Last Modified Date: January 11, 2020
Privacy No;ce
Scope
PLEASE READ THIS PRIVACY NOTICE CAREFULLY.
This Privacy No=ce (“Privacy No;ce”) details how the Smart Eye Technology (“we” “us” “Smart Eye” or
the “Company”) will collect, use, disclose and protect personal informa=on (“Personal Informa;on”)
obtained from users (“End Users”) of our technology solu=on (the “Solu;on”). Further, it describes the
rights that you have with respect to such informa=on.
IMPORTANT: At this =me, Smart Eye offers its Solu=on to End Users in the United States, Canada, South
Africa, India, Israel, and Australia.
Descrip;on of Our Solu;on
Smart Eye’s Solu=on is a security technology designed to protect devices and documents from
unauthorized viewing and access by authen=ca=ng authorized End User’s through biometric analysis.
The Solu=on can be u=lized through our mobile applica=on or through a web applica=on. Individual
consumers can establish a Smart Eye account and use the Solu=on in a personal context to protect
confiden=al informa=on (“Personal Use”). The Solu=on is also available for deployment at an enterprise
level by corporate en==es to protect confiden=al informa=on (“Enterprise Use”).
When the Solu=on is deployed for Enterprise Use, Smart Eye collects End User Personal Informa=on as a
service provider to our commercial customers (“Enterprise Customers”) and processes such Personal
Informa=on only as authorized by our contracts with those Enterprise Customers. Enterprise Customers
may opt to deploy and store the Personal Informa=on in their own technology infrastructure, in which
case Smart Eye does not receive the Personal Informa=on at all. In those cases, the Enterprise
Customer’s privacy policy will govern the processing of Personal Informa=on.
What Is Personal Informa;on
Personal Informa=on is defined differently by different laws and is some=mes referred to as “personally
iden=fiable informa=on” or “personal data”. Generally speaking, it is a category of informa=on that can
be used to iden=fy a person or a household or that can be reasonably associated with a person or
household. The specific data that qualify as Personal Informa=on vary depending on the state and
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country in which you reside. The following categories are examples of Personal Informa=on in many
(though not necessarily all) jurisdic=ons:
Smart Eye’s Collec;on and Use of Personal Informa;on
The Smart Eye Solu=on requires an End User to submit certain Personal Informa=on when an account is
established and when the Solu=on is used. When a Smart Eye account is established for Personal Use,
Smart Eye determines the means by and purposes for which the Personal Informa=on is processed.
Listed below are the sources from which the Company obtains Personal Informa=on, the categories of
Personal Informa=on collected from each and the purposes for such collec=on.
Sample Categories of Personal Informa;on and Data Elements
Personal Iden;fier: Name, alias, postal address, unique personal iden=fier, online iden=fier, internet
protocol address, email address, account name, social security number, driver’s license number, and
passport number
Biometric iden;fiers: Re=na or iris scans, fingerprints, voiceprints, scans of hand or face geometry
Commercial Informa;on: Records of personal property, products or services purchased, obtained, or
considered, or other purchasing or consumer histories or tendencies
Internet or other electronic network ac;vity informa;on: Browsing history, search history, and
informa=on regarding a consumer’s interac=on with an internet website, applica=on, or adver=sement
Geoloca;on informa;on: To disable the collec=on of precise loca=on informa=on from your mobile
device through our mobile apps, you can access your mobile device se\ngs and choose to limit that
collec=on.
Source of Personal
Informa;on
Category of Personal
Informa;on Collected
Purpose for Collec;on
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The End User
Smart Eye collects the following
personal iden;fiers from End
Users when they register to use
the Solu=on and during each
transac=on:
First and last name
Phone number
Email address
IP address
(a) To establish and maintain your
account;
(b) To fulfil your requests when
using the Solu=on;
(c) To respond to inquiries and
requests you have;
(d) To request feedback regarding
your experience with the
Solu=on;
(e) To improve the opera=on of our
Solu=on;
(f) To detect, prevent, and
inves=gate ac=vi=es that may
violate our policies, pose safety
issues or be fraudulent or illegal,
and;
(g) For security purposes
The End User
Biometric Iden;fiers:
Facial geometry: Fa cia l
geometry is captured to operate
the Solu=on, the primary
purpose of which is to protect
confiden=al informa=on an End
User sends or receives. Facial
geometry is one method by
which the Solu=on authen=cates
the intended recipient(s).
Fingerprint: When an End User
accesses the Solu=on on a device
that enables fingerprint capture,
that fingerprint can be used by
the Solu= o n t o p r o t e c t
confi den= al informa= on
transmi^ed.
Fingerprints are not received or
stored by Smart Eye. Rather, it
remains localized to the End
User’s mobile device.
Voiceprint: An End User has an
op=on to record his/her/their
voice to protect confiden=al
informa=on from unauthorized
access.
