Adverteyes Inc. (“Adverteyes”) conducts market research to help improve web content and online advertising for its customers. Our proprietary software is used to track facial features of people who choose to participate in our market research and to analyse their emotional response to on-screen media.
While Adverteyes is committed to making the participant experience as natural and as unobtrusive as possible, we also take seriously the privacy of participants in our studies. Adverteyes is incorporated in the State of Delaware, United States (principal address: 13 W Main Street, Felton, DE 19943, United States, contact: info@Adverteyes.ai). We comply with applicable data protection requirements, including the European Union General Data Protection Regulation (GDPR) where applicable to our processing of personal data of individuals in the EEA, and applicable U.S. federal and state privacy laws.
Our Privacy Policy tells you how we look after and use the Personal Information (see definition below) that we collect from participants through our Adverteyes services, as well as information that we collect through our website at www.Adverteyes.ai (“Website”). Adverteyes is the data controller (as defined under GDPR) and the business responsible for collecting your data (as defined under applicable U.S. state privacy laws) for the data we collect. Please read this Privacy and Cookies Policy (“Policy”) carefully. When you participate in one of our market researches or use our Website, you are agreeing to this Policy.
Adverteyes leaves you in charge in terms of your Personal Data.
Any Personal Information that we collect from you will be treated as confidential through the implementation of security measures.
We do not share your data collected during market research with our customers in a way that allows for the identification of any specific individual who participates in our studies.
Personal Information means anything that can be used to identify you, including facial recordings and IP addresses that we collect as you participate in our market research or information that we collect from users of our website or our services.
If you do not agree with our Policy, please do not participate in Adverteyes market research at this time or use our website.
All Personal Information will be stored in secure locations, primarily in the United States. For individuals in the European Economic Area, we ensure that any transfer of personal data is subject to appropriate safeguards under applicable data protection law.
We use industry standard technical and organizational security measures to protect your data against unauthorized disclosure or processing. These measures vary depending on the sensitivity of the information we have collected from you.
However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is absolutely secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
When you use our Website, we and third parties (data processors we engage such as website hosting and content management services providers, technology and communications platform providers, providers of website analytics) may use automated means to collect information about you, your computer or other device and your use of our Website.
For instance, our web servers may collect and log information such as the type of device, operating system and browser you use when accessing our Website, and other system settings, such as language your system uses and the country and time zone where your device is located. Our web server may also record the address of the web page that referred you to our Website and the IP address of the device you use connect to our Website.
We also collect other information that you choose to provide when using our Website or our services. If you choose to create an account on our website, we will collect your name, company name, job title and email address. (Creating an account will provide you the possibility to access advanced content which can include viewing our white papers presentations and to demo the Adverteyes services etc.)
Adverteyes will not use users’ personal information for any other purpose without your consent or legal obligation to do so.
This category of personal data includes all data we collect during a market research (including any media analysis carried out for the benefit of Adverteyes’ customers and software improvement).
Such personal data includes the following:
Assignment of unique identifiers during Services engagements, including via cookies.
Survey responses and market research study data explicitly provided by the subjects of the survey or market research data.
Your device environment and specifications:
Platform (mobile/tablet/desktop).
Browser name and version.
Operating System name and version.
Anonymised IP address with the last subnet discarded.
Your interactions with the content via the device:
Whether a video loads and is in focus.
How you engage with a video.
Video metadata such as content ID, title, and category.
Percentage of video content that has been viewed.
Facial recordings of you as you interact with the media content, via your device’s front-facing camera:
If you have given us permission to use the front-facing camera of your device then, while you are interacting with the content, we access the data from the camera and process it in our cloud environment using our software to derive the following separate data-points:
Whether a face is detected and, if so, the position and orientation of the face relative to the screen. Our software does not engage in facial recognition of any kind.
The extent to which you appear to be paying attention to the content.
Your apparent reaction to the content (levels of overall emotion displayed, such as happiness, surprise, sadness, feat, confusion, contempt or disgust).
Data we have accessed from the camera will be used strictly for reporting to our customers and for enhancements in the use of software.
