Privacy Policy
WhoLayer, Inc. (“WhoLayer,” “we”) is an identity data company. We help businesses recognize the people and companies who visit their websites and reach them with accurate contact information. This policy explains what personal information we collect, where it comes from, what we do with it, and the choices you have.
If you want us to stop selling or sharing your information, or to delete it, use our privacy request page, call +1 (888) 000-0000, or email privacy@wholayer.com. You do not need an account.
1. Who this policy covers
- Consumers in our identity data. People whose information is in the database we use to provide our services, including people who visit websites that use the WhoLayer tag. You probably do not have a direct relationship with us, which is why the law treats us as a data broker.
- Our customers and prospects. People who use, buy, or ask about WhoLayer.
- Visitors to wholayer.com.
2. What we collect and where it comes from
In the last 12 months we collected the following categories of personal information:
| Category | Examples | Sources | Sold or shared? |
|---|---|---|---|
| Identifiers | Name, email addresses, hashed email addresses, postal address, phone number, IP address, cookie and device identifiers | Data suppliers, publisher partners, the WhoLayer tag on customer websites | Yes |
| Professional information | Job title, seniority, department, employer, work history, professional profile URL | Data suppliers, public business sources | Yes |
| Commercial information | Products or pages viewed on a customer's website, inferred purchase interest | The WhoLayer tag on customer websites | Yes, to the customer whose site you visited |
| Internet or network activity | Pages visited, referrer, time of visit, browser and device type | The WhoLayer tag on customer websites | Yes, to the customer whose site you visited |
| General geolocation | City, state, and country derived from IP address. We do not collect precise geolocation. | IP address lookup | Yes |
| Inferences | Inferred seniority, company size, likely interests | Derived by us | Yes |
| Customer account data | Name, work email, company, billing details, support conversations | You, when you create an account or contact us | No |
Our sources include:
- Data suppliers that license identity and business contact data to us under contracts requiring that the data was collected lawfully and with the notices the law requires.
- Publisher partners that operate consent-aware networks of websites and share device-to-person links with us.
- The WhoLayer tag, which our customers install on their websites. When you visit such a site, the tag sends us the page you viewed, your IP address, your browser and device type, and cookie identifiers.
- Public business sources, such as company websites, press releases, and government business registries.
- You, when you contact us, create an account, or submit a privacy request.
We do not scrape LinkedIn or other sites in violation of their terms. We require our suppliers to promise the same.
3. Sensitive personal information
We do not knowingly collect, sell, or share sensitive personal information such as Social Security numbers, financial account numbers, precise geolocation, health information, racial or ethnic origin, religious beliefs, sexual orientation, citizenship or immigration status, or information about children. Our customers are prohibited from installing the WhoLayer tag on websites relating to these topics or directed to children, and we block known sites in these categories. We do not knowingly collect or sell personal information of consumers under 16.
4. How we use personal information
- To identify the companies and, in the United States, the people visiting our customers' websites, and report that to the customer whose site was visited.
- To provide contact and company data, such as verified email addresses and phone numbers, to our customers for business-to-business sales and marketing and for ecommerce marketing.
- To verify, correct, and keep our data accurate, including checking whether email addresses are deliverable.
- To honor opt-out and deletion requests across all of our products.
- To run, secure, and improve our services, prevent fraud and abuse, and comply with law.
- For our customers and prospects: to provide the service, bill, support, and communicate with you, including marketing you can unsubscribe from.
We do not use personal information to make decisions about anyone's eligibility for credit, insurance, employment, or housing, and we prohibit our customers from doing so.
5. Who we disclose personal information to
- Our customers. Businesses that subscribe to WhoLayer receive identity and contact data. This is a “sale” or “sharing” of personal information under California law and similar state laws.
- Service providers that host, store, email, and process payments for us, listed on our subprocessors page. They may only use personal information to provide services to us.
- Data suppliers, with whom we exchange limited identifiers, such as hashed email addresses, to match and verify records and to pass along opt-out and deletion requests.
- Authorities, when required by law or to protect rights, safety, and property.
