This Supplemental State-Specific Privacy Information Notice (the “Supplemental Notice”) applies to the use of the analytics and reporting Foureyes® tool (the “Tool”), provided by Foureyes, LLC, a Delaware limited liability company (“Foureyes”). When used in this Supplemental Notice, “we,” “us,” and “our” refers to Foureyes.
We are required by law to provide residents of California, Colorado, Connecticut, and Virginia with certain additional information about their privacy rights under the California Consumer Privacy Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Virginia Consumer Data Protection Act, respectively. This Supplemental Notice is intended only for residents of the aforementioned states.
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 https://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 | Categories of Sources: - Directly from you |
| 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 | Categories of Sources: - Directly from you |
| 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 | Categories of Sources: - Directly from you |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes | Categories of Sources: - Directly from you |
| 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 | Categories of Sources: None |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Yes | Categories of Sources: - Directly from you |
| 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. | Categories of Sources: None |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | Yes | Categories of Sources: - Directly from you |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | Yes | Categories of Sources: - Directly from you |
| 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 | Categories of Sources: None |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | No | Categories of Sources: None |
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 for the business or commercial purposes identified below:
- OEMs: Foureyes® partners with various automotive manufacturers (“OEMs”) as a part of their respective certified marketing programs and their affiliates.
- Digital experience partners that manage the OEM’s digital marketing, traffic generation, lead optimization, online-offline retail integration, customer retention, and loyalty strategies.
- Business partners with whom it conducts business regarding the Tool and/or the information collected by the Tool and/or associated with your user profile.
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' primary privacy policy located at https://foureyes.io.
Sharing of Personal Information
”Share,” “shared,” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.
In the preceding 12 months, we have shared 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.
This sharing has been to the categories of third parties for the business or commercial purposes identified above with respect to our sales of personal information.
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. 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 selling, or sharing that personal information.
- The categories of third parties with whom we disclose that personal information.
- The specific pieces of personal information we collected about you.
- If we sold, shared, or disclosed your personal information for a business purpose, three separate lists disclosing:
- the categories of personal information that we collected about you;
- sales or sharing (if any), identifying the personal information categories that each category of third parties to whom the personal information was sold or shared; 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.
- Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
- 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 and compatible with the context in which the consumer provided the information.
- Comply with a legal obligation.
In the absence of a verifiable consumer request from you, we will retain your personal information for as long as we think is necessary to fulfill the purposes for which it was collected, and we reserve the right to retain it to the full extent permitted by law before automatically deleting (and directing our service providers to delete) it. Retention periods can vary based on the category of personal information, and we use criteria which include the following to determine the relevant retention period: contract requirements, operational needs, legally mandated retention periods, pending and potential litigation, historical archiving, and intellectual property or ownership rights.
Further, you have the right to request a business that maintains inaccurate personal information about you to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. Once we receive and confirm your verifiable consumer request, and taking into account the foregoing, we will use commercially reasonable efforts to correct the inaccurate personal information as directed by you.
You may exercise the rights discussed herein by submitting a verifiable consumer request to us by either:
- Visiting us at foureyes.io/data-request
- Calling us toll-free at (971) 200-5909
- Emailing us at [email protected]
Only you, or a person legally entitled to submit a request 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.
We reserve the right to refuse to provide or to charge for data requests to the extent permitted by applicable law. Each 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 that person.
- 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. Unless otherwise requested, any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. You may request that we disclose certain information to you about our collection and use of your personal information beyond the past 12 months. We, however, may decline to provide you that information if doing so would require a disproportionate effort on our part. 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.
If required by the applicable laws of your state, we will provide you the opportunity to appeal certain decisions made by us related to your rights. For each request you submit, we will inform you of the action we have taken in response to your request. If your state requires it, you will be provided the opportunity to appeal our decision by following the instructions in our response.
We do not process any personal data of minor children. We do not process sensitive data or sensitive personal information, as defined under applicable state privacy laws, without consent, or use or disclose sensitive personal information for purposes other than those specified in Cal. Civ. Code § 1798.121.
Personal Information Sales and Sharing Opt-Out
You also have the right to direct us to not sell or share your personal information at any time, or to opt out of the processing of your personal information for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects which concern you (the “right to opt-out”). We do not collect, use, sell, or share the personal information of consumers we know to be less than 16 years of age.
In addition to the contact options provided above, to exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting: Do Not Sell or Share My Personal Information
Once you request to opt-out of the use of your information, we will wait at least 12 months before asking you to reauthorize personal information sales or sharing.
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 rights. Unless permitted by applicable law, 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.
· Retaliate against an employee, applicant for employment, or independent contractor for exercising their rights.
However, we may offer you certain financial incentives permitted by the applicable law that can result in different prices, rates, or quality levels. Any 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. In addition to the contact options provided above, you may opt-out of all information sharing under this law at the following link:
Do Not Sell or Share My Personal Information
Last Updated: March 31, 2024
