Privacy Policy

Supplemental California Privacy Information Notice

This Supplemental California Privacy Information Notice (the “Supplemental Notice”) applies to the use of the analytics and reporting Foureyes® tool (the “Tool”), provided by Adpearance, Inc., an Oregon corporation (“Adpearance”). When used in this Supplemental Notice, “we,” “us,” and “our” may refer to us, Foureyes, and/or Adpearance.

We are required by law to provide California residents with certain additional information about their privacy rights under the California Consumer Privacy Act (“CCPA”). This Supplemental California Privacy Information Notice (the “Supplemental Notice”) is intended only for California residents.

Information Collected

Using the Tool, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device, or household (“personal information”). The purpose for the collection is set forth in our primary privacy policy for the Tool located at foureyes.io. We do not collect any additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. In particular, we have collected the following categories of personal information using the Tool within the last 12 months:

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

Yes

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Yes

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Yes

G. Geolocation data.

Physical location or movements.

We do not track physical location or movements except to the extent it is possible through IP address tracking.

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

Yes

I. Professional or employment-related information.

Current or past job history or performance evaluations.

Yes

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

No

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, we have disclosed the following categories (as set forth above) of personal information for the business purposes of data storage, access, and analysis, call tracking, text messaging, e-mail marketing, and error logging:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category C: Protected classification characteristics under California or federal law.
  • Category D: Commercial information.
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data as stated above.
  • Category H: Sensory data.
  • Category I: Professional or employment-related information.

These disclosures have been exclusively to service providers that help to provide the services provided by the Tool.

Sales of Personal Information

In the preceding 12 months, we have sold the following categories (as set forth above) of personal information:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category C: Protected classification characteristics under California or federal law.
  • Category D: Commercial information.
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data as stated above.
  • Category H: Sensory data.
  • Category I: Professional or employment-related information.

These sales and/or disclosures have been to the following category of third parties:

  • OEMs: Foureyes partners with various automotive manufacturers (“OEMs”) as a part of their respective Certified marketing programs.

To the extent Foureyes further sells personal information collected with the Tool, such sales and your rights with respect to such sales are disclosed in Foureyes’s primary privacy policy located at foureyes.io.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting [or selling] that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales (if any), identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Likewise, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech rights, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

California residents can exercise the rights discussed above by submitting a verifiable consumer request to us at either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We ordinarily respond to a verifiable consumer request within 45 days. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. As necessary, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out

As long as you are 16 years of age or older, you also have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not collect, use, or sell the personal information of consumers we know to be less than 16 years of age.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting:

Do Not Sell My Personal Information

Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sales.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Discrimination Protections

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. However, we do not currently provide any financial incentives.

California’s “Shine The Light” Disclosure

California’s “Shine the Light” law (Civil Code Section § 1798.83) governs our disclosure of California residents’ personal information to third parties for the third-parties’ direct marketing purposes. You may opt-out of all information sharing under this law at the following link:

Do Not Sell My Personal Information