Last updated: 13 Oct 2026
At FullEnrich, respect for our customers' and users' privacy and personal data is at the core of our commitments. One of our actions to achieve this is to provide you with detailed information about how we collect and process your personal data through this privacy policy. You will find these details as you continue reading.
Who is the Data Controller?
This privacy policy covers the purposes and processing carried out by FullEnrich as a data controller.
FullEnrich (FullEnrich Corp, headquartered at 28 Geary St, STE 650, Suite #346, San Francisco, CA 94108, United States) provides its users with services and a software available in SaaS mode offering several functionalities to the Client, including Waterfall Enrichment, Search and Reverse Email Lookup. These features are offered through different means such as a browser extension, API, web application, and website (hereinafter the "Services"). As part of the Services, FullEnrich processes data as data controller for Search and Reverse Email Lookup and as data processor for Waterfall Enrichment.
For information about the purposes and processing carried out by FullEnrich as a data processor (i.e. for Waterfall Enrichment), please consult the Data Processing Agreement (hereinafter "DPA"). To avoid any ambiguity, the purposes carried out as data processor will not be covered in this Privacy Policy.
As part of its activities, FullEnrich processes personal data of customers, users, prospects, candidates, and website visitors.
When Does FullEnrich Collect Personal Data?
Depending on the purposes of processing, FullEnrich collects personal data at different times.
FullEnrich notably collects personal data in the following situations:
- during candidate searches and receipt of job applications;
- during prospect research, appointment scheduling, and communications;
- during webinar or event organization and newsletter subscription;
- when entering into contracts with customers, suppliers, partners, data providers and other contractors, as well as during payment processing, communications with them, and Service delivery;
- when collecting data from providers for its Search database;
- during user assistance and support requests;
- when users create an account, log into the web application, and use the Services;
- when visitors browse FullEnrich's website;
- when prospects click on one of our ads;
- when receiving data subject rights requests.
When FullEnrich collects personal data to create and provide its Search database to its customers and to provide the Reverse Email Lookup service, the data is not directly collected from the data subjects. In this case, the data comes from data providers and is processed by FullEnrich for its own commercial purposes. FullEnrich relies on the basis of its legitimate interest to collect and process data from data subjects for Search and Reverse Email Lookup. Data subjects may at any time exercise their rights by contacting FullEnrich at support@fullenrich.com or through FullEnrich's privacy right request portal here. Further details (categories of data, recipients, retention periods, transfers outside the EU, and your right to lodge a complaint with the CNIL) are set out in the relevant sections of this policy.
What Data Does FullEnrich Process?
As part of its activity and Service provision, FullEnrich processes the following personal data:
- identification data including name, first name, date of birth, gender. These may be necessary for account creation and contract conclusion;
- contact data including email address and phone number. These may be necessary for account creation and contract conclusion;
- application data including professional background, education, experience, resumes, and cover letters;
- data available in the Search database created by FullEnrich including name, first name, professional network url, job title, company name, seniority, function, location, university, former experiences, skills and languages, professional data including job positions, companies, or professional needs;
- browsing data including cookie data, IP address, logs, user journey;
- usage data including service utilization, user feedback and reviews, and session history;
- user device identification data including browser type, operating system, and processor;
- payment data including banking information, amounts due, invoices. These are necessary for contract conclusion and service provision. Without this information, FullEnrich cannot credit the account;
- support data including support needs and customer communications. Description of difficulties encountered by the user is essential for finding an appropriate solution.
What Are FullEnrich's Processing Purposes, Legal Bases, and Retention Periods?
The table below provides concise, clear, and precise answers to these questions.
Here's what each column represents:
- purposes correspond to the objectives pursued by processing personal data. FullEnrich processes personal data for specific, determined, and legitimate purposes;
- personal data corresponds to the data described in the previous section. FullEnrich processes relevant and necessary data for achieving the pursued purposes;
- legal bases correspond to the grounds on which FullEnrich relies to have the right to process personal data;
- retention periods correspond to the time during which FullEnrich processes personal data. Periods are determined based on the time necessary to achieve the purposes.
