We rely upon a number of legal grounds to enable our use of your Personal
Data. We use Personal Data to facilitate the business relationships we have
with our Users, to comply with our financial regulatory and other legal
obligations, and to pursue our legitimate business interests. We use Personal
Data for the purpose of entering into business relationships with prospective
Eye4Fraud Users, and to perform the contractual obligations under the
contracts that we have with Eye4Fraud Users. Activities include:
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Creation and management of Eye4Fraud accounts and Eye4Fraud
account credentials, including the evaluation of applications to
commence or expand the use of our Services;
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Accounting, auditing, and billing activities; and
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Assisting our User in the processing of payments, including fraud
detection and prevention, optimizing valid transactions,
communications regarding such payments, and related customer
service.
Legal compliance
We use Personal Data to verify the identity of our Users in order to comply
with fraud monitoring, prevention and detection obligations, laws associated
with the identification and reporting of illegal and illicit activity, and financial
reporting obligations.
Legitimate business interests
Where allowed under applicable law, we rely on our legitimate business
interests to process Personal Data about you. When we do so, we balance
our legitimate interests against the interests and rights of the individuals
whose Personal Data we process. The following list sets out the business
purposes that we have identified as legitimate:
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Detect, monitor and prevent fraud and unauthorized payment
transactions;
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Mitigate financial loss, claims, liabilities or other harm to Customers,
Users and Eye4Fraud;
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Respond to inquiries, send Service notices and provide customer
support;
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Manage, operate and improve the performance of our Sites and
Services by understanding their effectiveness and optimizing our
digital assets;
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Analyze and advertise our Services;
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Enable network and information security throughout Eye4Fraud and
our Services; and
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Share Personal Data among our affiliates for administrative purposes.
Payment transactions and related services
We use Personal Data of Customers to provide our Services to Users,
including to authenticate payment transactions and Customers on behalf of
our Users. All such use is pursuant to the terms of our business relationships
with our Users. We also use Personal Data to detect and prevent fraud. In
providing such services, we may provide Users who have requested such
services Personal Data from a Customer to assess the fraud risk associated
with an attempted transaction by their Customer.
b. Marketing and events-related communications
We may send you email marketing communications about Eye4Fraud
products and services, invite you to participate in our events or surveys, or
otherwise communicate with you for marketing purposes, provided that we
do so in accordance with applicable law, including any consent requirements.
For example, when you submit your contact information to us or when we
collect your business contact details through our participation at trade shows
or other events, we may use the information to follow-up with you regarding
an event, send you information that you have requested on our products and
services and, with your permission, include you on our marketing information
campaigns.
c. Advertising
When you visit our Sites, we (and our service providers) may use Personal
Data collected from you and your device to target advertisements for
Eye4Fraud Services to you on our Sites and other sites you visit (“interest-
based advertising”), where allowed by applicable law, including any consent
requirements. For example, when you visit our Site, we will use cookies to
identify your device and direct ads for our Services to you. You have choices
and control over our cookies (or similar technologies) we use to advertise to
you. We do not use, share, rent or sell the Personal Data of our Users’
Customers for interest-based advertising. We do not sell or rent the Personal
Data of our Users, their Customers or our Site Visitors.
Eye4Fraud does not sell or rent Personal Data to marketers or unaffiliated
third parties. We share your Personal Data with trusted entities, as outlined
below
a. Service providers
We share Personal Data with certain of our service providers subject to
contract terms that limit their use of Personal Data. We have service
providers that provide services on our behalf, such as identity verification
services, website hosting, data analysis, marketing service, information
technology and related infrastructure, customer service, email delivery, and
auditing services. These service providers may need to access Personal Data
to perform their services. We authorize such service providers to use or
disclose the Personal Data only to perform services on our behalf or comply
with legal requirements. We require such service providers to contractually
commit to protect the security and confidentiality of Personal Data they
process on our behalf. Our service providers are predominantly located in
the European Union and the United States of America.
b. Business partners
We share Personal Data with third party business partners in connection with
our Services to our Users, such as partners with whom we conduct certain
scientific and/or statistical studies (in this case, only aggregated personal
data will be processed).
c. Our Users and third parties authorized by our Users
We share Personal Data with Users to maintain a User account and provide
the Services and third party services. We share data with parties directly
authorized by a User to receive Personal Data. This includes sharing Personal
Data of Customers with Users to assess the fraud risk associated with
attempted transactions by Customers. The use of Personal Data by an
authorized third party is subject to the third party’s privacy policy.
d. Corporate matters
We share Personal Data with third parties with whom we negotiate in the
context of mergers, takeovers or similar operations.
You may have choices regarding our collection, use and disclosure of your
Personal Data:
a. Opting out of receiving electronic communications from us
If you no longer want to receive marketing-related emails from us, you may
opt-out via the unsubscribe link included in such emails. We will try to
comply with your request(s) as soon as reasonably practicable. Please note
that if you opt-out of receiving marketing-related emails from us, we may
still send you other messages in connection with providing our Services.
b. How you can see or change your account Personal Data
If you would like to review, correct, or update Personal Data that you have
previously disclosed to us, you may do so by signing in to your Eye4Fraud
account or by contacting us.
b. Your data protection rights
Depending on your location and subject to applicable law, you may have the
following rights with regard to the Personal Data we control about you:
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The right to request confirmation of whether Eye4Fraud processes
Personal Data relating to you, and if so, to request a copy of that
Personal Data;
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The right to request that Eye4Fraud rectifies or updates your Personal
Data that is inaccurate, incomplete or outdated;
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The right to request that Eye4Fraud erase your Personal Data in
certain circumstances provided by law;
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The right to request that Eye4Fraud restrict the use of your Personal
Data in certain circumstances, such as while Eye4Fraud considers
another request that you have submitted (including a request that
Eye4Fraud make an update to your Personal Data);
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The right to request that we export your Personal Data that we hold to
another company, where technically feasible;
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Where the processing of your Personal Data is based on your
previously given consent, you have the right to withdraw your consent
at any time; and/or
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In some cases, you may also have the right to object to the processing
of your Personal Data.
