Empresahaus

Empresahaus

Privacy Policy

Effective Date: October 1, 2026

Last Updated: October 1, 2026

1. Introduction

This Privacy Policy explains how Lincoln Barretta Consulting LLC, doing business as Empresahaus (“Empresahaus,” “EH,” “we,” “us,” or “our”) collects, uses, discloses, retains, and protects personal information when you use our websites, applications, matching services, member profiles, team features, communications, programs, events, paid products, or other services that link to this Privacy Policy (collectively, the “Services”).

Empresahaus is designed to help independent professionals create professional profiles, connect with other members, receive team matches or recommendations, and collaborate. Some information you choose to provide is therefore intended to be used to evaluate professional compatibility and, where appropriate, disclosed to prospective or actual teammates.

Please read this Privacy Policy together with our:

2. Who Is Responsible for Your Information

For purposes of U.S. state privacy laws that use terms such as “controller” or “business,” the entity responsible for covered personal information is:

Lincoln Barretta Consulting LLC d/b/a Empresahaus 109 Bridge St. Unit #1133 Groton, CT 06340 Email: info@lincolnbarretta.com

3. Scope

This Privacy Policy applies to personal information processed in connection with the Services.

It does not govern information processed solely by independent third parties under their own privacy policies, even where we link to, integrate with, or rely on those third-party services.

Public portions of the Empresahaus website may be accessible from outside the United States. Eligibility for Empresahaus Member Services is addressed separately in Section 20 — Geographic Availability.

4. Personal Information We Collect

The personal information we collect depends on how you interact with Empresahaus.

4.1 Account and Contact Information

We may collect your:

  • name;
  • email address;
  • telephone number;
  • username or account identifier;
  • authentication information in protected form;
  • general geographic information such as city, state, or time zone;
  • country or state of residence where needed for eligibility or legal compliance;
  • account status;
  • preferences;
  • communication preferences; and
  • records of acceptance of legal terms, notices, and consents.

4.2 Professional Profile and Application Information

We may collect professional information such as:

  • professional biography;
  • occupation;
  • employer or business information;
  • work history;
  • education and training;
  • professional skills;
  • experience level;
  • portfolio information;
  • professional achievements;
  • certifications or licenses you choose to provide;
  • professional role or functional strengths;
  • industry experience;
  • entrepreneurship or venture interests;
  • project interests;
  • professional goals;
  • business-building goals;
  • availability;
  • team-role preferences;
  • willingness to lead or participate in a venture;
  • questionnaire responses;
  • reliability or commitment responses; and
  • other professional information you choose to provide.

4.3 Resume, CV, Portfolio, and Uploaded Content

If you upload a resume, CV, portfolio, profile image, document, or other file, we collect the file and information contained in it.

We may extract, organize, summarize, classify, or transform professional information from that content to create or improve your Empresahaus profile and matching experience.

Please do not include sensitive personal information that is not necessary for your use of the Services.

If an uploaded file contains sensitive personal information that Empresahaus did not request, we handle that information as described in Section 11 — Sensitive Personal Information, including by excluding it from matching and other uses where appropriate and taking reasonable steps to restrict, redact, or delete unnecessary sensitive information once identified.

Where applicable law requires consent before particular sensitive information may be processed, Empresahaus will not continue processing that information for a purpose requiring consent unless the required consent has been obtained or another lawful basis or exception applies.

4.4 User-Submitted Websites

If you provide a personal, professional, portfolio, or business website, we may collect the URL and, where technically and legally permitted, process publicly available information located at that URL for purposes of creating or verifying profile information.

Submission of a URL does not authorize Empresahaus to circumvent passwords, authentication controls, paywalls, technical restrictions, or third-party contractual restrictions.

4.5 Information You Enter Directly

If you choose to build your profile directly in Empresahaus, we collect information you enter into profile forms, applications, questionnaires, preference screens, or other input fields.

4.6 Matching Data, Derived Data, and Inferences

We may create information based on information you submit or your activity within the Services, including:

  • inferred professional role;
  • skill or capability classifications;
  • team-role fit;
  • compatibility indicators;
  • suggested team assignments;
  • matching scores or rankings;
  • inferred professional interests;
  • profile summaries;
  • completeness or confidence indicators;
  • fraud or security risk signals;
  • engagement indicators; and
  • other inferences reasonably necessary to provide or improve the Services. These inferences may be produced using automated systems, artificial intelligence, rules-based systems, human review, or combinations of these methods.

4.7 Team, Collaboration, and Communication Information

If you participate in team features, we may collect:

  • team assignments;
  • team-role information;
  • participation history;
  • messages transmitted through Empresahaus-controlled communication features;
  • meeting or scheduling information;
  • feedback regarding matches or teammates;
  • reports of misconduct;
  • support communications; and
  • records necessary to administer a team. We do not claim ownership of a member’s independent venture idea or business merely because it is discussed through the Services.

4.8 Payment and Transaction Information

If you purchase a paid Service, we may collect:

  • billing contact information;
  • transaction date;
  • transaction amount;
  • subscription status;
  • payment status;
  • invoice or receipt information;
  • limited payment-method information supplied by a processor; and
  • records concerning refunds, disputes, cancellations, or renewals. Complete payment-card information may be collected directly by a third-party payment processor. Empresahaus does not store complete payment-card numbers on its own systems.

4.9 Device, Technical, and Usage Information

We or our service providers may collect information such as:

  • IP address;
  • browser and device information;
  • operating system;
  • language settings;
  • approximate location derived from IP address;
  • referring or exit pages;
  • timestamps;
  • pages, screens, or features viewed;
  • actions taken;
  • session information;
  • crash or performance information;
  • authentication or security logs; and
  • identifiers generated by cookies or similar technologies.

4.10 Cookies, Analytics, and Advertising Information

We may use cookies, local storage, SDKs, tags, scripts, pixels, and similar technologies as described in our Cookie and Tracking Technologies Policy.

Empresahaus does not currently enable third-party advertising technologies for cross-context behavioral advertising or targeted advertising as those terms are defined under applicable U.S. state privacy laws.

