Privacy Policy

4-Eyes.ai Data Services and Website Privacy Policy

4-Eyes.ai Inc. (“We,” “Our,” “4-Eyes.ai,” “4-Eyes”) provides a variety of data marketing and consumer analytics products (the “Services”) designed to help for-profit and not-profit organizations, and companies that work with them, to market their goods and services in a relevant and efficient way.   Our solutions, many of which are described on this website, are used through direct mail, email, online, connected-TV and other marketing channels.

We take seriously the privacy interests and consumer choices of the individuals whose information we handle and maintain in our database.  This Privacy Policy describes how we collect, use and manage information, and what rights consumers have to control how their information is used in marketing.   

To review the “Addendum” we have created specifically to address disclosures required under the California Consumer Privacy Act, please see our “CCPA PRIVACY NOTICE.” 

1. Information That We Collect and Use in Our Services

In order to provide our Services, we receive data, including personal information, from a variety of sources, including from websites and apps that collect the information, public sources, and other data compilers.   We refer to the information that we collect and process throughout this Privacy Policy  as “Information” or “the Information.”

The Information often includes various contact information, such as name, address, email address and telephone number.  It also includes demographic information about individuals.   It may also include information (on the individual, household, or wider (e.g., zip code) level), such as:

• Professional information, including occupation and job title or job history,
• Particular interests, such as (for instance) home improvement, music, online shopping, health and beauty sport, or travel, or political leanings,
• Demographic information, such as gender, age or age range, level of education or likely income range.
• Geolocation information, such as location coordinates tied to a device or wifi identifier.
• Online identifiers (such as cookie or mobile ad IDs), and IP addresses

This type of information may be inferred – for instance, if a household is in a particularly wealthy area, we might infer a particular income range.   

4-Eyes.ai also receives information through this website (and any other website we operate), and through corporate interactions and events.   We describe this information in Section 6.

2. How We Use the Information

4-Eyes.ai uses the Information for a range of purposes, including the following:

As Part of Our Services:

• Data Marketing Services.  Our Services include providing marketing information to our customers, generally regarding which customers or prospective customers are most likely to be interested (or disinterested) in certain offers.   When we provide these Services, consumers may be identified (and their information shared) in various ways, such as by household, email address, or device identifier. Similarly, we help our customers identify and understand their customers better, by providing insights about them.  
• Online Targeting.  We sometimes create defined audience segments (“Audience Segments”) based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with tech professionals, or with an interest in winter travel).  When we do this, we may work with a data partner that  “matches” our Information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels.  You may learn more about how to opt out of this and other online ad targeting in Section 4.
• Email Targeting.  We use the infrastructure and technology of either our Customers or our own service providers to help our Customers send and target (and measure and analyze) their email campaigns.
• Additional Services.  Other Services we may sometimes provide to our customers (or that they may provide to their own customers), which may overlap with or supplement the above, may involve (a) help with targeting and optimizing direct mail, email campaigns, display, social and mobile marketing; (b) measuring how effective marketing campaigns have been, by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases; (c) analyzing and optimizing our customers’ (or their service providers’) proprietary databases; (d) providing “validation” or data “hygiene” services, which is how companies update and/or correct their databases by verifying or removing or correcting old, incorrect or outdated information or (e) providing fraud prevention and identity verification purposes.

To Operate Our Services.  We also use the Information for our own internal purposes – such as to improve, test, update and verify our own database; develop new products;  operate, analyze, improve and secure our Services and our databases and servers.

3. How We Share Information with Third Parties, including Service Providers

4-Eyes.ai may share the Information with customers, marketing services and platforms, as well as service providers that help us to provide the Services we’ve described above (or other services we may add in the future).  This includes sharing in the following ways:

