Privacy Policy

Effective date: October 1, 2024

At Enrichly, we take your privacy seriously. Please read this privacy policy (“Privacy Policy”) to learn about how we treat your Personal Data when using or accessing our Website Services and Decision Support Tools (each as defined below).

Please note that your use of Enrichly’s website is at all times subject to our Terms of Use (https://www.enrichlyhr.com/terms-of-use) which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.

‍Table of Contents

1. Controller, Data Protection Officer and Contact
2. What this Privacy Policy Cover
3. Our Processing of Your Personal Data
   3.1 What Personal Data We Collect
   3.2 Where We Collect Personal Data
   3.3 What Purposes We Process Personal Data For
4. How We Share Your Personal Data With Third Parties
5. Our Use of Tracking Tools and Advertising
6. Data Security and Retention
7. Personal Data of Children
8. California Resident Rights
9. Other State Law Privacy Rights
10. Changes to this Privacy Policy

1. Controller, Data Protection Officer and Contact

​Enrichly HR, Inc. (“Enrichly,” “we,” or “us”), located at 12 16 Broadway New York, NY 10001, United States of America, is responsible for the processing of your Personal Data. If you have any questions about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please contact us at privacy@Enrichlyhr.com.

‍2. What this Privacy Policy Covers

​Enrichly’s mission is to build the world’s best compensation tools and easily accessible market data so companies (our “Customers”) can plan, communicate and benchmark in real-time. Our Customers have access to accurate and reliable compensation benchmarks in real-time (the “Decision Support Tools”). As part of the Decision Support Tools, our Customers provide a selection of data from their employees (“Customer Data”), which is subsequently modified, de-identified and integrated into the Decision Support Tools. For more detailed information on the Decision Support Tools, please see here.

‍This Privacy Policy describes the collection of personal information and certain other information by us from each user (“you” or “user”) of our website at www.enrichlyhealth.com (the “Website”), as well as all applications, widgets, software, tools and other services provided by us and on which a link to this Privacy Policy is displayed (collectively, and together with the Website, our “Website Services”). In addition, this Privacy Policy describes the collection of personal information and certain other information, including Customer Data, from our Customers as part of the Decision Support Tools.

‍“Personal Data” means any information that identifies or relates to a particular individual, and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations.

‍“Aggregated De-Identified Data” means data submitted to, collected by or generated by Enrichly in connection with Customer’s use of the Decision Support Tools, but only in aggregate form, from which individual identifiers have been removed such that the data can in no way be linked specifically to Customer or Customer’s employees.

‍Note that this Privacy Policy does not cover how we treat Personal Data that we process as a data processor or service provider when Customers use our products, other than with respect to the Decision Support Tools as described herein, or the practices of companies we don’t own or control or people we don’t manage.

3. Our Processing of Yours Personal Data

​3.1 What Personal Data We Collect

This chart details the categories of Personal Data that we currently collect and process:

‍Category of Personal Data: Profile or Contact Data in connection with the Website Services

• First and last name
• Email address
• Employer Name
• Address

Examples of Personal Data We Collect: Profile or Contact Data that may be collected in connection with the Decision Support Tools

• First and last name
• Email address
• Insurance Carrier Name
• Insurance Plan Details; Premiums, Deductible, Out-of-Pocket maximums etc..
• Insurance Broker Name
• Bank Name
• Salary
• Credit Card or Other Debt Details

3.2 Where We Collect Personal Data

We generally collect Personal Data from the following categories of sources:

‍When you use our Website Services, by:

– Through Cookies (defined in the “Our Use of Tracking Tools and Advertising” section below).
– If you use a location-enabled browser, we may receive information about your location.
– Voluntarily providing information in free-form text boxes through responses to surveys or questionnaires.

‍When you directly contact us, by:

• Sending us an email or otherwise contacting us.

‍When Customers access the Decision Support Tools, by:

– Completing questionnaires or data provided by Customer or their Employer

3.3 What Purposes We Process Personal Data For

​Our commercial or business purposes for collecting Personal Data vary depending on the context of our activities.

‍‍Providing, Customizing and Improving the Website Services

When providing our Website Services, we process Personal Data from users to:

• Create and manage Customer accounts or other user profiles.
• Provide our Customers with the products, services or information they request.
• Meeting or fulfilling the reason you provided the information to us.
• Provide support and assistance for the Website Services.
• Improve the Website Services, including testing, research, internal analytics and product development.
• Personalize the Website Services and communications based on your preferences.
• Doing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
• Market and sell the Website Services upon request, e.g. performing demos of our products, which can be booked via our Website.
• Provide promotional information to existing subscribers.