4.11 Support, Safety, and Integrity Information

If you contact us, report another member, appeal an enforcement decision, dispute a charge, or seek support, we may collect the information you provide and other information reasonably necessary to investigate, respond to, or document the matter.

4.12 Feedback, Surveys, Research, and Events

We may collect:

  • feedback;
  • survey responses;
  • product-research responses;
  • testimonials you voluntarily provide;
  • event registration information;
  • attendance status; and
  • related communications.

5. Sources of Personal Information

We may collect personal information from:

  • you directly;
  • files you upload;
  • websites or URLs you intentionally provide;
  • your activity within the Services;
  • other members;
  • service providers;
  • payment processors;
  • analytics providers;
  • security and fraud-prevention providers;
  • publicly available sources where legally permitted and relevant to a user-requested feature; and
  • other sources acting at your direction or with your authorization or consent. Empresahaus does not purchase scraped professional profiles or use unauthorized scraping of third-party professional networks as a source of member-profile data.

6. How We Use Personal Information

We may use personal information to:

  • create, authenticate, and maintain accounts;
  • determine or confirm eligibility for Member Services;
  • create and maintain EH member profiles;
  • extract professional information from resumes or submitted websites;
  • allow profile review and correction;
  • evaluate potential professional compatibility;
  • recommend or assign team roles;
  • recommend teammates and create team groupings;
  • facilitate introductions;
  • administer team changes;
  • provide, personalize, maintain, troubleshoot, analyze, and improve the Services;
  • send account, security, matching, team, support, event, and service communications;
  • send marketing communications where permitted and subject to your choices;
  • process purchases and administer subscriptions;
  • prevent fraud and payment abuse;
  • enforce our Terms of Service and Community Standards;
  • investigate reports and protect members;
  • maintain the safety, integrity, and security of the Services;
  • comply with law and legal process;
  • establish, exercise, or defend legal claims; and
  • perform additional processing when you direct us to do so or provide legally valid consent. We limit processing to purposes that are disclosed, reasonably necessary, compatible with the context in which information was collected, or otherwise permitted by applicable law.

7. Matching, Profiling, and Automated Systems

Empresahaus may use automated processing, artificial intelligence, rules-based logic, statistical methods, and human judgment to evaluate profile information and support professional matching and team formation.

These systems may generate or assist with:

  • professional role classifications;
  • skill or capability classifications;
  • profile summaries;
  • compatibility indicators;
  • matching scores or rankings;
  • suggested teammates;
  • suggested team assignments; and
  • other recommendations intended to help members identify potential collaborators. Automated outputs can be incomplete, inaccurate, or otherwise incorrect. They are intended to assist professional matching and team formation and do not establish objective truth about a member’s abilities, personality, character, reliability, employability, financial worthiness, or professional potential. Empresahaus does not use its matching system to make decisions concerning:
  • employment or hiring;
  • independent-contracting opportunities or compensation;
  • credit or lending;
  • housing;
  • insurance;
  • education enrollment or opportunities;
  • healthcare services;
  • criminal justice;
  • access to essential government services; or
  • other decisions that produce legal or similarly significant effects concerning an individual. Where applicable law provides rights concerning profiling or automated decisionmaking, Empresahaus will provide those rights as required.

8. Artificial Intelligence and Large Language Models

Empresahaus uses artificial intelligence, including large language models and other automated systems, to support certain features of the Services.

These technologies may be used to:

  • extract, organize, summarize, classify, or structure professional information;
  • generate profile information;
  • evaluate professional compatibility;
  • support matching and team recommendations;
  • assist with safety and security functions; and
  • operate, evaluate, or improve Empresahaus features.

8.1 Collection for AI and LLM Training

Empresahaus does not currently collect personal data for the purpose of training large language models. Processing member information through an AI provider to generate a profile or recommendation is described in this Section and is different from using that information to train a large language model.

Personal information collected through Empresahaus is collected for the purposes described in this Privacy Policy, including providing profiles, matching, collaboration, account administration, security, support, and related Services.

8.2 Use for AI and LLM Training

Empresahaus does not currently use member personal data to train large language models.

Empresahaus does not authorize AI service providers to independently use private member resumes, profiles, uploaded files, team communications, content submitted by members, or other private member personal information to train, fine-tune, or improve their general-purpose AI models.

AI service providers may process member information as necessary to provide AI-powered functionality to Empresahaus, subject to applicable contractual, technical, privacy, and security restrictions.

8.3 Sale or Disclosure for AI and LLM Training

Empresahaus does not currently sell personal data for the purpose of training large language models.

Empresahaus also does not disclose private member personal information to third parties for their independent use in training general-purpose AI models.

8.4 De-Identified, Aggregated, and Synthetic Information

Empresahaus may use de-identified, aggregated, synthetic, or otherwise non-personal information to analyze, evaluate, test, or improve Empresahaus systems and Services where permitted by law.

When Empresahaus maintains information as de-identified data, we:

  • take reasonable measures designed to prevent the information from being associated with an identifiable individual;
  • maintain and use the information in de-identified form;
  • do not attempt to re-identify the information except where necessary to test whether de-identification measures are effective or where otherwise expressly permitted by applicable law; and
  • where required by applicable law, contractually require recipients of de-identified information to maintain the information in de-identified form and not attempt to re-identify it. Except for permitted testing of de-identification safeguards or other processing expressly authorized by applicable law, Empresahaus publicly commits not to use de-identified information to identify individual members.

9. How We Disclose Personal Information

9.1 Other Members and Potential Teammates

We may disclose appropriate profile information to prospective or actual teammates or other members where necessary to provide matching, introductions, or team features.

This may include:

  • name;
  • profile image;
  • professional biography;
  • professional role;
  • skills;
  • experience;
  • interests;
  • general location;
  • availability; and
  • other profile fields intended for matching or collaboration. We do not intentionally disclose unnecessary sensitive personal information to prospective or actual teammates for matching purposes.