• With Our Customers:  Our customers include (but are not limited to) brands and agencies and various marketing data platforms that help them to market and advertise to their own customers (and prospective customers); our customers also include other data compilers, who work with their own customers. We license the Information in various ways to our customers (and something to partners and resellers, who license the Information to their customer), when we provide our Services. We license the Information in various ways to our customers (and sometimes to partners and resellers, who license the Information to their customer), when we provide our Services. We may sometimes share the Information with those Customers’ service providers too (for instance, a provider that prints or sends mailings or email for a Customer) or license to the Customer for their own fraud prevention and identity verification purposes. In such circumstances, our Customers may include, but are not limited to, global entities engaged in payment transaction processing, other related payment services, and multinational Fintech and AdTech companies.
• With Email Platforms:  We share our Customers’ data (but sometimes our own) with email platforms, for the purpose of targeting, measuring, sending and analyzing email campaigns.
• With Our Partners:  We may also share the Information, including personally identifiable information (such as contact information) and Audience Segments, with business and data partners to help to tailor marketing and advertising campaigns and other communications.  Likewise, we may share the information with those partners for analytical purposes, including to help those parties measure campaign performance, inform future campaigns, or to handle, analyze, or segregate this Information – generally on our or our customers’ behalf, but sometimes to help those parties’ own customers.
• With Our Service Providers:  We share the Information with a variety of service providers in order to operate, protect and advertise our Services and maintain our website(s).  For instance, we may share the Information with hosting providers, tech and customer support providers, marketing and advertising solution vendors, other data providers (such as to enhance or verify our Information), security providers, billing and payment vendors (as to our business to business information), and other companies that help us operate, improve or develop the Services.
• Corporate transfers:  If 4-Eyes.ai, its stock or its significant assets are acquired by or merged into another entity, our information will be transferred to that entity, and may be shared during due diligence in anticipation of any such transaction.

As required by law or to protect any person or entity:  4-Eyes.ai may disclose Information if we believe that such disclosure is necessary to (a) comply in good faith with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of 4-Eyes.ai, our customers, or any other person or entity.

4. Your Marketing and Opt-Out Choices

There are multiple ways that you can opt-out of having the Information used to market to you:

• First, you may contact us directly to have your personal information removed from our database via our website privacy portal located at this Form.  When you do this, please provide your current address, your email address, and any prior home or email addresses you would like “opted out” of our marketing databases.   Or if you prefer, you can contact us directly by Email or mail, at:

Attn:  Privacy Officer

600 Cleveland Street Suite 300

Clearwater, FL 33755, USA

Email: privacy@4-Eyes.ai

Toll Free (800) 579-6218

We will then in most cases remove your personal information from our active marketing databases within 30 business days, from the time we received the opt-out request.  We may in certain cases (but not in most cases) require that you verify any of the information that you submit, such as through a verified email response or another verified response.

• If you would like to opt-out of direct mail advertising in general, we recommend that you visit the DMA Choice website, at dmachoice.thedma.org. The DMA Choice service is run by the Direct Marketing Association and allows you to follow few easy steps to ensure that your marketing preferences are honored. 
• If you wish to opt out of online targeted ads (sometimes referred to as “interest-based” or “personalized” advertising), you can also visit the opt-out portals operated the industry groups the National Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA), and you can learn more about how those opt-outs work on those linked web pages.  Please note that these online opt-outs are cookie-based (unlike 4-Eyes.ai's direct opt-out.  Thus, if you browse the web from multiple browsers or devices, you will need to opt out from each browser and/or device, and for the same reason, if you change browsers or clear your browser cookie cache, you will need to perform this opt-out function again.  Opting-out in this way will not prevent you from seeing all types of online ads; it generally will prevent targeted ads customized to what advertisers think may be most likely to be relevant and of interest to you.
• If you wish to opt out of Hashed Email you can visit the opt-out portal https://optout.networkadvertising.org/optout/email.
• To adjust your advertising preferences in iOS (version 12.4 and earlier), visit Settings > Privacy > Advertising > Limit Ad Tracking or Settings > Privacy > Advertising > Reset advertising ID. For version 14.5 and later, please visit Apple Support here. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads or Settings > Google Services & Preferences > Ads > Opt out of Ads Personalization. Additionally, visit https://youradchoices.com/appchoices to download the AppChoices Tool to control interest-based advertising on apps on your mobile device and https://thenai.org/opt-out/mobile-opt-out for more information and instructions on opting out on mobile device.

If we market to you by email, in our corporate capacity – such as if you are a customer or prospective customer of ours and we send information about our Services — you may “unsubscribe” from our marketing emails through a link placed in your emails.