| Purposes | Personal Data | Legal Bases | Retention Periods |
|---|---|---|---|
| Identify and recruit new talent | Identification data, Contact data, Application data | Legitimate interests in identifying qualified talent; Contractual execution or pre-contractual measures | Duration necessary for the recruitment process |
| Identify, contact, and communicate with prospects | Identification data, Contact data, Professional data | Legitimate interests in developing its customer base | 3 years from the last contact from the prospect or, in absence of contact, from collection by FullEnrich |
| Organize webinars, events and send newsletters | Identification data, Contact data, Professional data | Consent to participate in webinar, event or receive newsletter | Duration of newsletter subscription or until webinar or event |
| Payment reception, processing, and management | Identification data, Payment data | Contractual execution; Legal obligation | Until receipt of final payment or duration necessary for legal obligations compliance |
| Management of contractual and commercial relationships with customers, suppliers, partners, and other contractors; Management of potential disputes | Identification data, Contact data, Professional data, Communications with customers, suppliers, partners, and contractors | Contractual execution; Legitimate interests in maintaining customer relationships; Legitimate interests in managing disputes | Duration of contract or duration of dispute |
| Assistance and support management | Identification data, Contact data, Support data | Legitimate interests in ensuring proper service operation and responding to users | Duration of assistance or support |
| Website and web application security, including fraud prevention | Navigation data, User device identification data, Usage data | Legitimate interests in ensuring proper service operation and responding to users | 1 year from collection |
| Improvement of website, web application, and services & monitoring of partnerships and influences | Navigation data, Usage data | User consent; Legitimate interests in providing users with performant service and interfaces | 25 months from collection |
| Reception, management, and response to data subject rights requests | Identification data, Contact data, Communication content | Legal obligation to process data subject rights requests; Legitimate interests in maintaining a list of processing refusals | Duration of request + 5 years and 3 years for the list |
| Creation, hosting and provision of the Search database to the customers and partners | Data available in the Search database | Legitimate interest in developing, operating and commercialising a database of professional contacts to develop FullEnrich's activities | 3 years from the first collection date |
| Provision of the Reverse Email Lookup services (collection of data, identification of the relevant data and provision of data to the customer and partners) | Email address, Name, Professional network url, Data available in the Search database | Legitimate interest in providing a service enabling professionals to find a contact's professional information using their email address for their own business purposes | 3 months from the date of the request |
Who Are the Recipients of the Data?
As part of its activities, FullEnrich may need to transmit your personal data to recipients. These are either internal or external recipients to FullEnrich.
Internal Recipients
These are employees and people working for FullEnrich who need access to data to perform their assigned tasks. For example, the tech team when they respond to technical support requests.
External Recipients
These are either data processors that FullEnrich uses to carry out its activities or third parties. For example, a data processor may be the company providing the CRM or online payment tool, and a third party may be a law firm, accounting firm, or administration.
FullEnrich commits to concluding a DPA with each of its processors to ensure they comply with applicable data protection regulations and maintain the confidentiality of the data they process.
Where your personal data is included in the Search database or processed for the purposes of the Reverse Email Lookup service, FullEnrich makes such data available to its customers, acting as independent data controllers. FullEnrich may also make your data accessible to its partners, which may include resellers, platforms and agencies, who can integrate your data in their own services or products and share your data with their own customers. Your data may only be used for sales prospecting and recruitment.
FullEnrich may also need to share personal data when required by legal, regulatory, or administrative or judicial decision, or in case of audits conducted in the context of investment, sale, or transfer of all or part of FullEnrich's activities.
Does FullEnrich Transfer Data Outside the European Union?
As part of its activities, FullEnrich and its processors may transfer data outside the European Union, particularly to the United States, including where FullEnrich makes data from the Search database or processed for the purposes of the Reverse Email Lookup service available to customers and partners located outside the European Union.
FullEnrich ensures that transfers are carried out either under an adequacy decision or under the European Commission's standard contractual clauses in their June 4, 2021 version, or through any other transfer instrument explicitly authorized by applicable data protection regulations. Thus, when transfer occurs to the United States, FullEnrich first checks the Data Privacy Framework list. If not listed there, FullEnrich verifies the existence and application of standard contractual clauses. To obtain a copy of the transfer instrument, you can contact FullEnrich at support@fullenrich.com.
What Are the Rights of Data Subjects?
Individuals whose data is processed by FullEnrich can exercise the following rights:
- right of access to access and obtain information and a copy of the personal data processed by FullEnrich;
- right to object to oppose FullEnrich's use of your data for a specific purpose;
- right to rectification to request FullEnrich to update personal data;
- right to erasure to request FullEnrich to delete personal data;
- right to restriction to request FullEnrich to limit processing carried out on personal data;
- right to data portability to retrieve data you provided to FullEnrich or request its transmission to a third party;
- right to establish post-mortem directives regarding the fate of personal data after death.
When processing is based on consent, it is also possible to withdraw consent.
To exercise these rights, simply contact FullEnrich at: support@fullenrich.com or through FullEnrich's privacy right request portal here. Please indicate the nature of the right you wish to exercise.
It is also possible to file a complaint with the CNIL.
Texas Data Broker Notice
The entity maintaining this website is a data broker under Texas law. To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS). Information about data broker registrants is available on the Texas SOS website.
Consumers may exercise their rights under the Texas Data Privacy and Security Act (Texas Business and Commerce Code, Chapter 541), and any other applicable data privacy rights, as described in this privacy policy or by contacting FullEnrich at support@fullenrich.com.
What Security Measures Does FullEnrich Implement?
To ensure the security of personal data it processes, FullEnrich implements technical and organizational measures to ensure the confidentiality, availability, access, and integrity of processed personal data.
For example, FullEnrich implements measures to ensure users use strong passwords, that strict access control exists, and that connection logs are encrypted at rest and retained for one year.
How Are Cookies Handled?
FullEnrich has implemented a specific policy regarding trackers and cookies. It can be consulted from the Legal & Privacy Center or directly at our Cookie Policy.
Privacy Policy Modifications
This privacy policy may be subject to modifications and updates to take into account changes in FullEnrich's activities and Services. It is recommended to consult it regularly to stay up to date with the latest developments.