9.2 Service Providers and Contractors

We may disclose personal information to vendors and contractors that perform services on our behalf, including providers of:

  • cloud hosting;
  • databases and infrastructure;
  • authentication;
  • artificial intelligence processing;
  • email and messaging;
  • customer support;
  • analytics;
  • security and fraud prevention;
  • payment processing;
  • accounting;
  • file storage;
  • event administration; and
  • website operations. Service providers acting on our behalf may process personal information only for authorized purposes or as otherwise permitted by applicable law. Where required by applicable law, we use contractual terms addressing matters such as processing instructions, confidentiality, security, deletion or return of personal information, subprocessors, and other applicable privacy obligations. Professional advisers may also receive information as reasonably necessary to provide legal, accounting, insurance, security, or other professional services.

9.3 Payment Providers

Payment information may be disclosed to payment processors, financial institutions, card networks, and related parties as necessary to:

  • complete transactions;
  • prevent fraud;
  • administer subscriptions;
  • process refunds or disputes; and
  • meet financial or legal obligations.

9.4 Analytics and Technology Providers

Empresahaus may use third-party analytics, performance, infrastructure, or similar technologies.

Depending on the provider and configuration, those providers may receive device, browser, cookie, usage, interaction, or similar information as described in this Privacy Policy and the Cookie and Tracking Technologies Policy.

Empresahaus does not currently authorize third-party advertising technologies to use member activity for cross-context behavioral advertising or targeted advertising.

9.5 Legal, Safety, and Compliance Disclosures

We may disclose information where reasonably necessary to:

  • comply with applicable law, regulation, legal process, or government request;
  • protect the rights, safety, or security of Empresahaus, our members, or others;
  • investigate fraud, abuse, misconduct, or security incidents;
  • enforce our agreements and policies;
  • establish, exercise, or defend legal claims; or
  • respond to emergencies involving potential harm.

9.6 Business Transactions

If Empresahaus, Lincoln Barretta Consulting LLC, or relevant assets are involved in a merger, acquisition, financing, restructuring, bankruptcy, sale, or similar transaction, personal information may be disclosed as part of evaluating, negotiating, or completing the transaction, subject to applicable law and appropriate confidentiality protections.

9.7 With Your Direction or Consent

We may disclose personal information when you direct us to do so or provide legally valid consent.

9.8 De-Identified or Aggregated Information

We may disclose aggregated or de-identified information that is not reasonably linkable to an identifiable individual.

Where required by applicable law, recipients of de-identified information are contractually required to maintain the information in de-identified form and not attempt to re-identify it.

10. Sale, Sharing, and Targeted Advertising

Empresahaus does not currently:

  • sell personal information;
  • share personal information for cross-context behavioral advertising; or
  • process personal information for targeted advertising, as those terms are defined under applicable U.S. state privacy laws. This does not mean that Empresahaus never discloses personal information. As described in Section 9, we may disclose personal information to service providers, contractors, payment processors, prospective or actual teammates, professional advisers, and other parties as necessary to provide, maintain, secure, and operate the Services. Where applicable law excludes such disclosures from the definitions of “sale,” “sharing,” or targeted advertising, they are not treated as a sale, sharing, or targeted advertising. If Empresahaus begins selling personal information, sharing personal information for cross-context behavioral advertising, or processing personal information for targeted advertising in the future, we will update this Privacy Policy and other applicable notices and implement legally required consumer rights and controls before or at the time the new processing begins. Where required by applicable law, those controls may include:
  • a Your Privacy Choices mechanism;
  • an opt-out of sale or sharing;
  • an opt-out of targeted advertising; and
  • recognition of qualifying opt-out preference signals such as Global Privacy Control.

11. Sensitive Personal Information

Empresahaus is designed primarily to collect professional information needed to create profiles, provide matching and team features, administer accounts, and operate the Services.

We do not intentionally request sensitive personal information unless it is reasonably necessary for a specific feature or purpose that has been clearly disclosed.

Unless specifically requested by Empresahaus for a legitimate and disclosed purpose, please do not submit sensitive personal information through resumes, CVs, portfolios, profiles, free-form fields, team communications, or other uploads.

Sensitive personal information may include, where applicable:

  • Social Security numbers;
  • passport numbers;
  • driver's-license numbers;
  • state identification numbers;
  • other government-issued identifiers;
  • financial-account numbers;
  • financial-account credentials;
  • security codes or passwords;
  • precise geolocation;
  • health or medical information;
  • disability or treatment information;
  • genetic or neural information;
  • biometric identifiers or templates;
  • information revealing race or ethnicity;
  • religious or philosophical beliefs;
  • sexual orientation;
  • gender identity where treated as sensitive data under applicable law;
  • citizenship or immigration status; and
  • other information defined as sensitive personal information or sensitive data under applicable law.

11.1 Sensitive Information Submitted Incidentally

A resume, profile, portfolio, document, communication, or other content submitted to Empresahaus may contain sensitive personal information that Empresahaus did not request or intend to collect.

When we identify sensitive personal information that was submitted incidentally and is not necessary for a disclosed Empresahaus purpose, we may take reasonable steps to:

  • exclude the information from profile creation;
  • exclude it from matching, compatibility scoring, recommendations, rankings, and other automated processing;
  • redact, remove, or delete the information from active systems where reasonably practicable;
  • restrict access while deletion, redaction, or other appropriate action is completed;
  • delete or request replacement of an uploaded file where the sensitive information cannot reasonably be separated from the file; and
  • retain only information that may lawfully be retained for security, fraud prevention, legal compliance, dispute resolution, enforcement, or another lawful purpose. Empresahaus does not intentionally use incidentally submitted sensitive personal information to determine team compatibility, matching scores, suggested roles, rankings, or team assignments. If continued processing of sensitive personal information would require consent under applicable law, Empresahaus will obtain the required consent before continuing that processing or will restrict, delete, or otherwise cease the covered processing as required.

11.2 Sensitive Characteristics and Inferences

Empresahaus does not infer or attempt to infer sensitive characteristics from resumes, profiles, photographs, uploaded files, websites, communications, or other member information for purposes of professional matching or team formation.

This includes characteristics such as:

  • race or ethnicity;
  • religion;
  • health or disability status;
  • sexual orientation;
  • gender identity where treated as sensitive data under applicable law;
  • genetic characteristics;
  • citizenship or immigration status; and
  • political beliefs.