5. Cookies and Similar Technologies

Cookies and How We Use Them

4-Eyes.ai and its business partners use certain industry-standard technologies, including cookies and similarly functioning technologies, which we describe below. (We and/or our service providers use these technologies on our website, for instance, and our partners may use these technologies in their own marketing services.)

We may work with third parties or service providers to provide or enhance our services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form.   These partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration periods. Those partners may, likewise, collect various types of information about your browser, device, or browsing activities through use of these cookies.

Cookies, in turn, are small data files that contain a string of characters, such as a  unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages.  When you access web pages (such as the website of a marketer), pixel tags may generate a generic notice of the visit and permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed.  Pixel tags are used in combination with cookies to track the activity on a site by a particular device.  When you turn off cookies, pixel tags simply detect a given  website visit.

We or our service providers, and other online marketing platforms that we or they work with, may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see.   Cookies are used in this way to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

Sometimes, we work with companies that link our Audience Segments to cookies (as also described in Section 2), in order to help companies better target (or suppress) advertisements to consumers.   This is one of type of the various categories of advertising that are often referred to as “personalized” or “interest-based” advertising” or “Interest-Based Advertising.”   You can opt out of this type of advertising through the industry opt-out methods described in Section 3, which are cookie-based.

Disabling Cookies

Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our website and other services may be difficult to use or become inoperable.

6. Data Collected Through Our Corporate Website

Information Collected

4-Eyes.ai collects information from users of our website(s) (including any page on which this Privacy Policy is posted), including:

• The domain name and IP address of a user’s web browser, along with a timestamp and other information about a user’s browser or device.
• Information about what content and pages users access, utilize or visit on our website, or how they interact with our content – for instance, if they spent a certain amount of time reviewing a particular blog post or description of particular services.
• Information, including personally identifiable and contact information that you provide, which could include (for instance) survey information, sign-up information (e.g., if you sign up for events or newsletters), requests for information, mailing addresses and email addresses.

How 4-Eyes.ai Uses the Information We Collect Through Our Website

We use the Information we collect through our website(s) to do the following:

• Create and manage your unique user account.
• Provide Services to you.
• Respond to and communicate with you (including regarding news and updates about our services).
• Send you offers and ads for our products and services, when you browse the website(s) or other companies’ websites on the Internet (such as to “retarget” you with information about our services).
• Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you, such as invitations to events and webinars.
• Perform data analysis (including market research).
• We may combine the Information with other information we obtain from third parties, publicly available sources, and any other product or service we provide to further improve the relevance and effectiveness of products, and advertisements offered, including (but not limited to), those provided on or through our services.
• We may use IP addresses to help diagnose problems with our servers and to administer our website(s).  We also may use IP addresses to help identify visitors to our website(s) for the duration of a session and to gather demographic information about our visitors. We may use clickstream data to determine how much time visitors spend on each web page of our website(s), how visitors navigate through the website(s), and how we may tailor our website(s) to better meet the needs of our visitors. We also use this Information for compliance with our legal obligations, policies and procedures, including the enforcement of our Terms and Conditions.
• If we collect Information from “offline” sources – such as if you provide us your business card at a trade show – we will maintain that information and use it for marketing and business purposes, as well.

How 4-Eyes.ai Shares the Information We Collect Through Our Websites

We may sometimes share or otherwise disclose the Information we collect about you, as described in this Privacy Policy or otherwise disclosed to you when you provide us with the information, including as follows:

• We may share the Information with service providers who help us deliver the services you request or we provide.   For instance, we share the Information with tech and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Information), security and data hygiene vendors, payment vendors (as to our business to business information), and other companies that may help us deliver or develop Services.
• We may share the Information to communicate with you and market to you, including through email, direct mail or display media.
• We will disclose your PII (or other Information) if we believe in good faith that we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies in any official investigation and we may disclose any Information to the requesting agency in doing so.
• If we or all or substantially all of our assets are purchased by another company (such as in a merger, consolidation, restructuring, the sale of stock and/or assets, or other corporate change or financing transaction), the Information in our possession will likely be transferred to the successor entity.  We also may share the Information during the course of any due diligence process leading up to any such transaction.

