Summary: Enigma Advisory LLC ("Enigma," "we," "our," or "us") respects your privacy. We collect limited personal information through this website for the purposes of responding to inquiries, improving our services, and complying with legal obligations. We do not sell personal information to third parties.
1. Company Information
This Privacy Policy applies to the website located at enigmaadvisory.com and is operated by:
Enigma Advisory LLC
101 Federal Street, Suite 1900
Boston, MA 02110
United States
Phone: (617) 286-4318
Email: privacy@enigmaadvisory.com
2. Information We Collect
We collect personal information in the following categories when you interact with our website or services:
2.1 Information You Provide Directly
- Contact form submissions: Your full name, business email address, company name, phone number (optional), job title (optional), and the content of your message.
- Newsletter subscriptions: Business email address and, if provided, your first name and areas of interest.
- Client engagement communications: Information exchanged via email, phone, or in-person meetings in connection with advisory engagements.
2.2 Information Collected Automatically
- Usage data: Pages visited, time spent on pages, referring URL, and navigation path through the site.
- Device and browser data: Browser type and version, operating system, screen resolution, and general device category (desktop, tablet, mobile).
- IP address: Used to derive approximate geographic location (city/region level) and to detect and prevent fraudulent or abusive access.
- Cookies and similar technologies: As described in our Cookie Policy, we use functional, analytical, and preference cookies. We do not use advertising or cross-site tracking cookies.
3. Legal Basis for Processing
Where applicable under US state privacy laws (California Consumer Privacy Act/CPRA, Virginia CDPA, Colorado Privacy Act, and similar), we process personal information on the following bases:
- Performance of a contract or pre-contractual steps: Processing necessary to respond to service inquiries or fulfill advisory engagements.
- Legitimate interests: Website analytics to improve content and user experience, security monitoring, and fraud prevention, balanced against the reasonable privacy expectations of website visitors.
- Consent: Newsletter subscriptions, where you may withdraw consent at any time by clicking the unsubscribe link or contacting us at privacy@enigmaadvisory.com.
- Legal obligation: Compliance with applicable laws, regulations, and lawful legal process.
4. How We Use Your Information
We use the personal information we collect for the following purposes:
- Responding to inquiries, requests for proposals, and general contact form submissions, typically within two business days.
- Delivering advisory services, research briefings, and client reports in connection with executed engagement agreements.
- Sending our bi-weekly Enigma Briefing newsletter to subscribers who have opted in.
- Analyzing aggregate website usage patterns to improve content structure, navigation, and user experience.
- Maintaining records as required by applicable law, including engagement records for tax and accounting purposes.
- Detecting and preventing fraudulent, abusive, or unauthorized access to our website or systems.
5. Information Sharing and Disclosure
Enigma does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We share personal information only in the following limited circumstances:
- Service providers: We engage vetted third-party service providers who process data on our behalf under contractual data processing agreements, including: email delivery (transactional and newsletter), website analytics, customer relationship management (CRM), and cloud infrastructure hosting. These providers are authorized to use personal information only as necessary to provide services to us.
- Professional advisors: Attorneys, accountants, and auditors engaged by Enigma in connection with legal compliance, audits, or dispute resolution, subject to professional confidentiality obligations.
- Legal requirements: When required by applicable law, court order, subpoena, regulatory authority, or to protect the rights, property, or safety of Enigma, our clients, or the public.
- Business transfers: In connection with a merger, acquisition, restructuring, or sale of all or substantially all of Enigma's assets, provided that the acquiring entity assumes our obligations under this Privacy Policy.
6. Data Retention
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, and to resolve disputes:
- Contact form inquiries: 24 months from the date of submission, unless a client engagement arises, in which case engagement records are retained for 7 years from engagement completion.
- Newsletter subscriber records: For the duration of the subscription plus 12 months following unsubscription, for suppression list purposes.
- Website analytics data: 26 months in aggregated, pseudonymized form.
- Financial and engagement records: 7 years from the end of the applicable fiscal year, as required by applicable law.
7. Your Privacy Rights
Depending on your state of residence, you may have the following rights regarding your personal information:
- Right to know / access: Request disclosure of the categories and specific pieces of personal information we hold about you.
- Right to correction: Request correction of inaccurate personal information we hold about you.
- Right to deletion: Request deletion of your personal information, subject to exceptions for legal obligations and legitimate business interests.
- Right to opt out of sale/sharing: We do not sell or share personal information for cross-context behavioral advertising. No opt-out action is required.
- Right to non-discrimination: We will not discriminate against you for exercising your privacy rights.
To exercise any of these rights, please submit a verifiable consumer request to privacy@enigmaadvisory.com or call (617) 286-4318. We will respond within 45 days, with the possibility of a 45-day extension where reasonably necessary.
8. Security
Enigma implements commercially reasonable technical, administrative, and physical security measures to protect personal information against unauthorized access, disclosure, alteration, or destruction. Measures include TLS encryption for data in transit, access controls, and annual security assessments of our technology infrastructure. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.
9. Third-Party Websites
Our website may contain links to third-party websites, including those of professional associations, research organizations, and technology vendors referenced in our publications. This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of any third-party sites you visit.
10. Children's Privacy
Our website and services are directed at business professionals and are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If you believe we have inadvertently collected such information, please contact us at privacy@enigmaadvisory.com and we will promptly delete it.
11. Changes to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices, applicable laws, or regulatory guidance. Material changes will be posted to this page with an updated effective date. We encourage you to review this policy periodically. Your continued use of our website following the posting of an updated Privacy Policy constitutes your acknowledgment of the changes.
12. Contact
If you have questions, concerns, or requests related to this Privacy Policy or our data practices, please contact our Privacy team:
Enigma Advisory LLC — Privacy Office
101 Federal Street, Suite 1900
Boston, MA 02110
Email: privacy@enigmaadvisory.com
Phone: (617) 286-4318