11.3 Detection Limitations

Empresahaus does not represent that it can automatically identify every instance of sensitive personal information contained in information submitted by members.

Members are responsible for reviewing resumes, portfolios, documents, and other content before submission and removing sensitive information that is not necessary for their use of the Services.

If you believe you inadvertently submitted sensitive personal information that is not necessary for the Services, contact info@lincolnbarretta.com with the subject line Privacy Request and identify the information you would like reviewed or removed.

11.4 Sensitive Information Requested by Empresahaus

If Empresahaus introduces a feature that requires sensitive personal information, we will:

  • identify the information requested;
  • explain the purpose for collecting and using it;
  • limit processing to information reasonably necessary for the disclosed purpose;
  • provide any additional notice required by law; and
  • obtain consent before processing where required by applicable law. Where processing depends on consent, we will provide any legally required mechanism for withdrawing that consent and will stop covered processing within the period required by applicable law.

12. Data Retention

Empresahaus retains personal information according to the general retention schedule below.

Where applicable law requires earlier deletion, including in response to a valid deletion request, we will delete or de-identify covered information sooner unless a lawful exception applies.

Retention periods may be extended as described in Sections 12.1 and 12.2.

Category of Personal General Retention Period or Criteria Information

Account, contact, and Retained while your account is active and for up to 24 months core profile information after account closure, unless deleted earlier pursuant to applicable law.

Authentication Retained while necessary to maintain and secure the account. information Active credentials and access tokens are revoked or deleted when the account is closed. Related authentication and security records are generally retained for up to 12 months where maintained by Empresahaus.

Professional profile, Retained while your account is active and for up to 24 months preferences, after account closure to administer the Services, address questionnaires, and account issues, and maintain appropriate records of prior directly entered matching activity. information

Resumes, CVs, Current files are retained while used to provide the Services. portfolios, profile Superseded files are generally deleted from active systems images, and other within 90 days. Remaining uploaded files are generally deleted uploaded files from active systems within 90 days after account closure, unless a lawful exception applies.

Information extracted Temporary copies, extracted source material, and caches are from user-submitted generally retained for no more than 90 days after extraction, websites unless needed during that period to resolve an extraction, security, or verification issue. Information incorporated into an EH profile follows the applicable profile-information retention period.

Matching data, derived Retained while your account is active and for up to 24 months data, and inferences after account closure. Matching information associated with a team may also be retained for the applicable team-record period.

Team assignments and Retained while the team is active and for up to 36 months after team participation the team ends. history

In-platform team Retained while the applicable team is active and for up to 24 communications and months after the team becomes inactive or ends, unless a collaboration records shorter period applies through a Service feature or longer retention is reasonably necessary for safety, disputes, enforcement, or legal obligations.

Payment, transaction, Retained for up to 7 years after the relevant transaction or end of invoice, and accounting the applicable subscription where appropriate for tax, accounting, records fraud-prevention, and legal-recordkeeping purposes.

Subscription Retained for up to 7 years after the relevant authorization, authorization, renewal, cancellation, or end of the subscription. and cancellation records

Terms, Privacy Policy, Retained for up to 7 years after account termination to Team Agreement, and maintain evidence of agreements and disclosures applicable to other legal acceptance an account. records

Support requests and Retained for up to 24 months after the request or matter is routine account-related closed. communications

Safety, misconduct, Routine records may be retained for up to 24 months after fraud, abuse, and resolution. Records involving serious misconduct, fraud, safety enforcement records risks, permanent restrictions, or material legal claims may be retained for up to 7 years after resolution. Limited identifiers may be retained longer where reasonably necessary to enforce a permanent restriction, prevent repeated fraud or abuse, or meet legal obligations.

Device, technical, Generally retained for up to 12 months from collection, unless security, and associated with a security incident, fraud investigation, legal authentication logs claim, or other matter requiring longer retention.

User-linked analytics Generally retained in identifiable or user-linked form for up to 12 and usage information months from collection, after which information may be deleted, aggregated, or de-identified.

Cookies and similar Session technologies expire when the applicable session ends. technologies Persistent technologies are retained for the periods disclosed in the Cookie and Tracking Technologies Policy or the applicable technology.

Marketing consent and Records demonstrating consent, withdrawal, or unsubscribe communication-preferen activity may be retained for up to 7 years after the relevant ce records action. Minimal suppression information may be retained as long as reasonably necessary to continue honoring an opt-out or unsubscribe request.

Privacy-rights requests Retained for at least 24 months after the request or appeal is and appeals closed, or longer where required by law. Identity-verification information collected solely for a privacy request is deleted when no longer reasonably necessary to complete or document the request.

Feedback, surveys, Generally retained for up to 24 months after collection or the research, and event applicable event, unless converted to aggregated or information de-identified form. Testimonials or content you authorize us to publish may be retained while the authorization remains valid and the content remains in use.

De-identified and May be retained for longer periods, including indefinitely, where aggregated information maintained in a form that cannot reasonably be linked to an identifiable individual and handled in accordance with Section 8.4.

12.1 Legal Holds and Other Required Retention

The periods above may be extended where reasonably necessary to:

  • comply with a legal obligation;
  • comply with a court order or regulatory requirement;
  • satisfy tax or accounting requirements;
  • preserve information subject to a litigation hold;
  • investigate fraud or security incidents; or
  • establish, exercise, or defend legal claims. When information is retained beyond its ordinary retention period for one of these purposes, we limit its continued use to purposes reasonably related to the reason for extended retention and delete or de-identify it when the reason no longer applies.

12.2 Deletion and Backups

When a retention period expires, Empresahaus deletes, de-identifies, aggregates, or otherwise securely disposes of affected personal information in accordance with applicable law and our data-management practices.

Information deleted from active systems may remain temporarily in encrypted, access-restricted, disaster-recovery, or system backups until those backups are overwritten, expire, or are otherwise removed through the ordinary backup lifecycle.