Our website(s) use cookies and similar technologies, both for its internal and operational purposes and to market to you (such as to retarget ads to you when you visit other sites across the Internet).

7. Links

This website may provide links to other websites that 4-Eyes.ai thinks users will find interesting or useful. 4-Eyes.ai is not responsible for the privacy practices of these other sites or companies.

8. Security and Data Integrity

4-Eyes.ai takes steps to help ensure that the data we possess is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information.  While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ efforts that are designed to ensure that this does not occur.

9. Changes to this Privacy Policy

From time to time, we may update this Privacy Policy. Any changes to it will become effective when it is posted to our website, unless we indicate a later effective date. Please check back to learn of any changes to this Privacy Policy

10. Storage of Information in the United States

If you are accessing our website from outside of the United States, your connection likely will be through and to servers located in the United States and all Information you provide will likely be processed and securely maintained in our web servers and internal systems located within the United States.  (We generally store the Information used in our Services in the United States.)   Thus, you should be aware that in accessing this website or otherwise communicating with us, the information we collect or receive from you may be subject to laws with lesser or different privacy standards than those in your own country (such as if you are in a country located in the European Union).

11. CAN SPAM, calOPPA, CASL Acts and Your Choices and Access Rights

The CAN-SPAM Act of 2003

4-Eyes.ai upholds and adheres to The CAN-SPAM Act of 2003 which establishes regulations for commercial email, including what information must be included in an email message, the types of messages that are prohibited, and how to unsubscribe from commercial emails.

The CAN-SPAM Act was passed in response to concerns about the increasing amount of spamming and other deceptive marketing practices. The law establishes requirements for commercial messages, gives recipients the right to have Email Marketers stop emailing them.

CAN-SPAM contains seven requirements that 4-Eyes.ai adheres to in order to avoid unsolicited email spamming.

• Be honest and transparent in your header (including from, to, and routing information)
• Do not be deceptive in your subject lines
• Disclose the email as an advertisement
• Provide your physical postal address in the body
• Give instructions for opting out
• Honor opt-out requests within ten business days
• Ensure processors or third parties comply with CAN-SPAM

CalOPPA

4-Eyes.ai upholds and adheres to CalOPPA and requires that any person or company whose website collects personally identifiable information from Californian consumers must feature a conspicuous Privacy Policy stating exactly what information is collected and with whom it is shared. This includes tracking of online visits for marketing purposes.

The law applies to email marketing because it requires:

• A Privacy Policy, andTransparency about what kinds of personal data your app or website collects. To comply with the law’s requirements, it’s necessary to include a statement within our Privacy Policy that we collect email addresses and whether we share them with third parties or not.

4-Eyes.ai ensures that we provide subscribers with a means of opting out of email marketing campaigns.

CASL

4-Eyes.ai upholds and adheres to CASL, or Canada’s anti-spam legislation, protects consumers and businesses from misusing digital technology, including spam and other electronic threats. It also aims to help companies stay competitive in a global, digital marketplace.

CASL covers “Commercial Electronic Messages” (CEM), which is a bit broader than simply applying to emails. For example, it also covers instant messages, text messages, and social media messages that are related to commercial activities.

CASL, like the GDPR, touches on consent. 4-Eyes.ai adheres to the requirements for implied consent, such as (making a purchase, donation, gift, providing volunteer time or resources, providing an email address, or publishing an email address).

If 4-Eyes.ai do not meet the conditions of implied consent, 4-Eyes.ai obtains express consent from subscribers. This requires either a written agreement or an oral agreement from the subscriber stating that they consent to receive digital communications from our or our client’s business.

If you wish to opt out of email marketing campaigns, please click here.

12. Data Retention

4-Eyes.ai retains the non-personal user data we collect for all of our products and services for purposes of interest-based advertising for up to thirteen (13) months from the date of its collection.

We will also only retain your personal data for as long as we believe it is up to date, i.e. as long as it is associated with a business that is included in our database. We verify our data periodically and if we learn that you are no longer involved with a business that is in our database, we will remove your data from our records.

Customer Data We will retain this information for as long as needed to provide services to any one of our customers or as otherwise authorized, directed, or permissioned by our Customers. In addition, 4-Eyes.ai will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In the event we are processing data for our Customer, we will take Client instruction.