(a) To establish and maintain your
account;
(b) To fulfil your requests when
using the Solu=on;
(c) To improve the opera=on of our
Solu=on;
(d) To detect, prevent, and
inves=gate ac=vi=es that may
violate our policies, pose safety
issues or be fraudulent or illegal,
and;
(e) For security purposes
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The End User’s Device
Internet or other electronic
network ac;vity informa;on:
When an End User interacts with
the Solu=on, Smart Eye collect
electronic network ac=vity
informa= on and device
informa=on.
We also collect informa=on
regarding your use of the
Solu=ons such as:
▪
Date Solu=on first opened
▪
Date Solu=on last opened
▪
Time spent per usage
▪
Cumula=ve =me spent
across all usage
▪
Frequency of usage
▪
Conversion from trial to paid
▪
Which biometrics are set up
and when
▪
Frequency of changes to
biometrics a`er set up
▪
Frequency of changing
default security se\ngs
▪
Solu=on features visited/
bu^ons clicked/ac=ons taken
and frequency of each
Unique device iden;fica;on
numbers
Opera;ng system and version
Performance data
(a) To establish and maintain your
account;
(b) To fulfil your requests when
using the Solu=on;
(c) To improve the opera=on of our
Solu=on;
(d) To detect, prevent, and
inves=gate ac=vi=es that may
violate our policies, pose safety
issues or be fraudulent or illegal,
and;
(e) For security purposes
From the Enterprise
Customer
Employment Informa;on
If you are using the Solu=on as an
employee of an Enterprise Customer
who accesses the Solu=on via Smart
Eye’s cloud infrastructure, Smart Eye
will be aware of your status as an
employee of the Enterprise
Customer.
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Collec;on of Biometric Iden;fiers
s, Smart Eye’s Solu=on requires Biometric Iden=fiers. Specifically, Smart Eye collects scans of End User
facial geometry. In addi=on, we enable use of fingerprints and voiceprints although that informa=on is
not transmi^ed to Smart’s Eye’s infrastructure. Smart Eye collects biometric iden=fiers only a`er
receiving the informed consent of the End User from whom the informa=on is obtained.
When an End User establishes an account, and prior to the collec=on of any biometric iden=fier, an End
User is directed to electronically sign a no=ce sta=ng that the End User: (1) acknowledges and consents
to his/her/their biometric iden=fier being collected by Smart Eye; (2) acknowledges the purpose for
which his/her/their biometric iden=fier is collected; and (3) reviews and acknowledges the no=ce
regarding the length of =me for which Smart Eye retains biometric iden=fiers. If the End User does not
agree to the acknowledgement, the account setup process will terminate.
Biometric Informa;on Policy
We will protect, store and transmit biometric iden=fiers in accordance with applicable laws and will use
such informa=on solely for the purposes outlined herein. Biometric iden=fiers are encrypted both in
transit and at rest. We will not sell, lease, trade, or otherwise profit from the biometric iden=fiers we
collect, but we receive payment for the use of our Solu=on, which u=lizes such biometric informa=on. In
addi=on, we will not disclose or disseminate any biometric iden=fiers to anyone other than our third
party service providers (e.g., cloud services provider) unless:
a. the End User first consents in wri=ng to such disclosure or dissemina=on;
b. Disclosure is required by federal, state or local municipal laws; or
c. Disclosure is required pursuant to a valid order, warrant or subpoena issued by a
court of competent jurisdic=on.
When we collect biometric iden=fiers from End Users for Personal Use, such informa=on is retained un=l
the End User affirma=vely deletes his/her/their Smart Eye profile. End Users have the ability to delete
their biometric iden=fiers from Smart Eye’s infrastructure via a “delete profile” func=on. Once that
func=on is selected, all of that End User’s biometric informa=on is automa=cally and permanently
destroyed.
If an End User uses our Solu=on as an employee or contractor of an Enterprise Customer, that End User
must contact the organiza=on with which their use is associated to determine how the biometric
iden=fiers are managed.
For residents of Illinois, Texas and Washington: The Company does not collect biometric iden=fiers for
commercial purposes. We collect biometric iden=fiers only for security purposes. The Company
maintains a wri^en policy that establishes the period of =me for which the Company will retain
biometric iden=fiers and the guidelines we use for storing, protec=ng, transmi\ng and permanently
destroying biometric iden=fiers. Please review the Biometric Informa=on Policy, which can be accessed
HERE, for more informa=on.
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Smart Eye’s Disclosure and Sale of Personal Informa;on
Smart Eye does not “sell” Personal Informa=on in the ordinary meaning of the word. Rather, Smart Eye
licenses a Solu=on that is used for authen=ca=on and security purposes by End Users. That Solu=on
requires the collec=on and use of Personal Informa=on in order to func=on. When an End User ini=ates
a transac=on via the Solu=on, certain informa=on will be electronically communicated to the recipient
designated by the End User. The personal informa=on shared will include the name and phone number
of the End User who ini=ated the transac=on. No other Personal Informa=on is shared.
Smart Eye may disclose Personal Informa=on as necessary or appropriate in connec=on with any of the
purposes for which we use Personal Informa=on.
