Ntegrity 1st Advisors – Database Reactivation Services

Last Updated: November 2025

1. Overview
This Privacy Policy explains how Ntegrity 1st Advisors (“Company,” “we,” or “our”) collects, processes, and safeguards personal information during the performance of database reactivation, outreach, verification, and related administrative services (“Services”). We are committed to maintaining strict privacy and security standards in accordance with applicable federal and state data protection laws.

2. Categories of Data We Process
The Company may handle personal information provided by clients, including:
- Contact information (names, addresses, emails, phone numbers)
- Account or record identifiers
- Dormant account status or historical information
- Publicly available data
- Client-provided notes or supplemental verification data

We do not collect or use data for independent commercial purposes.

3. Lawful Basis and Authorization
Clients are responsible for ensuring that:
- All provided data was lawfully obtained
- Required consumer notices have been issued
- Data subjects’ rights under privacy laws are respected
- Processing instructions comply with all applicable laws

We serve strictly as a service provider or processor and do not act as a data controller.

4. How We Use Personal Information
Personal information is used solely to:
- Reactivate dormant customer or claimant accounts
- Verify or update contact details
- Conduct lawful outreach by phone, SMS, email, or mail
- Report outcomes and verification results to clients
- Maintain compliance and audit documentation

We do not sell, trade, or disclose personal data for external marketing.

5. Data Security Measures
We use industry-standard security practices, including:
- Encryption in transit and at rest
- Access controls and role-based permissions
- Secure networks and monitored systems
- Audit trails and activity logging
- Secure data destruction protocols

6. Data Retention
Personal information is retained only as long as needed for:
- Delivery of contracted Services
- Legal and regulatory obligations
- Specific timeframes outlined in Service Agreements

Upon termination or client request, data is returned or securely destroyed.

7. Data Sharing and Disclosure
Information may be disclosed only:
- At the client’s explicit direction
- To authorized subcontractors under strict confidentiality
- When required by law or lawful authority
- To prevent fraud or protect operational security

We do not disclose data for advertising or profiling.

8. Consumer Rights
Depending on jurisdiction, individuals may have rights such as:
- Access to their information
- Correction of inaccurate data
- Deletion requests
- Opt-out rights for certain communications
- Restrictions on sensitive data use

Requests must be made directly to the data controller (our client). We assist clients in fulfilling verified requests.

9. Outreach and Communications Compliance
All communications follow:
- TCPA requirements
- CAN‑SPAM rules
- State-level Do‑Not‑Call (DNC) statutes
- Carrier messaging guidelines
- Opt-out and unsubscribe protocols

We honor opt-out requests immediately and notify clients.

10. Children’s Privacy
We do not knowingly process data of individuals under 18. Any such information identified will be deleted promptly.

11. Changes to This Privacy Policy
This Policy may be updated periodically. The “Last Updated” date reflects revisions. Continued use of Services indicates acceptance of changes.

12. Contact Information
Ntegrity 1st Advisors
Compliance & Data Governance Department
Email: [email protected]