Other Data We will retain this information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with permitted applicable laws and regulation. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).

13. Children’s Privacy

Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@4-Eyes.ai.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see your-california-rights for more information.

14. Your California Privacy Rights

If you are a resident of California, the California Consumer Protection Act (CCPA)/California Privacy Rights Act (CPRA) provides certain rights of disclosure, access and deletion of your Information as described below in the “Addendum for California Residents” at the end of this Privacy Policy.

15. Contact Us

4-Eyes.ai has a designated privacy contact.  If you have questions related to this Privacy Policy, or regarding our products or services, please contact us:

Attn: Privacy Officer

4-Eyes.ai Inc.

600 Cleveland Street, Suite 300 

Clearwater, FL 33755

Email: privacy@4-Eyes.ai

Toll Free (800) 579-6218

We appreciate your comments and questions regarding 4-Eyes.ai's privacy practices.

ADDENDUM FOR CALIFORNIA RESIDENTS CALIFORNIA PRIVACY RIGHTS

NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY ACT (CCPA)/ CALIFORNIA PRIVACY RIGHTS ACT (CPRA)

Pursuant to the California Consumer Privacy Act (“CCPA”), California Privacy Act (“CPRA” and together with the CCPA, “CCPA/CPRA”) and other California privacy laws, we are providing the following information to visitors, users, and other who reside in the State of California (“consumers” or “you). This Addendum supplements the information in the Privacy Policy. However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you, and you should not rely on it.

In the below tables and sections, we describe (as required by the CCPA/CPRA):

1. Our Collection of Personal Information – the types of Personal Information (which the CCPA/CPRA defines broadly) that we collect, the types of sources we collect it from,
2. Our Disclosure and Sale of Personal Information – the types of recipients to whom we disclose or sell Personal Information.
3. Our Business Purposes – our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
4. Your California Privacy Rights and Choices – what rights you have under the CCPA/CPRA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:

1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.

2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION

We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers. The chart below how and with whom we share or disclose personal information, and whether (based on the CCPA/CPRA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.

We also may share any of the personal information we collect as follows:

Sharing for Legal Purposes:  In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public.  We likewise may provide information to other companies (which may include, but are not limited to, global entities engaged in payment transaction processing, other related payment services, and multinational Fintech and AdTech companies) and organizations (including law enforcement) for their own fraud protection and identification verification and spam/malware prevention, and similar purposes.

Sharing In Event of a Corporate Transaction:  We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing With Service Providers:    We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.

Sharing of Aggregate Information:  We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”).  We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

Generally speaking, we collect and share the Personal Information that we collect for the following purposes, as we also have described in our Privacy Policy and/or our website.

Our Purposes for collecting, using and sharing Personal Information

Data marketing services, for example:

• Generally, creating data marketing tools and products for our marketer clients, as more fully described in our Privacy Policy (and on our websites).   This includes our provision of datasets, data “appends” (connecting data across datasets), data “scoring” (providing inferences about potential consumer behavior), data hygiene services (helping customers to evaluate, validate and correct personal information they hold), and security and anti-fraud services (helping customers to identify potentially fraudulent activity).
• Helping our Clients identify and understand their consumers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products.
• Assisting our Clients through our Services to provide their current and prospective customers with better service, improved offerings, and special promotions, for instance, advising on which current or prospective customers are most likely to be interested (or disinterested) in certain offers.

Online targeting, for example:

• Creating or helping to create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with prospective students). When we do this, we work with a data partner that “matches” our or other Information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels.
• Assisting Clients in creating “identity” graphs, to help locate users across various channels, such as based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).

Additional marketing services, for example (which may overlap with “data marketing services” above):

• Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing.
• Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.
• Analyzing and optimizing our Clients’ (or their service providers’) proprietary databases, or helping Clients to identify and mitigate potential fraud.
• Providing “verification” or data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying or

Operating our Services, for example:

• Improving, testing, updating and verifying our own database.
• Developing new products.
• Operating, analyzing, improving, and securing our Services.

Other internal purposes, for example:

For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance.