Information retained solely in backups is not returned to ordinary active use except where reasonably necessary for:

  • disaster recovery;
  • security;
  • system restoration;
  • legal compliance; or
  • another legitimate recovery purpose. Where information is restored from a backup, deletion requests, account closures, restrictions, or other applicable privacy controls may be reapplied where reasonably practicable and required by law.

13. Security

Empresahaus uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, acquisition, use, disclosure, alteration, or destruction.

Our safeguards are selected based on:

  • the nature of the information involved;
  • how the Services operate;
  • the sensitivity of the information;
  • the volume of information processed; and
  • risks reasonably associated with the processing. Our measures include controls designed to:
  • restrict access to personal information to authorized individuals and service providers with a legitimate need for access;
  • protect account access and authentication credentials;
  • protect personal information during transmission using security measures supported by our systems and service providers;
  • limit collection and retention to information reasonably necessary for disclosed purposes;
  • manage access by service providers and contractors;
  • detect, investigate, and respond to suspected security incidents; and
  • delete, de-identify, or otherwise securely dispose of information according to applicable retention practices. Empresahaus relies on third-party technology, hosting, infrastructure, payment, communications, artificial-intelligence, and other service providers. Those providers are responsible for security controls applicable to the systems and services they operate. We seek to use providers and processing arrangements appropriate to the nature of the information and Services involved and impose contractual security and data-processing requirements where required by applicable law. We periodically evaluate our safeguards and may update them as the Services, technology, risks, and legal requirements change. No method of Internet transmission, electronic storage, or security protection is completely secure. Accordingly, we cannot guarantee that personal information will never be accessed, acquired, used, disclosed, altered, or destroyed without authorization.

14. Your Privacy Choices

Depending on the Services, your account, and applicable law, you may be able to:

  • review or edit profile information;
  • change communication preferences;
  • unsubscribe from marketing;
  • close your account;
  • request access to personal information;
  • request correction;
  • request deletion;
  • request portability;
  • withdraw certain consent;
  • opt out of certain sale, sharing, targeted advertising, or profiling where applicable; and
  • appeal certain privacy-request decisions. Additional legally available rights are described in Sections 15, 16, and 17.

15. U.S. State Privacy Rights

Residents of certain U.S. states may have rights under applicable privacy laws to:

  • confirm whether Empresahaus processes their personal information;
  • access personal information;
  • receive information concerning categories, sources, purposes, and recipients of personal information;
  • correct inaccurate personal information;
  • request deletion;
  • obtain a portable copy of certain personal information;
  • opt out of sale, targeted advertising, or certain profiling where applicable;
  • limit certain uses of sensitive personal information where applicable;
  • withdraw consent where processing is based on consent;
  • appeal certain decisions concerning privacy requests; and
  • exercise privacy rights without unlawful discrimination. The rights available to you depend on your state of residence, the applicable law, and whether that law applies to Empresahaus.

15.1 How to Submit a Privacy Request

You may submit a privacy request by emailing info@lincolnbarretta.com with the subject line Privacy Request.

Please identify the privacy right you wish to exercise and provide enough information for us to understand and process your request.

You are not required to create a new Empresahaus account solely to submit a privacy request.

If you already have an account, we may use your existing account to help authenticate the request.

15.2 Verification of Requests

Before fulfilling certain privacy requests, Empresahaus may need to verify that the person making the request is the individual to whom the personal information relates.

Depending on the nature and sensitivity of the request, verification may include:

  • confirming access through an existing Empresahaus account;
  • sending a verification message to an email address associated with the account;
  • asking the requester to confirm limited information already associated with the account; or
  • requesting additional information reasonably necessary to verify identity. We use verification methods intended to be proportionate to the sensitivity of the information and the risk of unauthorized disclosure, alteration, or deletion. Empresahaus does not require government-issued identification as a standard verification method where a less intrusive method is reasonably sufficient. Information collected solely to verify a privacy request will be used for verification, security, fraud prevention, and legally required recordkeeping and will not be used for unrelated purposes. If we cannot reasonably verify a request, we may request additional information. If we remain unable to verify the request, we may deny or limit the request where permitted by applicable law and explain the reason for doing so.

15.3 Response Timing

Empresahaus will respond to privacy requests without undue delay and within the period required by applicable law.

For laws that generally provide a 45-day response period, we generally respond no later than 45 calendar days after receiving the request, subject to legally permitted extensions.

Where an extension is reasonably necessary and permitted by law, we will notify you within the initial response period and explain the reason for the extension.

If applicable law requires a shorter response period, we will follow the shorter period.

If we deny all or part of a request, our response will explain the basis for the decision and, where applicable, provide instructions for appealing the decision.

Privacy requests will be processed without charge unless applicable law permits a reasonable fee, including where a request is manifestly unfounded, excessive, repetitive, or exceeds the number of free requests provided by law.

15.4 Authorized Agents

Where applicable law permits use of an authorized agent, another person or entity may submit a privacy request on your behalf.

An authorized-agent request should identify:

  • the individual whose privacy rights are being exercised;
  • the authorized agent;
  • the privacy right or rights the agent is authorized to exercise; and
  • sufficient information for Empresahaus to evaluate the agent’s authority. We may require an authorized agent to provide:
  • written authorization signed by the individual;
  • a valid power of attorney; or
  • other legally sufficient evidence of authority. Unless prohibited by applicable law or unnecessary because the agent holds legally sufficient authority, we may also contact the individual directly to verify identity and confirm authorization. Authorized-agent requests may be submitted by emailing info@lincolnbarretta.com with the subject line Authorized Agent Privacy Request or through the privacy request form where that option is available. We will not disclose personal information to an authorized agent unless we have reasonably verified the request and the agent’s authority where verification is permitted or required by law.

15.5 Appeals

If Empresahaus denies all or part of a privacy request and applicable law provides a right to appeal, you may appeal the decision.

An appeal may be submitted by:

  • emailing info@lincolnbarretta.com with the subject line Privacy Appeal; or
  • using the privacy request form and selecting the appeal option where available. An appeal should identify the original privacy request and explain why you believe the decision should be reconsidered. An appeal should be submitted within a reasonable period after receiving our decision or within any different period required by applicable law. We will review the appeal and respond within the period required by applicable law. Our response will explain the action taken or not taken and the reasons for our decision. If an appeal is denied, we will provide information regarding any additional complaint procedure required by applicable law. For Connecticut residents, this includes information about how to submit a complaint to the Connecticut Attorney General.