‍Providing our Website and the Website Services

​When users access and interact with our Website, we process Personal Data from users to:

• Provide the contents of our Website.
• Manage the sign up for our Decision Support Tools.
• Manage the sign up for our newsletter.
• Schedule demos for our products.
• Ensure the security of the Website and correct errors.
• Manage Cookies (see “Our Use of Tracking Tools and Advertising” for more information).
• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Enrichly, the Website Services or our products.

‍Correspondence with Customers, Users and Others

For communication purposes, we process Personal Data to:

• Respond to correspondence that we receive from you, contacting you when necessary or requested.
• Send emails and other communications according to your preferences or that display content that we think will interest you.

‍Meeting Legal Requirements and Enforcing Legal Terms

​In fulfillment of our legal obligations under applicable law, regulation, court order or other legal process, we process Personal Data to:

• Prevent, detect and investigate security incidents and potentially illegal or prohibited activities.
• Protect the rights, property or safety of our Customers, users, Enrichly or another party.
• Enforce agreements with our Customers.
• Respond to claims that any posting or other content violates third-party rights.
• Resolve disputes.

‍Internal Use and Modification in Connection with the Decision Support Tools

We internally use and modify (but not disclose) Customer Data for the purposes of:

• Providing the Decision Support Tools to our Customers.
• Testing, improving and operating Enrichly’s products and services.
• Generating Aggregated De-Identified Data.

‍Using, Making Available and Retaining Aggregated De-Identified Data

We use, make available and retain Aggregated De-Identified Data for business purposes, including improving, testing, operating, promoting and marketing our products and services.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

4. How We Share Your Personal Data with Third Parties

​In connection with the Website Services, we disclose your Personal Data to the categories of service providers and other parties listed in this section.

Service Providers. These parties help us provide the Website Services or perform business functions on our behalf.

They include:

• Hosting, technology and communication providers.
• Analytics providers to make sure our Website and Website Services are functioning correctly.

Advertising Partners. These parties help us market our products to users and provide our Customers with other offers that may be of interest. They include:

• Ad networks.
• Data brokers.
• Marketing providers.

Analytics Partners. These parties provide analytics on web traffic or usage of the Website Services. They include:

• Companies that track how users found or were referred to the Website Services.
• Companies that track how users interact with the Website Services.

In connection with the Decision Support Tools, we may share Customer Data as described in this Privacy Notice with service providers who need to access the Customer Data in order to perform services on our behalf, such as processing or storing such information. The service providers are bound by contractual obligations to keep all Personal Data confidential and to use it only for the purposes for which we disclose it to them. In addition, we use Aggregated De-Identified Data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Decision Support Tools and promote our products and services, provided that we will not share such data in a manner that could identify any Customer or Customer employee.

‍Business Transfers

​If we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part), all of the Personal Data that we collect may be transferred to the third party. Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

5. Our Use of Tracking Tools and Advertising

First and third-party cookies

​The Website Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Website Services, analyze trends, learn about our user base and operate and improve our Website Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Website Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

‍We use the following types of Cookies in connection with the Website Services:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Website Services.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Website Services, maintain your preferences over time and recognize you when you return to our Website. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how users interact with our Website Services. They do this by collecting information about the number of users of the Website, what pages users view on our Website and how long users are viewing pages on the Website. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Website Services’ content for those who engage with our advertising.
• Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”

You can decide whether or not to accept Cookies through our cookie consent manager or, alternatively, your internet browser’s settings. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our Website and some of the Website Services may not work. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/

‍Information about Interest-Based Advertisements:

​We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Website Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users of the Website Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Website. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Website Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

6. Data Security and Retention

​We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

‍With respect to the Website Services, we retain Personal Data about you only as long as is necessary for the fulfillment of the relevant purposes. After the end of the purpose, we delete your Personal Data in compliance with legal retention rights and obligations and insofar as other legal regulations do not conflict with this.

• As long as you have an open account with us or as otherwise necessary to provide you with our Website Services.
• Longer, if doing so is necessary to comply with our legal obligations (e.g. tax regulation), resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.
• Our own purposes in an anonymous or aggregated form where that information would not identify you personally.