As referenced above, Smart Eye uses a limited number of third-party service providers and partners to
assist us in making the Solu=on available. Those third par=es include:
Purpose for Disclosure
To Whom and Further Detail
For our business or commercial
purposes
We may use third-party service providers, agents, and independent
contractors to help us maintain our Solu=on and assist us with other
services (including, but not limited to, order processing and
fulfillment, providing customer service, maintaining and analyzing
data, and sending customer communica=ons on our behalf).
For legal purposes
For instance, (i) to inves=gate, prevent or take ac=on regarding
actual or suspected illegal ac=vi=es or fraud, situa=ons involving
poten=al threats to the physical safety of any person, or viola=ons of
our terms of use; (ii) to respond to or defend against subpoenas,
court orders, or other legal process; (iii) to establish or exercise our
legal rights; or (iv) to otherwise comply with applicable law.
A s p a r t o f a c o r p o r a t e
transac=on
Smart Eye may acquire other businesses, and other businesses may
acquire us. If that occurs, the informa=on we collect would likely be
one of the assets examined or transferred as part of the transac=on.
Smart Eye will not permit another business to examine the
informa=on we have collected without a confiden=ality agreement.
We will not transfer the informa=on we have collected in this
acquisi=on context unless the recipient agrees to provide privacy
protec=ons equal to or exceeding those established by this Privacy
No=ce.
Name
Descrip;on of Sub-processing Ac;vi;es
Adobe
To enable the End User to open an Adobe account for document
viewing
Third Party Cloud Provider
Cloud hos=ng services
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Smart Eye does not share Personal Informa;on with third par;es for marke;ng purposes.
Each third party with whom we share Personal Informa=on is responsible for maintaining its own privacy
no=ce and prac=ces related to the use and protec=on of End User Personal Informa=on. Smart Eye
requires third party service providers with whom we share End User Personal Informa=on to process
Personal Informa=on only as allowed in our contract with such third party service provider. We ensure
that any third party service providers with whom we share Personal Informa=on are subject to privacy
and security obliga=ons consistent with this Privacy No=ce and applicable laws.
Pendo
User ac=vity tracking and analy=cs
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If You Are a Nevada Resident
Last Modified Date: January 11, 2020
In accordance with Nevada law, our Privacy No=ce iden=fies for you the categories of “covered
informa=on” that we collect through our Solu=on and the categories of third par=es with whom we may
share such informa=on.
Smart Eye does not sell “covered informa=on” as that term is defined by Nevada law. In addi=on, Smart
Eye does not enable third par=es to collect “covered informa=on” about End User’s ac=vi=es over =me
when using our Solu=on.
How Long We Retain and How We Protect Your Informa;on
How long we retain personal informa;on.
Smart Eye retains End User Personal Informa=on un=l such =me as the End User expressly requests
dele=on of his/her/their profile via the func=onality provided in the Solu=on. When an End User
“deletes” his/her/their profile, Smart Eye will delete such End User’s Personal Informa=on from our
system. An End Users may also contact us and request that his/her/their Personal Informa=on be
deleted. Once deleted, an End User cannot re-ac=vate the deleted account; a new account must be
established in order to use the Solu=on.
How we protect personal informa;on
Smart Eye’s Solution is built with strong security features that continuously protect your Personal
Information. We work hard to protect you and Smart Eye from unauthorized access, alteration,
disclosure, or destruction of Personal Information we hold, including:
•
We use encryption to keep your Personal Information private while in transit and at rest
•
We offer a range of security features to help you protect your account
•
We review our information collection, storage, and processing practices, including physical
security measures, to prevent unauthorized access to our systems
•
We restrict access to Personal Information to Smart Eye employees, contractors, and agents who
need that information in order to process it. Anyone with this access is subject to strict
contractual confidentiality obligations and may be disciplined or terminated if they fail to meet
these obligations.
Access and Ability to Correct Your Informa;on
If the Personal Informa=on that we maintain about you is incorrect, you may correct it via the
Se\ngs, You may also contact us to request a correc=on via email or phone:
•
Email:
•
Phone:
This right does not apply to biometric informa=on.
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Children Under 17
The Solu=on is not intended for use by persons under 17. We do not knowingly collect Personal
Informa=on from children under 17. If you become aware that an End User under 17 years of
age is accessing the Solu=on, please contact us via email or phone:
•
Email:
•
Phone:
We will take steps to remove Personal Informa=on from the Company's servers and terminate
the account should the Company determine that a child under 17 has provided Personal
Informa=on via the Solu=on.
Changes or Updates to this Privacy No;ce
We reserve the right to revise or update this Privacy No=ce at any =me, and each update to the
Privacy No=ce will reflect the “Last Modified” Date. Your interac=on with the Company through
the methods discussed in this Privacy No=ce cons=tutes your assent to the terms contained
herein. You should periodically revisit the Privacy No=ce to learn of any revisions or updates.
In the event we materially change the way in which we use Personal Informa=on, the Company
will provide you with at least 30 days’ no=ce and provide you with the opportunity to indicate
your express consent to our use of your personal informa=on as described in the new Privacy
No=ce.
If you have specific ques=ons about this Privacy No=ce, please e-mail us at
dexter@getsmarteye.com.
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