- A successor business, if we are involved in a merger, acquisition, financing, reorganization, or sale of assets. Any successor will be bound by this policy for the information it receives, and we will give notice before personal information becomes subject to a different policy.
6. How long we keep it
- Website visit events from the WhoLayer tag: up to 13 months, then deleted or de-identified.
- Identity and contact records: for as long as they remain accurate and useful, unless you ask us to delete them. Person-level records are removed within one day of the person opting out or asking us to delete them.
- Suppression records (a one-way hash of your email address or other identifier): for as long as we operate, so that we can keep honoring your request. We cannot honor an opt-out if we forget it.
- Privacy request records: 24 months, as California regulations require.
- Customer account and billing records: for the life of the account plus 7 years for tax and accounting.
7. Your privacy rights
Depending on where you live, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, you may have the right to:
- Opt out of the sale or sharing of your personal information, and of targeted advertising and profiling.
- Delete personal information we hold about you.
- Know and access the categories and specific pieces of personal information we hold, the sources, the purposes, and who we disclosed it to, and receive a portable copy.
- Correct inaccurate personal information.
- Limit the use of sensitive personal information.
- Appeal our decision on your request. Email privacy@wholayer.com with the subject “Appeal” and your request number. If we deny your appeal, you can contact your state attorney general.
We offer these rights to everyone in the United States, regardless of state. We will not discriminate against you for exercising them.
How to make a request
- Online: wholayer.com/privacy-request
- Phone (toll-free): +1 (888) 000-0000
- Email: privacy@wholayer.com
Opt-out and deletion requests take effect on our suppression list as soon as we receive them. For access, correction, and deletion requests, we may need to verify your identity, usually by confirming control of the email address in your request. We respond within 45 days and will tell you if we need up to 45 more days. We never require you to create an account.
Authorized agents
You can have someone else make a request for you. We will ask the agent for your signed permission and may ask you to confirm your identity directly, unless the agent holds a power of attorney.
Global Privacy Control
We treat a Global Privacy Control (GPC) signal from your browser as a request to opt out of sale and sharing. On wholayer.com we honor it automatically. The WhoLayer tag on customer websites does not identify visitors whose browser sends a GPC signal.
California Delete Act
California residents can ask every registered data broker, including WhoLayer, to delete their information at once through the California Delete Request and Opt-out Platform (DROP). We check DROP at the interval the law requires and process every matching request.
New Jersey residents (Daniel's Law)
If you are a covered person under New Jersey's Daniel's Law, or an authorized person acting for one, email privacy@wholayer.com with the subject “Daniel's Law.” We will stop disclosing your home address and unpublished phone number within 10 business days.
Other jurisdictions
We do not identify individual visitors outside the United States. If you live outside the US and believe we hold your personal information, email privacy@wholayer.com and we will respond under the laws that apply to you.
8. Data broker registration
| State | Status |
|---|---|
| california | Registration pending (California Delete Act) |
| vermont | Registration pending |
| texas | Registration pending |
| oregon | Registration pending |
9. Request metrics
We publish the number of privacy requests we received and how we responded each calendar year.
| Request type | Received | Completed in whole or part | Denied |
|---|---|---|---|
| Requests to opt out of sale or sharing | Not yet available | ||
| Requests to delete | Not yet available | ||
| Requests to know or access | Not yet available | ||
| Requests to correct | Not yet available | ||
| Requests to limit use of sensitive information | Not yet available | ||
| Deletion requests received through DROP | Not yet available |
10. Security
We protect personal information with encryption in transit and at rest, access controls, logging, and vendor reviews, as described in our Trust page. No system is perfectly secure. If a breach affects your information, we will notify you as the law requires.
11. Our website
On wholayer.com we use essential cookies and privacy-friendly analytics. See our Cookie Policy.
12. Changes
We review this policy at least once a year. If we make material changes, we will update the effective date and, for customers, notify you by email.
Questions
Email legal@wholayer.com or write to WhoLayer, Inc., 1309 Coffeen Avenue, Suite 1200, Sheridan, WY 82801. For privacy requests, use our privacy request page.