It is helpful to start by explaining some of the key terms that are used in this policy.

Key Term	Definition
Our representative	EnrichedNYC 203 Royal Poinciana Way, #1 Palm Beach, Florida 33480 compliance@enrichednyc.com +1 (917) 886-2358
Our data protection officer	Contact details. This may be same person as the representative.
Personal information	Any information relating to an identified, or identifiable individual.
Special categories of information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data Data concerning health, sex life, or sexual orientation

We do not collect any personal information from you unless you voluntarily provide it to us. We do not collect any personal information from any person under the age of 18 unless we have first obtained consent from the minor person’s parent or legal guardian. If you are a student under the age of 18, please do not send any personal information to us without first obtaining permission from your parent or legal guardian. If we learn that we have improperly received information from a student under age 18 without the required consent, we will delete that information. If you believe your minor student may have provided us with their personal information in violation of this Privacy Notice, please contact us at compliance@enrichednyc.com.
In some instances, we may receive sensitive information about you, which may be defined differently in various countries. This information, if provided, may be associated with your religious or philosophical beliefs, or could include information about your health. Information relating to your health may also be collected in the context of your employment with Enriched NYC, including for social security and social protections. In any case, we commit to safeguard your personal information, to provide adequate protections for your personal information, and to only use your personal information according to the purposes set forth in this Privacy Notice and applicable laws.
In addition to the categories of information expressed in the table below, we also collect the following information from you:

Categories	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

We may collect your personal information directly from you, from third parties, or through automation, as further described below.

A. Information you provide directly to us

We may receive your personal information directly when you:

• Email us
• Request marketing materials
• Inquire about services
• Submit an application
• Attend an event that we are hosting
• Interview with us
• Provide us with your feedback
• Contact us through our website

B. Information we receive from third parties
We may receive your personal information form third parties as follows:

• Via analytics through providers such as Google Analytics located in the United States; and
• From other service providers we use such as:
- Calendly, when we are sent a link to a calendar;
- Intuit QuickBooks, when we process invoices and payments;
- MailChimp, when you subscribe to our newsletters or share information about your communication preferences;
- Microsoft, when you collaborate with us electronically, such as sending an electronic message, meeting invite, or sharing a file or collaborative workspace;
- Social media platforms, such as Facebook, when we participate in events, receive requests for collaboration and for advertising purposes.

C. Information we automatically collect

When you use our website or login to our services, we may learn technical data about your computing system and browsing activity. This data is gathered by employing cookies and related tools. To learn more about the cookies we utilize on this site.

Data protection laws in the United States and around the world prohibit us from using your personal information unless we have a proper reason for doing so. For example, we may use your personal information:
• For the performance of our contract with you, or to take steps at your request before entering into a contract;
• To comply with our legal and regulatory obligations;
• To protect your vital interests or those of another person:
• For our legitimate* interests or those of a third party; or
• Where you have given consent.

*A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own fundamental rights and interests which require protection of personal information, especially when the subject is a child. The table below explains what we use (process) your personal information for, and our reasons for doing so, but it does not apply to any special category personal information which we process only with your express consent

What We Use Your Personal Information For	Our Reasons
To provide products AND/OR services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Enriched NYC	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity; screening for financial and other sanctions or embargoes; or other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulators	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to [our financial performance, customer base, product range or other efficiency measures]	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: — existing and former customers; — third parties who have previously expressed an interest in our services; — third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
[Credit reference checks via external credit reference agencies]	[For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services]
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards, and to comply with our legal and regulatory obligations.

We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations for marketing purposes. You have the right to opt out of receiving promotional communications at any time by:

• Contacting us at compliance@enrichednyc.com
• Using the “unsubscribe” link in emails or “STOP” number in texts; or
• Updating your marketing preferences on your online account with us.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We do not share your personal information with individuals outside Enriched NYC except as described in this Privacy Notice. We use service providers to assist in the storage and processing of personal data, but we only allow them to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.