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California Civil Code Section § 1798.83 permits Users that are
California residents to request certain information regarding our
disclosure of personal information to third parties for their direct
marketing purposes. To make such a request, please contact us.
d. Process for exercising data protection rights
We will comply with your request to the extent required by applicable law.
We will not be able to respond to a request if we no longer hold your
Personal Data. If you feel that you have not received a satisfactory response
from us, you may have the right under applicable laws to consult with the
data protection authority in your country.
For your protection, we may need to verify your identity before responding to
your request, such as verifying that the email address from which you send
the request matches your email address that we have on file. If we no longer
need to process Personal Data about you in order to provide our Services or
our Sites, we will not maintain, acquire or process additional information in
order to identify you for the purpose of responding to your request.
If you are a Customer of a Eye4Fraud User, please direct your requests
directly to the User. For example, if you are making, or have made, a
purchase from a merchant using Eye4Fraud’s Services, and you have a
request that is related to the payment information that you provided as part
of the purchase transaction, then you should address your request directly to
the merchant.
We make reasonable efforts to provide a level of security appropriate to the
risk associated with the processing of Personal Data. We maintain
organizational, technical and administrative measures designed to protect
Personal Data covered by this Privacy Policy against unauthorized access,
destruction, loss, alteration or misuse. Your Personal Data is only accessed
by a limited number of personnel who need access to the information to
perform their duties. Unfortunately, no data transmission or storage system
can be guaranteed to be 100% secure. If you have reason to believe that
your interaction with us is no longer secure (e.g., you feel that the security of
your account has been compromised), please contact us immediately.
We retain your Personal Data as long as we are providing the Services to you
or our Users (as applicable). Even after we stop providing Services directly or
indirectly to you, and even if you close your Eye4Fraud account or complete
a transaction with a Eye4Fraud User, we keep your Personal Data in order to
comply with our legal and regulatory obligations. We may also keep it to
assist with our fraud monitoring, detection and prevention activities. We also
keep Personal Data to comply with our tax, accounting, and financial
reporting obligations, where we are required to retain the data by our
contractual commitments to our financial partners, and where data retention
is mandated by the payment methods you used. In all cases where we keep
data, we do so in accordance with any limitation periods and records
retention obligations that are imposed by applicable law.
We are a global business. Personal Data may be stored and processed in any
country where we do business or our service providers do business. We may
transfer your Personal Data to countries other than your own country,
including to the United States and countries in the European Economic Area
(“EEA”). These countries may have data protection rules that are different
from your country. When transferring data across borders, we take measures
to comply with applicable data protection laws related to such transfer.
Officials (such as law enforcement or security authorities) in those other
countries may be entitled to access your Personal Data.
If you are located in the EEA, the UK or Switzerland, we comply with
applicable laws to provide an adequate level of data protection for the
transfer of your Personal Data to the US. Where applicable law requires that
a data transfer legal mechanism, we use one or more of the following: EU
Standard Contractual Clauses with a data recipient outside the EEA or the
UK, verification that the recipient has implemented Binding Corporate Rules,
or other legal method available to us under applicable law.
While Eye4Fraud Inc. remains self-certified under the E.U.-U.S. Privacy Shield
and the Swiss-U.S. Privacy Shield, it is not currently relying on these
frameworks for the transfer of personal data to the U.S.
The Services are not directed to minors, including children under the age of
13, and we request that they not provide Personal Data through the
Services. In some countries, we may impose higher age limits as required by
applicable law. We do not sell any Personal Data of Customers, Visitors or
Users, including those aged between 13 to 16.
We may change this Privacy Policy from time to time to reflect new services,
changes in our Personal Data practices or relevant laws. The “Last updated”
legend at the top of this Privacy Policy indicates when this Privacy Policy was
last revised. Any changes are effective when we post the revised Privacy
Policy on the Services.
We may provide you with disclosures and alerts regarding the Privacy Policy
or Personal Data collected by posting them on our website and, if you are a
User, by contacting you through your Eye4Fraud account, email address
and/or the physical address listed in your Eye4Fraud account.
If applicable law requires that we obtain your consent or provide notice in a
specified manner prior to making any changes to this Privacy Policy
applicable to you, we will provide such required notice and will obtain your
required consent.
If you wish to submit a request to exercise one or more of the rights listed
above, you can contact us. An e-mail requesting to exercise a right will not
be construed as consent with the processing of your Personal Data beyond
what is required for handling your request. Such request should meet the
following conditions:
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State clearly which right you wish to exercise; and
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State clearly the reasons for exercising your right if such is required;
and
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Your request should be dated and signed; and
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Your request should be accompanied by a digitally scanned copy of
your valid identity card proving your identity. If you use the contact
form, we may ask you for your signed confirmation and proof of
identity.
We will promptly inform you of having received your request. If the request
meets the conditions above and proves valid, we will honor it as soon as
reasonably possible and at the latest thirty (30) days after having received
your request.
If you have any questions or complaints about this Privacy Policy, please contact us.