We sometimes use the information collected from our own website,  from social networks, from other “business to business” interaction (such as at trade shows) or from data compilers for the above, as well as for our own marketing purposes.

4. YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.  (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)

Sometimes, we act only as a “service provider” to our clients (for instance, if they provide information to us for analytics, processing or other data management services), in which case any consumer requests for opt-out, deletion or access to data must be made through that client:  we will forward any such requests to a named client, as feasible, but we recommend making any requests directly to the company you wish to direct the request to.

A. Right to “opt-out” of the sale of your personal information

California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.”

Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in Section II of this Addendum, titled OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION.

B. Right to request access to your personal information

California residents have the right to request that we disclose what categories of your personal information that we collect, use, or sell.  As explained in Section (D) below, you may also request the specific pieces of personal information that we have collected from you.  (We may withhold some personal information where the risks are too great to permit disclosure of the information.)

C. Right to request deletion of your personal information

As explained further in Section (D) below, you may also request that we delete any personal information that we collected from, such as if you have been a customer of ours. (Note that this is different from your right to “opt out” of us selling your personal information, which is described below; also note that we do not generally collect personal information directly from consumers.) However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

D. How to exercise your access, and (if applicable) deletion rights

Access:  California residents may exercise their California privacy rights by sending an email to privacy@4-Eyes.ai.com, submitting their removal request through our form, or by contacting us at Privacy Officer, 600 Cleveland Street, Clearwater FL, 33755. Toll Free (800) 579-6218.

Because it is required by California law (and also, for security purposes), we will verify your identity – in part by requesting certain information from you or by requesting you demonstrate possession of a particular identification method (such as an email account) — when you request to exercise your California privacy rights.  For instance, if you request categories or specific pieces of personal information we have received about you, you may need to confirm your possession of such an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.

Once we have verified your identity, we will respond to your request as appropriate:

• Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories.
• Where you have requested specific pieces of personal information, we will provide the information you have requested, to the extent required under the CCPA/CPRA and provided we do not believe there is an overriding privacy or security concern to doing so.

Deletion:  Where you have requested that we delete personal information that we have collected from you, we will seek to confirm whether your request is for an “opt out” or a “deletion”: because “opt out” or “do not sell” rights enable us to maintain your information for “suppression” purposes – i.e., to prevent us from selling information about you in the future (which is what many consumers requesting “deletion” actually desire to occur), we try to explain this in order to ensure we are meeting consumers’ preferences.  (In addition, “deletion” rights only apply to information that we have collected “from” consumers – which does not apply to much of the information in our databases.)

E. Right to non-discrimination

We do not deny to you, charge different prices for, or provide a different level of quality of goods or services to you, if you choose to exercise these rights.

F. Information about persons under the age of 16

We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).

G. Authorized agents

You may also designate an agent to make requests to exercise your rights under CCPA/CPRA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a legally sufficient power of attorney. We likewise may require that you verify your own identity, depending on the type of request you make.

H. NOTICE TO EMPLOYEES/APPLICANTS

As you have self-reported that you are a resident of California, we are serving notice that the Company collects and retains certain information about you.

California’s Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”) provides California employees and applicants with certain rights:

• Knowledge of information collected;
• Deletion of information collected;
• Opt-out of information collected;
• Opt-in of information collected;
• Correction of information collected;
• Go to court;
• Limit use of information collected;
• Not to be discriminated or retaliated against for exercising rights under the law.

Where We Get Your Information From. The Company collects information about you from the following sources: 1) you; 2) prior employers, references, recruiters, job-related social media platforms; 3) third-party sources of demographic information; 4) third-party companies, such as background check companies; and 5) claim administrators and investigators. Depending on the Company’s interactions with you, we may or may not collect all of the information identified about you.