We may also share personal information with external auditors, e.g. in relation to accreditation and the audit of our accounts. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business, or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

The name of the service provider, the locations where data is transferred or stored by the provider and the purpose of processing are described below.

Name	Location	Purpose
Amazon Web Services	US Data Centers	For managing service requests and knowledge articles
Dropbox Business	US Data Centers	For file storage and processing
Microsoft Office 365	US Data Centers	For file storage and processing
Squarespace	United States	For sending information to which you may have requested or subscribed
OneTrust CookiePro	MS Azure Germany	For managing website cookie notices and tracking cookies consent and preferences
Wix.com	US Data Centers	For submitting requests for information through our website

In the preceding 12 months, we have not sold to any third party any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, in this same time period, we have made certain disclosures to third parties for one or more business purposes the following categories of personal information that does identify, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);

• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;

• Characteristics of protected classifications under California or federal law;

• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);

• Biometric information;

• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);

• Geolocation data;

• Audio, electronic, visual, thermal, olfactory, or similar information;

• Professional or employment-related information;

• Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA);

• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Your information is stored and accessed by Enriched NYC employees, independent contractors, or service providers as described above (see above: “Who We Share Your Personal Information With”). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”

We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

To deliver services to you, we may transfer personal information from the EEA or the UK to the United States or other third countries. These transfers are subject to special rules under European and UK data protection law for which we rely on one of the following transfer mechanisms:

• Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR); or

• Standard Contractual Clauses issued by the European Commission. The European Commission has determined that the Standard Contractual Clauses provide sufficient safeguards to protect the personal data transferred outside the EU or EEA.

Except for the countries with a decision of adequacy from the European Commission, non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses, please contact us or our Data Protection Officer (see “How To Contact Us” below).

For further information on each of the rights below, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: • The categories of personal information we have collected about you; • The categories of sources from which the personal information is collected; • Our business or commercial purpose for collecting or selling personal information; • The categories of third parties with whom we share personal information, if any; and • The specific pieces of personal information we have collected about you. Please note that we are not required to: • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or • Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: • The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and • The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, please emailcompliance@enrichednyc.com
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: • Delete your personal information from our records; and • Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; • Debug to identify and repair errors that impair existing intended functionality; • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; • Comply with the California Electronic Communications Privacy Act; • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; • Comply with an existing legal obligation; or • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: • Deny goods or services to you; • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; • Provide a different level or quality of goods or services to you; or • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

This website may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice or other relevant information of every website you visit.

You may send us an email at compliance@enrichednyc.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Moreover, we are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us, you will need to provide us with:
• Enough information to identify you (e.g., your name, address, and telephone number);
• Proof of your identity and address; and
• A description of what right you want to exercise and the information to which your request relates.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly excessive or repetitive.

We regularly review our compliance with this Privacy Notice. In the event that we receive a formal written complaint, we will contact the person who made the complaint and we will make all efforts to resolve such complaint directly with the claimant. We also work with the appropriate regulatory authorities, to resolve such complaints. We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information. Nonetheless, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

By accepting our services, you agree to the terms and conditions contained in this Privacy Notice and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use any of our services.

As our organization evolves and how we operate our business changes, and as the legislative framework governing data protection and data privacy continues to evolve, this Privacy Notice is expected to change as well. We reserve the right to amend this Privacy Notice at any time, for any reason. We may e-mail periodic reminders of our notices and terms and conditions and will e-mail our registered users about material changes.

Please note that if you have opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices still govern your use of the services, and you are still responsible for reading and understanding them. If you use the website, purchase materials, or use our services after any change to this Privacy Notice, then you agree to the new changes.

If you have any questions or concerns about our Privacy Notice, or should you wish to file a complaint about anything relating to our Privacy Notice, do not hesitate to contact our Data Protection Officer Brooke Ooten at compliance@enrichednyc.com.