Privacy Statement and Notice of Privacy Practices
Effective Date: July 1st, 2019 Scope
Contact and Electronic Communications Opt Out
Technical Description and Overview of the Product and Service
Smart Eye Technology was founded in January 2018 by Dexter Caffey. Mr. Caffey, while on a business trip to Israel speaking to cyber security professionals, noticed he could see every application on smart phones being used by participants around the room. Based upon this experience, Mr. Caffey decided to launch the Company. In a digitally connected world, securing data and sensitive information has become an increasing challenge.
Instances of “digital screen snooping,” meaning the act of unauthorized individuals observing the screens and documents of an unsuspecting user, are an increasingly common problem for individuals. Smart Eye’s technology is designed to ensure that the convenience offered by increasing accessibility of electronic documents is not threatened by the attention of unauthorized eyeballs.
Smart Eye Technology’s mobile application is designed to help secure and manage your data across multiple devices from any location and to securely enable sharing with trusted partners through reliance on biometric access and authentication. Smart Eye Technology’s continuous authentication system uses a combination of iris recognition, facial identification, and fingerprint recognition to provide greater security by immediately alerting and shutting off the document in the event an unauthorized user looks at the document (“Product”).
Smart Eye Technology’s cloud-based technology service is offered through the mobile application which provides you, as the end user, with a highly accurate, automated method of biometric identification to ensure secure access to business-confidential information is accessible only to authorized end users (“Service”) with whom you choose to share documents.
Information We Collect From You
We collect two types of information from you when you visit our Sites, register to download, and use our Product and Service: (1) “personally identifiable information” (as defined below) and (2) non-personally identifiable information (as defined below).
Personal Identifiable Information (“PII”)
Personally identifiable information includes, but is not limited to, your name, e-mail address, and phone number.
Use of Biometric Identifiers and Biometric Information Disclaimer
Generally, we use your PII, including your Biometric Information, to enable your use of the Product and Service, administer your inquires, and help secure and manage access to the confidential documents you may wish to share with third parties utilizing the Product and Service.
Acceptance and Consent Process for the Collection of Biometric Identifiers
During the mobile application download and setup process, immediately after you input your name and create a username and prior to the collection of any of your Biometric Identifiers or Biometric Information. you will be directed to electronically sign and acknowledge a notice detailing that you: (1) acknowledge and consent to your Biometric Identifiers and Biometric Information being collected by Smart Eye; (2) acknowledgment of the purpose for which your Biometric Identifiers and Biometric Information are being collected; and (3) review and acknowledge the notice regarding the length of time for which Smart Eye will retain your Biometric Identifiers and Biometric Information. The requirements set forth in this section are mandatory and, if there is no acknowledgement, the setup process will terminate.
Non-Personally Identifiable Information (“NPII”)
Non-Personally Identifiable Information can be technical information or it can be demographic information, such as your age, gender, or interests. NPII may also mean aggregated, nonidentifiable, or anonymized information. NPII does not identify you personally. If you provide us with non-personally identifiable information, we may use it for the purposes described in this statement or where it is collected, or any other legal purpose.
Here are some examples of the ways in which we may collect and store your NPII through our Services, and how we use such information:
- Log Information. When you use our Service or view content provided by the Company, we automatically collect and store certain information in our server logs. This type of information includes: details of how you used our Service; IP address information (described below); web pages which have been viewed by a visitor; data and time; domain type; device event information such as crashes; system activity; hardware; settings; browser type or version; browser language; the date and time of your request; and referral URL.
- Internet Protocol (IP) Address. Your “IP address” is a number that lets computers attached to the Internet know where to send you data, such as the screens and pages of our Services that you view. We use this information to deliver our screens and pages to you upon request, to tailor our services to the interests of you and our other visitors, and to measure traffic to and within our services.
- Demographic Information. “Demographic information” may be your gender, age, zip code, and interests. We may collect such information about you through our Service and use it to provide you with personalized Service and to analyze trends to ensure that our services and the information on them are targeted to meet your needs. Please note that we also consider aggregated information, which is not personally identifiable, to be nonpersonally identifiable information.
- Mobile Device Information: Information that identifies your mobile device, such as: Electronic Serial Number (“ESN”) or International Mobile Equipment Identity (“IMEI”) data; device serial number; and media access control (“MAC”) address.
Sharing and Disclosure of PII and NPII
Personally Identifiable Information. Primarily, we may share or disclose your PII, excluding Biometric Identifiers or Biometric Information, in the following instances:
- To fulfill a service to you. For example, if you e-mail us a question, we may use your e-mail address to process your request and respond to your question.
- Where you have appropriately opted-in to the sharing of your PII with third parties, to offer you products from our affiliates, strategic partners, agents, or from third-party marketers and other unaffiliated parties that we believe may be of interest to you, or to assist such parties for research, administrative, and/or business purposes. These parties may contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes.