Adverteyes does not knowingly obtain information, study data, or survey responses from participants under the age of 18, unless (i) applicable local data protection legislation provides for a lower threshold age; or (ii) we obtain the required parental consent.
Should we discover that any data has been collected from a participant under the age of 18, without meeting either conditions under points (i) or (ii) above, we will immediately delete it.
We use your Personal Information for the following purposes.
Adverteyes specialises in media measurement research — we analyse how people feel when they view on-screen media. We analyse these reactions to help our customers improve their content and advertising. Your participation in our studies is voluntary and highly valued.
Processing based on your explicit consent
With your explicit consent, we collect and process your facial images, biometric data, and other personal data described in the “Information collected during market research” section above for the following purposes: (a) conducting media measurement research for the benefit of our clients, including quality assurance; and (b) training, developing, testing, and improving our machine learning models and artificial intelligence systems.
Our machine learning models and AI systems are being trained to be able to determine if the same individual appears in two separate recordings and to accurately measure attention and emotional engagement.
These models are built and trained on datasets of real data, such as the facial data we collect from participants. While our models may develop the capability to uniquely differentiate one natural person from another, the primary purpose for collecting and using your facial images is to train and improve our machine learning models and AI systems — not to uniquely identify you.
Facial images as such can be considered as biometric data, if the following three conditions are met:
a) data relating to physical, physiological or behavioural characteristics of a natural person (including facial images);
b) such personal data results from specific technical processing of data set out in a); and
c) personal data is used to uniquely identify a natural person.
As set out above, our current purpose for using your facial images is not to uniquely identify you, but to properly train our machine learning models and AI systems. Our research and development team does not have any other identifying information about you and does not intend to uniquely identify you through any other means.
Processing based on our legitimate interest
In the course of the above processing, we create anonymous and aggregated data from the personal data we collect. We create anonymous data by removing or transforming information (such as facial images) in a way that the resulting data can no longer be used to identify any individual.
We use this anonymous, aggregated data to analyse usage patterns, improve our platform and services, and for ongoing research and development. The legal basis for processing such anonymous, aggregated data is our legitimate business interest. Broadly speaking, legitimate interests means that we process this data based on our genuine and legitimate reason and on condition that we are not harming any of your rights and freedoms.
In our assessment, we have taken into account the risks present in our processing, your likely response to those risks, and the benefits you are likely to receive from such processing.
What our clients receive
The information that we share with our customers is anonymized and does not individually identify any participant. Our clients receive only aggregated ad performance results based on tested creatives.
If you create an account on our website and if you provide your consent for Adverteyes to contact you, Adverteyes may use your personal information to contact you and to ensure that the Website and services work correctly and to offer you support.
The personal information might be needed also in case our registered users have issues with the Adverteyes services or website. Further use is also specified in this Policy under the Cookies section.
Adverteyes will not share your Personal Information with third parties for marketing purposes.
Adverteyes will not use users’ personal information for any other purpose without your consent or legal obligation to do so.
Adverteyes may share your information in limited ways in order to provide our services:
We work with trusted partners to perform the following tasks on our behalf and we may need to disclose Personal Information to them so that they can perform these tasks. These tasks include website hosting, content management services, technology and communications platform providers and providers of website analytics, annotation service providers. However, these companies are bound by confidentiality obligations and do not have any independent right to use Personal Information beyond what is necessary to assist us in order to provide our services.
We may share your Personal Information, where appropriate and where we have the necessary legal basis, with any member of our group of companies, any of our affiliates or direct or indirect licensees. Any disclosure will be in accordance with data protection regulations and you consent to share your Personal Information with our group companies and affiliates.
We may share your Personal Information when we believe that doing so is necessary to protect, enforce, or defend the legal rights, privacy, safety, or property of Adverteyes, our employees or agents or users, or to comply with applicable law or legal process, including responding to requests from public and government authorities.
You agree that, if there is a change in the ownership of Adverteyes or any of our assets, such as in connection with a merger, acquisition, reorganization, dissolution or liquidation), or if we take steps in anticipation of such a transaction, we may transfer and disclose Personal Information we have collected to the new or prospective company, subject always to the data protection regulations.
