us any personal information. We encourage parents
and legal guardians to monitor their children's Internet usage and to help
enforce our Privacy Policy by instructing their children never to provide
personal information to us without their permission. If you have reason to
believe that a child under the age of sixteen has provided personal information
to us, please contact us at privacy@enigma.com, and we will endeavor to delete
that information from our databases.

Consent to Transfer

It is important to note that our website, the Services, and their servers are
operated in the United States. If you are located outside of the United States,
please be aware that any information provided to or collected by us, including
personal information, will be transferred from your country of origin to the
United States. Your decision to provide such data to us, or allow us to collect
such data through our website and Services, constitutes your consent to this
data transfer. 

Additional Notices About Our Practices

California’s “Shine the Light” law permits residents who have provided personal
information to certain businesses to request information about whether the
business has disclosed personal information to any third parties for the third
parties’ direct marketing purposes.  We do not disclose personal information to
any third parties for their direct marketing purposes as defined by this law.  
Some browsers include a "Do Not Track" (DNT) setting that can send a signal to
the websites you visit indicating you do not wish to be tracked. There is not a
common understanding of how to interpret the DNT signal; therefore, our website
does not respond to browser DNT signals.

Changes to this Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this
Privacy Policy. We may change this Privacy Policy from time to time and will
post any changes on our website and the Services as soon as they go into effect.
By accessing our website and/or the Services after we make any such changes to
this Privacy Policy, you are deemed to have accepted such changes. Please refer
to this Privacy Policy on a regular basis.

Questions or Concerns

If you have any questions, complaints, or concerns regarding privacy at Enigma,
please send us a detailed message to privacy@enigma.com or to Enigma
Technologies, Inc. at 217 Centre Street, Suite 124, New York, NY 10013, ATTN:
Legal. Your privacy is important to us, and we will make every effort to resolve
your concerns.

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