15.6 Requests to Delete Personal Information

When we approve a deletion request, we will delete or de-identify covered personal information from active systems and direct applicable service providers to take corresponding action where required by law.

Certain information may be retained where permitted or required by law, including information reasonably necessary to:

  • complete a transaction or provide a Service requested by you;
  • maintain security;
  • prevent fraud or abuse;
  • comply with legal, tax, accounting, or regulatory obligations;
  • exercise or defend legal claims;
  • enforce agreements;
  • maintain records of privacy requests or legal consents;
  • preserve information subject to a legal hold; or
  • honor a prior opt-out, unsubscribe, or account restriction. Information remaining solely in backups will be handled according to Section 12.2.

15.7 Corrections and Service Providers

When we approve a correction request, we will correct inaccurate personal information in relevant active systems.

Where required by applicable law, we will also take reasonable steps to communicate an approved correction or deletion request to service providers or processors maintaining affected personal information on our behalf.

15.8 Non-Discrimination

Empresahaus will not unlawfully discriminate against you for exercising a privacy right.

Exercising a privacy right will not, by itself, result in:

  • denial of Services;
  • different pricing; or
  • a different level or quality of Service, except where a difference is reasonably related to personal information necessary to provide the Service or is otherwise permitted by applicable law.

16. Connecticut Privacy Disclosures

This section supplements this Privacy Policy for Connecticut residents where the Connecticut Data Privacy Act (“CTDPA”) applies.

16.1 Personal Data We Process and Why

The categories of personal data Empresahaus may process are described in Section 4 — Personal Information We Collect.

The purposes for processing personal data are described in Section 6 — How We Use Personal Information.

The categories of parties to which we may disclose personal data are described in Section 9 — How We Disclose Personal Information.

Our retention periods and criteria are described in Section 12 — Data Retention.

16.2 Sale of Personal Data and Targeted Advertising

Empresahaus does not currently sell personal data to third parties as “sale” is defined under the CTDPA.

Accordingly:

  • there are currently no categories of personal data that Empresahaus sells to third parties; and
  • there are currently no categories of third parties to which Empresahaus sells personal data. Empresahaus does not currently process personal data for targeted advertising as defined under the CTDPA. If these practices change, we will update this Privacy Policy and provide any notices, consent mechanisms, opt-out rights, universal opt-out signal recognition, or other controls required by Connecticut law before or at the time the new processing begins.

16.3 Large Language Model Training

Empresahaus does not currently collect personal data for the purpose of training general-purpose large language models.

Empresahaus does not currently use member personal data for the purpose of training large language models.

Empresahaus does not currently sell personal data for the purpose of training large language models.

As described in Section 8, Empresahaus may use artificial-intelligence and large-language-model service providers to process personal data as necessary to provide profile, matching, safety, support, and other features.

Such processing is performed to provide functionality to Empresahaus and does not authorize those providers to independently use private member personal information to train their general-purpose artificial-intelligence or large-language models.

If our practices concerning collection, use, or sale of personal data for large-language-model training change, we will update this Privacy Policy and provide any notice or consent required by applicable law before covered new processing begins.

16.4 Publicly Available Information and Profile Data

Empresahaus may process publicly available professional or business information from a website or URL that you intentionally provide, as described in Sections 4.4 and 5.

Information is not treated as outside the protections of this Privacy Policy merely because some underlying information originated from a publicly available source.

Where publicly available information is combined, organized, transformed, or used to create an identifiable Empresahaus profile, matching information, derived data, or inferences, we handle that information in accordance with this Privacy Policy and applicable Connecticut law.

Connecticut residents may request access to, correction of, or deletion of covered personal data derived from or incorporated into such profiles, subject to applicable law and exceptions, using the procedures described in Section 15.

16.5 Precise Geolocation Data

Empresahaus may collect general geographic information such as city, state, time zone, or approximate location derived from an IP address.

Empresahaus does not currently collect precise geolocation data as part of its standard member profile or matching functionality.

Empresahaus does not sell precise geolocation data.

If Empresahaus introduces a feature that collects precise geolocation data in the future, we will provide any notice and obtain any consent required by applicable law before collecting or processing the information.

Empresahaus will not sell, disclose, transfer, or otherwise provide access to precise geolocation data in a manner prohibited by Connecticut law.

16.6 Sensitive Personal Data and Consent

Empresahaus does not use sensitive personal characteristics such as race, ethnicity, religion, health status, sexual orientation, citizenship status, or political beliefs for team matching.

Where the CTDPA applies, Empresahaus will not process sensitive personal data in a manner requiring consent under Connecticut law without first obtaining legally valid consent, unless an applicable legal exception permits the processing.

If sensitive personal information is submitted incidentally without having been requested, Empresahaus will not intentionally use it for team matching and will take reasonable steps to restrict, redact, delete, or otherwise cease unnecessary processing as described in Section 11.

If continued processing would require consent under Connecticut law, Empresahaus will obtain the required consent before continuing the covered processing.

Where processing is based on consent, Connecticut consumers may withdraw that consent through a mechanism at least as easy as the mechanism used to provide consent.

Where required by the CTDPA, Empresahaus will stop the covered processing as soon as practicable and no later than 15 days after receiving a valid withdrawal of consent.

16.7 Profiling and Automated Decisionmaking

Empresahaus may use automated systems, artificial intelligence, rules-based logic, and statistical methods for professional profiles, compatibility indicators, matching, and team recommendations as described in Sections 7 and 8.

These systems are used for professional matching and team formation.