The Personal and Sensitive Personal Information That We Are Collecting. We are collecting the following information:

• Identifiers, such as name, government-issued identifier (e.g., Social Security number), and unique identifiers (e.g., employee ID);
• Personal information, such as legal name, signature, SSN, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, passport number, federal identification authorizing work in the United States, access and/or passcodes, insurance policy number, education, employment, employment history, bank account number, other financial information, medical information, or health insurance information;
• Characteristics of protected classifications under California or federal law, such as age, marital status, gender, sex, race, color, disability, citizenship, primary language, immigration status, military/veteran status, disability, request for leave, and medical conditions;
• Commercial information, such as transaction information and purchase history (e.g., in connection with travel or other reimbursements);
• Internet or network activity information, such as browsing history and interactions with our online systems and websites and any personal information that you provide while accessing the Company’s computer systems, such as personal credit card information and passwords;
• Geolocation data, such as device location from usage of the Company’s devices;
• Biometric information related to access to the Company’s secured access points;
• Audio, electronic, visual, and similar information;
• Professional or employment-related information, such as work history and prior employer;
• Non-public education information; and
• Inferences drawn from any of the Personal and Sensitive Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

How Your Personal and Sensitive Personal Information is Used. We may use Personal and Sensitive Personal Information:

• To operate, manage, and maintain our business;
• For hiring, retention, and employment purposes;
• To otherwise accomplish our business purposes and objectives, including, for example:
  • Emergency services;
  • Conducting research, analytics, and data analysis;
  • Maintaining our facilities and infrastructure;
  • Quality and safety assurance measures;
  • Conducting risk and security controls and monitoring;
  • Protecting confidential and trade secret information;
  • Detecting and preventing fraud;
  • Performing identity verification;
  • Performing accounting, audit, and other internal functions, such as internal investigations;
  • Complying with the law, legal process, and internal policies;
• Maintaining records;
• Claims processing;
• Responding to legal requests for information and subpoenas; and
• Exercising and defending legal claims.
• Any other purposes authorized by the California Privacy Protection Agency, California or Federal law.

We may or may not have used Personal and Sensitive Personal Information about you for each of the above purposes.

Sharing of Personal Information. We only share your information with the following current third-party entities:

• US payroll provider (ADP)
• Health & welfare benefit registration platform (Employee Navigator)
• Health & welfare benefits insurance broker (IMA)
• Employee benefit carriers (UnitedHealthcare, Optum, Unum, Advanced Benefit Strategies)
• 401(k) plan recordkeeper (Principal)
• 401(k) plan third party administrator (Prime Pensions, Inc.)
• 401(k) plan advisor (Pallas Capital Advisors)
• Applicant Tracking System (Greenhouse)
• Corporate Learning Management System (Cornerstone)
• Legacy Performance Review System (Darwinbox)
• Employee Travel & Expense Platform (Emburse Certify)
• Corporate Intranet (Jostle)
• Background Screening Services (Good Hire/Checkr, HireRight)
• Email Licensing Platform (Microsoft)
• Telephone Extension Service (OneBox)
• Lenders for Employment Verifications (Employee Selected and Authorized)

The Company may also use other third-party companies to operate, manage and maintain our business.

Selling of Personal Information. The Company DOES NOT sell your personal information.

Data Retention. The Company retains the information it receives about you for a period of seven (7) years, unless a shorter or longer period is required by California or Federal law.

For Inquiries and/or to Submit Requests for Information, Deletion or Correction.

Please contact privacy@4-Eyes.ai 

Or write to:

Privacy Officer | 4-Eyes.ai Inc.

600 Cleveland Street, Suite 300

Clearwater, FL 33755

Toll Free (800) 579-6218

For more information about Data that the Company collects, stores and transfers, please refer to the Company’s Privacy Policy.

4-Eyes.ai respects your privacy and strives to uphold all applicable privacy laws in our business relationship with you.

Here is copy for the opt out form:

The information provided on this form will be used only for the purpose of removing information about you from 4-Eyes.ai’s marketing data products.

Also, as part of our commitment to upholding Global Data Protection Legislations we want to provide you with clear and concise information with what we do with your personal data. 

Your data may be used for Marketing Services, which may include targeted advertising and measurement by Third Parties. 

Please review the 4-Eyes.ai Privacy Policy https://4-eyes.ai/privacy-policy/ for more information about how 4-Eyes.ai collects, uses, discloses, and deletes consumer personal information.

If you have any questions not covered by our privacy policy, please contact us at privacy@4-Eyes.ai. You may also submit this form and advise us of your privacy choices and we will take action and respond to your request as part of our commitment to upholding your Privacy Rights.