We may share anonymized, aggregated or de-identified data without restriction.
In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you consent to or direct such sharing.
We do not sell, share, or disclose your biometric data to third parties for their own independent use. Our clients receive only aggregated, anonymized ad performance results based on tested creatives.
Cookies are small text files that we place on your computer or device to allow us to track our research and assess participant behaviour information. We use third party service providers to track usage and interaction with the media players that are used to measure responses to advertisements. Our cookies are deleted after 13 months.
We also may use service providers like Google Analytics and Hubspot to help us analyse how users use our Website. The information collected by the technology will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on. To find out more about cookies and how to delete them.
If you take part in a market research, we will place a cookie on your browser containing a Participant ID which enables us to identify you in case you wish to see the data we hold of you. We require you to provide us the Participant ID in case you wish to access the participant records we hold of you.
If you opt out of participating in a market research, we will place a cookie on your computer as it is required to remember your choice (the sole purpose of that cookie). If you delete your cookies from your browser, you will also be deleting your opt out and you may be asked to participate in our market researches again.
We do not have access to and this Policy does not govern the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below.
We do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
Our website may contain links to third-party websites such as social media sites, and may also contain third-party plug-ins (such as the Facebook “like” button and Twitter “follow” button).
If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. Our media player may be placed on third party websites as part of their services to their users.
As these third-party websites and services are not operated by Adverteyes, we are not responsible for the content or practices of those websites or services beyond incorporating such third-party plug-ins to our website.
The collection, use, and disclosure of your personal and other information will also be subject to the privacy policies of the third party websites or services, and not only this Privacy Policy. We urge you to read the privacy and security policies of these third-parties.
We retain Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including providing media measurement services, ongoing research and development, product improvement, machine learning model training, and as required by applicable law. When determining the appropriate retention period, we consider the nature and sensitivity of the data, the purposes for which it is processed, and applicable legal requirements. When Personal Information is no longer required for these purposes, we will securely delete or anonymize it.
If you request deletion of any of your Personal Information (see right to erasure as set out below), we will delete that particular data within 30 days of receipt of your request.
Adverteyes does not knowingly obtain information, study data, or survey responses from participants under the age of 18, unless (i) applicable local data protection legislation provides for a lower threshold age; or (ii) we obtain the required consent under applicable law. Should we discover that any data has been collected from a participant under the age of 18, without meeting either conditions under points (i) or (ii) above, we will immediately delete it.
Your Personal Information is primarily stored and processed in the United States or Europe. For individuals located in the European Economic Area (EEA), this constitutes a transfer of personal data outside the EEA.
We ensure that any such transfer is subject to appropriate safeguards as required under applicable data protection laws, such as Standard Contractual Clauses approved by the European Commission, or other legally recognized mechanisms.
We may also transfer data to other countries where adequate protections are in place. We take appropriate steps to ensure your information is adequately protected regardless of where it is processed. If you do not agree to this, please do not use our services.
If you want to see, change or delete your Personal Information, contact us at info@adverteyesit.com under the subject heading “Privacy Policy”. In certain jurisdictions, you may be entitled to request access to Personal Information we hold, by writing to us. A small fee may be charged for this service, to cover administrative costs.
Depending on your location, you may have certain rights regarding your personal data under applicable laws, including the EU General Data Protection Regulation (GDPR) and applicable U.S. state privacy laws. Please contact info@Adverteyes.ai for applications regarding your personal data.
If you took part in our surveys, we can only identify your personal data using a Participant ID that was shown to you after the survey and which was also stored in a cookie on your device. Please keep record of your participant ID for future reference. If the Participant ID cannot be identified, Adverteyes is not able to identify your data to fulfil your request.
The GDPR gives you the right to access information that we held about you. If you want to access that information, please send your request to info@Adverteyes.ai. Any request for access of your information shall be a subject to providing the acceptable proof of identification.