Empresahaus does not use its matching systems to make automated decisions concerning:

  • credit or lending;
  • housing;
  • insurance;
  • criminal justice;
  • access to essential government services;
  • employment opportunities;
  • independent-contracting compensation;
  • education enrollment;
  • healthcare; or
  • other decisions that produce legal or similarly significant effects concerning a consumer. Where Empresahaus engages in profiling subject to Connecticut consumer rights, Connecticut residents may have rights to:
  • opt out of qualifying profiling;
  • question the result of a qualifying profiling decision;
  • receive information concerning the reason for the result;
  • review personal data used in a qualifying profiling decision;
  • correct inaccurate personal data used in the decision where applicable; and
  • have a qualifying decision reevaluated using corrected information where required by law. Requests concerning profiling may be submitted using the procedures described in Section 15.

16.8 Connecticut Consumer Rights

Subject to applicable law and exceptions, Connecticut residents may have rights to:

  • confirm whether Empresahaus processes their personal data and access that data;
  • correct inaccuracies;
  • request deletion of personal data provided by or obtained about them;
  • obtain a portable copy of certain personal data;
  • opt out of targeted advertising;
  • opt out of sale;
  • opt out of qualifying profiling;
  • exercise rights concerning qualifying automated profiling decisions;
  • obtain information concerning certain third parties to which personal data has been sold, where applicable; and
  • appeal certain decisions regarding privacy requests. Because Empresahaus does not currently sell personal data or process personal data for targeted advertising, there are currently no sale or targeted-advertising activities from which Connecticut residents need to opt out.

16.9 Requests and Appeals

Connecticut residents may submit privacy requests, authorized-agent requests, and appeals using the procedures described in Section 15 — U.S. State Privacy Rights.

Requests may be submitted to: info@lincolnbarretta.com

Use the subject line:

  • Privacy Request for an initial request;
  • Authorized Agent Privacy Request for a request submitted by an authorized agent; or
  • Privacy Appeal for an appeal. Empresahaus will respond to a Connecticut privacy request without undue delay and generally no later than 45 calendar days after receiving the request. Where reasonably necessary and permitted by law, that period may be extended once for up to an additional 45 calendar days. We will notify you within the initial period if an extension applies and explain the reason. If Empresahaus declines to take action, we will explain the reason and provide instructions for submitting an appeal where an appeal right applies. Empresahaus will respond to a Connecticut appeal within the period required by Connecticut law. If an appeal is denied, we will provide information about how to submit a complaint to the Connecticut Attorney General, as required by applicable law.

16.10 De-Identified Data

Where Empresahaus possesses de-identified data subject to Connecticut law, we:

  • take reasonable measures designed to prevent the information from being associated with an individual;
  • publicly commit to maintaining and using the information in de-identified form without attempting to re-identify it, except for legally permitted testing of de-identification safeguards; and
  • contractually require recipients of covered de-identified data to comply with applicable de-identification restrictions.

16.11 Changes to Connecticut Practices

If Empresahaus materially changes a practice described in this section, including practices concerning:

  • sale of personal data;
  • targeted advertising;
  • large-language-model training;
  • precise geolocation;
  • sensitive data; or
  • qualifying profiling, we will update this Privacy Policy and implement any notice, consent, opt-out, assessment, or other consumer-right mechanism required by Connecticut law.

16.12 Contact

Connecticut residents may contact Empresahaus regarding privacy matters at:

Lincoln Barretta Consulting LLC d/b/a Empresahaus

109 Bridge St.

Unit #1133

Groton, CT 06340

Email: info@lincolnbarretta.com

Most recent update: October 2026

17. California Privacy Disclosures

This section provides additional disclosures for California residents.

Certain provisions below apply only where a particular California privacy law applies to Empresahaus.

17.1 Categories of Personal Information

Empresahaus may collect categories of personal information including:

  • identifiers;
  • customer-record information;
  • commercial or transaction information;
  • Internet or electronic-network activity;
  • approximate geolocation;
  • visual or electronic information voluntarily submitted or used in a feature;
  • professional or employment-related information;
  • education information voluntarily provided;
  • inferences;
  • uploaded content; and
  • limited sensitive personal information as described in Section 11. Additional details appear in Section 4.

17.2 Sources and Purposes

Sources of personal information are described in Section 5.

Business and operational purposes for processing personal information are described in Section 6.

Categories of parties to whom information may be disclosed are described in Section 9.

17.3 Sale or Sharing Under the CCPA

Where the California Consumer Privacy Act (“CCPA”) applies to Empresahaus, Empresahaus does not currently sell personal information or share personal information for cross-context behavioral advertising as those terms are defined by the CCPA.

To the extent the CCPA applies, during the preceding 12 months Empresahaus has not sold or shared consumers’ personal information as those terms are defined by the CCPA.

This does not include disclosures to service providers, contractors, or other parties where a disclosure is not treated as a sale or sharing under applicable law.

If Empresahaus becomes subject to the CCPA and begins selling or sharing personal information, we will update this Privacy Policy and applicable notices and implement required opt-out rights before or at the time the new practice begins.

Where required by applicable California law, Empresahaus will recognize qualifying opt-out preference signals such as Global Privacy Control.

17.4 Disclosures for Business Purposes

We may disclose the categories of information described above to service providers, contractors, and other parties for business or operational purposes described in Sections 6 and 9, subject to applicable legal and contractual restrictions.

17.5 Sensitive Personal Information

Empresahaus does not intentionally use or disclose sensitive personal information for the purpose of inferring sensitive characteristics in a manner that would trigger a right to limit such processing under the CCPA.

17.6 California Consumer Rights Under the CCPA

Where the CCPA applies to Empresahaus, California residents may have rights to:

  • know categories or specific pieces of personal information collected;
  • access personal information;
  • request deletion;
  • request correction;
  • opt out of sale or sharing;
  • limit certain uses of sensitive personal information;
  • receive equal treatment for exercising privacy rights; and
  • exercise other rights provided by applicable California law. Where a right applies, requests may be submitted using the procedures described in Section 15.

17.7 California Online Tracking and Do Not Track Disclosures

Some web browsers offer a Do Not Track (“DNT”) setting intended to signal a preference concerning certain online tracking.

There is not currently a single universally adopted technical standard governing how all websites and online services must respond to traditional browser DNT signals.

Accordingly, Empresahaus does not currently respond to traditional browser DNT signals as a separate privacy-control mechanism.