- To comply with law, or in the good faith belief that such action is necessary to conform to the requirements of law, or comply with legal process served on us, and to protect and defend our rights or property, including our rights and property and our services, or act in urgent circumstances to protect the personal safety of you and our other visitors.
- To third parties as part of a corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
- To track and analyze NPII, i.e. non-identifying, aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
- To protect against fraud and potential fraud.
Non-personally Identifiable Information. We may share and disclose your NPII for the purposes described in this statement or where it is collected, or any other legal purpose, including, when and where applicable, sharing and disclosing non-personally identifiable information combined with PII.
General Legal Disclosure. We may disclose information about you and your use of the Service if we believe that such disclosure is permissible under applicable law and reasonably necessary to:
(i) Comply with the law and/or legal process where a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding);
(ii) Protect or defend our rights and/or property or the rights and property of others;
(iv) Respond to claims that the content(s) of a communication violates the rights of another.
Also, circumstances may arise where, for business reasons, we may decide to reorganize, or divest all or part of our business through sale, assignment, merger or acquisition, or we may acquire a new business. In these circumstances, PII may be shared with the actual or prospective
Legal Disclosures for the Use and Disclosure of Biometric Identifiers in IL, TX and WA
Access and Ability to Correct Your Information
Cookies and Other Technology
We use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We receive and stores information about how you use our website when you visit the Site. For example, we receive information that your browser or device sends to our servers whenever you visit the Sites. Your browser or device may tell us your internet protocol (IP) address used to connect your computer to the Internet, computer and connection information such as browser type, version, language and time zone setting, browser plug-in types, operating system, and type of device you are using. When you visit the Sites, your browser may also tell us information such as the actions you take on our Site, the page that led you to our Site and, if applicable, the search terms you typed into a search engine that led you to our Site.
You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the Sites. If you do not accept cookies, however, you may not be able to use all portions of the Sites or all functionality of the Services.
Third-Party Links and Websites
Children Under 13
Social Media and Community Platforms
areas. We do not control who reads postings on our Sites, or how they may use or disclose such information. If you choose to voluntarily disclose information on public portions of our Sites, that information will be publicly available and can be collected and used by others. For example, if you post your e-mail address, you may receive unsolicited messages. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION ABOUT YOURSELF OR OTHERS IN PUBLIC AREAS OF OUR SERVICES. WE ARE NOT RESPONSIBLE FOR THE USE OR DISCLOSURE OF SUCH INFORMATION
Advertisers and Marketing
We may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements about our Product and Service. Such third parties may gather information about your visit to our Sites, monitor your access to or market products or services to you, monitor the ads you view, click on, or interact with, when they were delivered, and the screens and pages that they are on. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
To learn more about these practices, as well as your choices regarding the practices of these third-party advertising companies, you may wish to visit http://www.networkadvertising.org/optout_noNPIIi.asp and/or http://www.aboutads.info/choices/#completed. Both the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”) websites provide information regarding their respective members practices and your choices regarding having your information used by these companies, including the opt out procedures. Opting out of one or more NAI or DAA members only means that those NAI or DAA members no longer will be allowed under their own rules to deliver advertisements to you based on your visits to this site and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI or DAA opt out may not, or may no longer, be effective. We are not responsible for effectiveness of or compliance with any third parties’ opt out options or programs.
How We Protect Your Information
No data transmissions over the Internet are completely secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us or others over the Internet. You transmit such information at your own risk. Once we receive your transmission, we make reasonable efforts to ensure the security of our systems. We use encryption to protect your information from unauthorized access, disclosure, alteration, or destruction. However, this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of our systems or our secure servers.
California Residents’ Rights
(As provided by California Civil Code Section 1798.100)
You have certain rights under the California Consumer Privacy Act (“CCPA”) of 2018. Under the CCPA you have the right to disclosure of all of the categories and specific pieces of PII we have collected from you. You have the right to request that we delete any PII we have collected from you. You also have the right upon a verifiable request from you access to personal information and to obtain the information free of charge to the extent technically feasible. For more information on your rights under the CPPA please contact us by e-mail.
(As provided by California Civil Code Section 1798.83)
A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California Customer” or “Customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.
Please note that whenever you opt-in to receive future communications from a third party, your information will be subject to the third-party’s privacy policies and practices. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as we have no control over how third parties use information. You should always review the privacy policies and practices of any party that collects your information to determine how that entity will handle your information. California Customers may request further information about our compliance with this law by e-mailing email@example.com___. Please note that we are only required to respond to one request per Customer each year, and we are not required to respond to requests made by means other than through this e-mail address.
California Do Not Track Notice