In relation to our studies we also require you to provide us the Participant ID shown to you when taking part in the study and which is also stored in a cookie on the device used to participate in our study. If all complies, you will be provided with the copy of your personal data.
If a person’s request for information or measures is clearly unjustified or excessive, a reasonable fee may be asked, or the action taken may be refused.
You can have your personal data rectified at any time, in case it is inaccurate or incomplete. You should notify us to correct or update your personal data. You can notify us at any time at info@Adverteyes.com
You can request to delete your personal data at any time by contacting us at info@Adverteyes.com.
In certain circumstances, you have a right to restrict or block us from processing your personal data.
If the processing is done based on your consent, you have the right to withdraw your consent to processing of your personal data at any time by contacting us at info@Adverteyes.ai
At any given time, you have a right to object to the processing of your personal data. Please follow the instructions for erasure.
If you are a resident of a U.S. state with applicable privacy legislation, you may also have the following additional rights:
This Policy is governed by the laws of the State of Delaware, United States, without regard to its conflict of law provisions. Any disputes in connection with this Policy shall be settled through negotiations.
If the parties fail to resolve the dispute through negotiation, the disputes shall be settled by the courts of the State of Delaware, United States.
If you have any concerns with the way we process or handle your data, we would encourage you to contact us directly to resolve your concerns. For individuals in the European Economic Area, you have the right to lodge a complaint with your local data protection supervisory authority.
For individuals in the United States, you may contact your state’s Attorney General’s office if you believe your privacy rights have been violated.
Please contact us if you have any comments or questions about information that we hold or about our Privacy Policy. Send an email to info@Adverteyes.ai under the subject heading “Privacy Policy”. Write to us at Adverteyes Inc., 13 W Main Street, Felton, DE 19943, Delaware, United States.
We may update our Privacy Policy from time to time. We will notify you of changes by posting an announcement on our website or during the use of the software or other service we provide. You are bound by any changes to our Privacy Policy when you use our service after you are notified of these changes (by an announcement on our website or in the software or during other service).
| Definitions | The terms “Business Purpose(s)”, “Personal Information”, “Sell” (or “Sale”), “Share”, “Sensitive Personal Information”, “Service Provider(s)” and “Third Parties” have the meanings given in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”). These term references and disclosures are limited to this section of the Privacy Policy and designated exclusively for California Consumers. |
| Categories of collected Personal Information | Website visitors: Names, professional titles and company affiliations, email addresses, cookie IDs, IP addresses. Market research: Proprietary unique identifiers, IP addresses, cookie IDs, facial images, coded facial expressions, age and gender estimations, device heuristics, behavioral information associated with use of our software. |
| Categories of Sensitive Personal Information Collected | Biometric information, including facial scan data and numerical biometric data derived from facial images. We process this sensitive personal information based on explicit consent and only for the purposes disclosed in this Policy. |
| Purposes for collection and use of Personal Information | We use personal information to facilitate the operation of our website, conduct market research, train and improve our machine learning models and AI systems, develop and improve our products and services, and for internal research and development. |
| Categories of sources from which Personal Information is collected | Directly from participants through our proprietary media measurement software and device cameras during participation, our website, and customer support services. |
| Sale and Sharing of Personal Information | We do not sell or share personal information as those terms are defined under the CCPA. Our clients receive only aggregated, de-identified ad performance results. |
| Categories of third parties to whom information was disclosed for a business purpose | Website hosting and content management services, technology and communications platforms, website analytics, annotation service providers, and our group entities and affiliates. |
| California Consumer Rights & Options | As a California resident, you have the right to: (i) request access to and disclosure of the categories and specific pieces of personal information we have collected about you; (ii) request deletion of your personal information; (iii) request correction of inaccurate personal information; (iv) limit our use of your sensitive personal information; and (v) not be discriminated against for exercising your rights. To exercise these rights, email us at info@Adverteyes.ai with the subject heading “Privacy Request.” We may need to verify your identity before fulfilling your request. Please note we may not accept a request where we cannot verify your identity or California residency, where we require it to comply with a legal obligation or in relation to a legal claim. |
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