This is different from legally recognized opt-out preference signals, such as Global Privacy Control (“GPC”). Where applicable law requires Empresahaus to recognize a qualifying opt-out preference signal, we will process the signal as required.

Third-party service providers used for analytics, performance, security, infrastructure, or similar functions may collect information concerning online activity over time and, depending on the provider and configuration, across different websites or online services where their technologies are present.

Empresahaus does not currently authorize third-party advertising technologies to collect or use activity through the Services for cross-context behavioral advertising or targeted advertising.

Additional information regarding cookies and similar technologies is available in our Cookie and Tracking Technologies Policy.

18. Cookies and Communications

Cookie and similar-technology practices and available cookie choices are described in our Cookie and Tracking Technologies Policy.

Where a cookie-preference mechanism is provided, users may be able to manage categories of non-essential technologies as described in that tool and policy.

Marketing emails may be unsubscribed from using the unsubscribe mechanism included in the communication or another method we provide.

Any legally required consent for marketing text messages will be obtained separately from general acceptance of the Terms of Service.

Transactional or service communications reasonably necessary to administer an account, subscription, security matter, team activity, legal notice, or requested Service may continue after you opt out of marketing communications.

19. Under-18 Accounts

Empresahaus Member Services are intended exclusively for individuals who are 18 years of age or older.

Individuals under 18 may not create or maintain an Empresahaus member account or participate in member matching, team formation, or member-to-member collaboration features.

19.1 If We Discover an Under-18 Account

If Empresahaus learns or reasonably determines that an account may belong to an individual under 18, we may:

  • temporarily suspend or restrict the account while the matter is reviewed;
  • disable matching;
  • disable team participation;
  • disable messaging or other member features;
  • request limited information reasonably necessary to confirm age where appropriate; and
  • stop using the individual's personal information for matching, recommendations, personalization, or other ordinary Member Services while the matter is reviewed. If Empresahaus determines that the account holder is under 18, we will terminate or permanently disable the member account and delete or de-identify the under-18 user’s personal information as reasonably appropriate and required by applicable law. Limited information may be retained where reasonably necessary and legally permitted for:
  • security;
  • fraud prevention;
  • enforcement of account restrictions;
  • legal compliance;
  • dispute resolution; or
  • protection of the rights and safety of Empresahaus, our members, or others. Such retained information will not be used to allow the under-18 user to continue participating in Member Services. If an account is suspended based on incorrect information and the account holder reasonably verifies that they are at least 18 years old, Empresahaus may restore the account.

19.2 Users Under 13

Empresahaus does not knowingly permit users under 13 to create accounts or use Member Services.

For purposes of the Children’s Online Privacy Protection Act (“COPPA”), a “child” is an individual under 13.

If Empresahaus obtains actual knowledge that it has collected personal information through a member account from a child under 13, Empresahaus will stop using that information for ordinary Member Services, terminate or permanently disable the account, and delete the personal information as soon as reasonably practicable, subject only to information that may

lawfully and necessarily be retained for security, fraud prevention, legal compliance, or similar limited purposes.

Empresahaus does not use parental consent as a means of allowing a user under 18 to create or maintain an Empresahaus member account.

19.3 Reports Concerning an Under-18 User

If you believe an individual under 18 has created an Empresahaus account or provided personal information through Member Services, contact:

info@lincolnbarretta.com

Subject line: Under-18 Account

A parent or legal guardian may also contact us regarding personal information they reasonably believe was submitted by an under-18 user.

Before disclosing account information or acting at the direction of another person, Empresahaus may take reasonable steps to verify:

  • the requester’s identity;
  • the requester’s relationship to the under-18 user; and
  • the requester’s authority to make the request. We will review credible reports and take appropriate action in accordance with this Privacy Policy and applicable law.

20. Geographic Availability

Empresahaus Member Services are currently offered only to individuals aged 18 or older whose primary residence is in one of the fifty U.S. states or the District of Columbia. For this membership rule, the United States does not include Puerto Rico or other U.S. territories or possessions. Citizenship is not required. Temporary travel does not by itself change eligibility while your primary residence remains in an eligible location. Public portions of the website may be accessible from elsewhere. This geographic availability rule does not limit rights protected by applicable civil-rights law.

Empresahaus may expand Member Services to additional countries or jurisdictions in the future.

Before intentionally offering Member Services in an additional jurisdiction, we may update:

  • this Privacy Policy;
  • our Terms of Service;
  • applicable privacy notices;
  • cookie and tracking controls;
  • data-transfer arrangements;
  • consent mechanisms; and
  • other agreements or privacy controls, as appropriate for the applicable jurisdiction. If Empresahaus learns that a member does not meet geographic eligibility requirements, we may restrict or terminate the account and handle associated personal information in accordance with this Privacy Policy and applicable law.

21. Changes to This Policy

We may update this Privacy Policy to reflect changes in:

  • the Services;
  • technology;
  • vendors or processing arrangements;
  • privacy practices;
  • applicable law; or
  • other operational requirements. When we make material changes, we will provide notice where required by applicable law. If we intend to collect new categories of personal information or use previously collected personal information for a materially different or incompatible purpose, we will provide any additional notice or obtain any consent required by applicable law before beginning the covered processing. Where applicable law requires additional protection for a retroactive material change affecting information previously collected, Empresahaus will provide affected individuals with legally required notice and a reasonable opportunity to withdraw consent, object, or exercise another applicable privacy choice before or in connection with applying the materially different processing. We will not rely on a general update to this Privacy Policy as a substitute for affirmative consent where applicable law requires affirmative consent. The Last Updated date at the top of this Privacy Policy identifies when this Privacy Policy was most recently revised.

22. Accessibility

We intend for this Privacy Policy and our privacy-request mechanisms to be reasonably accessible to individuals with disabilities.

If you need this Privacy Policy or a privacy-request mechanism in an alternative format, contact:

info@lincolnbarretta.com

23. Contact Us

For questions or requests concerning this Privacy Policy or Empresahaus privacy practices, contact:

Lincoln Barretta Consulting LLC d/b/a Empresahaus 109 Bridge St. Unit #1133 Groton, CT 06340

Email: info@lincolnbarretta.com