With respect to the Decision Support Tools, we retain Personal Data in order to generate Aggregated De-Identified Data. Personal Data is deleted or anonymized within 30 days, upon request of the data subject or the Customer. Customer Data is anonymized before incorporation into the Decision Support Tools. Data within the Decision Support Tools is only ever presented in aggregated forms.

7. Personal Data of Children

​As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age. If you are a child under the age of 16, please do not attempt to register for or otherwise use the Website Services or Decision Support Tools, or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at  privacy@Enrichlyhr.com.

8. California Resident Rights

​If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our Customers’ employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

‍If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@Enrichlyhr.com.

‍Access

​You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. We have not sold your Personal Data over the last twelve (12) months and Enrichly does not sell Personal Data.

‍Deletion

​You have the right to request that we delete the Personal Data that we have collected about you. Under the California Consumer Privacy Act (“CCPA”), this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Website Services, the Decision Support Tools or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

‍Exercising Your Rights

​To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

‍We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

‍You may submit a Valid Request by emailing us at privacy@Enrichlyhr.com.

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

‍Personal Data Sales Opt-Out and Opt-In

In this section, we use the term ‘sell’ as it is defined in the CCPA. We do not sell your Personal Data.

As described in the “Our Use of Tracking Tools and Advertising” section above, we have incorporated Cookies from certain third parties into our Website Services. These Cookies allow those third parties to receive information about your activity on our Website Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads when using our Website Services or on other websites you visit. You can opt out of these sales by following the instructions in this section.

‍You always have full control over whether these technologies work on your devices.  You can disable them entirely using our cookie consent manager.

‍In addition, under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@Enrichlyhr.com.

‍We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Website Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

9. Other State Law Privacy Rights

Nevada Resident Rights

​If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@Enrichlyhr.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Legal grounds for processing Personal Data

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains for which purposes we use your Personal Data.

We will only process your Personal Data if we have a legal basis to do so pursuant to Art. 6 EU-GDPR. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

1. Contractual Necessity‍

We process Personal Data used for providing and customizing our Website Services as a matter of “contractual necessity” according to Art. 6 (1) lit. b of EU-GDPR, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Website Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Website Services that require such data.

2. Legitimate Interest‍

Further, we process Personal Data where we consider it to be the legitimate interest of us or third parties according to Art. 6 (1) lit. f of EU-GDPR. Our interests here are:

• Efficient and secure operation of our Website Services, for which we process technical data from users.
• Purposeful and timely communication with our Customers, users and other people who contact us to answer questions, provide information and resolve requests.
• The operation, optimization and improvement of our Website Services by generating aggregated de-identified data and making the results available to our Customers.
• Marketing developments and new features of our Website Services to our existing Customers.
• With respect to our Decision Support Tools, to test, improve and operate our Decision Support Tools in accordance with Art. 6 lit. f of EU-GDPR. The processing of Personal Data in this context is strictly limited to the set of data described above, and is necessary for us to provide our Decision Support Tools.

3. Consent

‍In some cases, we process Personal Data based on the consent you expressly grant to us according to Art. 6 (1) lit. a of EU-GDPR. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. We mainly obtain consent for:

• Using non-essential cookies on our website.
• Providing advertisement on our Website Services and sharing the data accordingly with our partners.

4. Other Processing Grounds‍

From time to time we may also need to process Personal Data to comply with our legal obligations, if it is necessary to protect the vital interests of you or other data subjects or if it is necessary for a task carried out in the public interest.

Transfers of Personal Data

We only transfer your Personal Data to external third parties if this is necessary for the processing or handling of your request, if another legal permission exists or if we have your consent for this. External recipients of user data can be, in particular, service providers that we use for the provision of services, for example in the areas of technical infrastructure and maintenance of our Website. Such service providers as processors are carefully selected and regularly reviewed by us. They may only use the data for the purposes specified by us and in accordance with our instructions.

​The Website Services and the Decision Support Tools are hosted and operated in the United States (“U.S.”) through Enrichly and its service providers. If you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. Processing Personal Data outside the EU / EEA requires additional safeguards to ensure a similar level of protection of the EU-GDPR. To achieve this, we have integrated the standard data protection clauses (SCC) into a data privacy agreement (DPA), which we conclude with third parties for processing personal data.

11. Changes to this Privacy Policy

​We’re constantly trying to improve our Website Services and the Decision Support Tools, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Website Services and the Decision Support Tools.