Data Services & Privacy Policy

Data Services & Privacy Policy

Smart Recognition, LLC (“We,” “Our,” or “Smart Recognition”) offers data marketing solutions (the “Solutions”) that aim to assist both for-profit and non-profit organizations, and their partner firms, in promoting their products and services in a relevant and effective manner. Our Solutions, which are largely outlined on this website, are primarily used to support email marketing.

This Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Policy. To the extent that any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall control.

We take the privacy concerns of the individuals whose data we handle and keep in our database very seriously. This Privacy Policy (“Policy”) is provided to explain how we utilize and manage data, as well as to inform consumers of their rights regarding how their information is used for marketing purposes.

To view theadditional disclosures for residents of California, Colorado, Nevada, Virginia, Connecticut, Utah, Iowa, Indiana, Tennessee, Montana, Florida, Texas, Oregon, or Delaware, please refer to the pertinent “ADDENDUM FOR ___________ RESIDENTS” following this general policy.

We also operate corporate websites that are intended for our own customers, potential customers, and other interested individuals who want to learn more about our Solutions. The information that we collect and use for those business purposes (such as data we use to communicate with our corporate clients and potential clients) is addressed in Section 6 of this Policy

To provide our Solutions, we obtain data, including personal data, from various sources, such as websites and applications that collect information, public sources, and other data compilers. In this Privacy Policy, we refer to this data as “Information” or “the Information.”

The Information in our database includes different identification details, such as:

Personal email account
Professional email account
Information and activities related to an email account, including whether it has recently been used, the amount and type of marketing or email open activity linked to an email
IP address
A cookie or other device identifiers unique to your web browser or device
Usage data connected to your email interactions, such as whether you receive, open, or respond to an email, and relevant information
Usage data connected to your website interactions, such as whether you visit or sign in to a website, page visits, and related information
Demographic data, such as approximate income or age range, household size, or home ownership
Information about consumer interests, such as the type of products that may interest you, or your hobbies, such as whether you are likely to have a pet or be a sports or art enthusiast.

Some of the data above may be deduced – for example, if a household is located in an affluent area, we may infer a specific income range.

We may merge any of the Information points we gather or receive with additional Information.

Smart Recognition also gathers data through this website (and any other site that we run), as well as our business activities. We clarify this data in Section 6.

How We Use the Information

Smart Recognition utilizes the Information for several purposes, including:

Part of Our Solutions:

Data Marketing Services. Our Solutions consist of supplying marketing information to our clients, concerning which clients or potential clients are likely to be interested (or not interested) in specific offers. We also assist our clients in better identifying and comprehending their customers by providing insights about them. Our clients include (but are not limited to) small and medium-sized businesses, advertising and media agencies, brands, and marketing data platforms that aid their clients in marketing and advertising to their own customers and prospective customers. Our clients may also include additional data compilers who collaborate with their own customers.

Retargeting Services. On occasion, we support our clients in “retargeting” marketing content to site visitors. Specifically, our Solutions help clients send emails to individuals who visited or logged in to their sites by cross-referencing information such as cookie identifiers and emails for those aims.

Additional Marketing Services. Smart Recognition may provide other Solutions to our clients (or assist them in providing these services to their own clients). These Solutions may complement the previous Solutions and include (a) helping clients target and optimize email campaigns, display, or other marketing; (b) assessing the effectiveness of marketing campaigns to determine which messages are more likely to be seen or opened by specific consumer types, or which types of advertisements are more likely to result in purchases; (c) analyzing and optimizing our clients’ (or their service providers’) personalized databases; (d) helping clients identify and prevent fraud and supply “validation” or data hygiene services, such as verifying or removing or correcting outdated, incorrect, or obsolete information, or determining whether an email address has been active recently.

To Operate Our Solutions

We also employ the Information mentioned above for our private internal purposes, such as to enhance, test, upgrade, and authenticate our own database; create new products; and run, evaluate, enhance, and secure our Solutions and our databases and servers.

How We Share Information with Third Parties, including Service Providers

Smart Recognition may share the Information with clients, marketing services and platforms, as well as service providers that assist us in providing the Solutions we have described above (or other Solutions we may include later). This encompasses sharing in the following manners:

With Our Clients: As stated above, we license the Information in various ways to our clients (and sometimes to partners and resellers, who subsequently license the Information to their clients) while delivering our Solutions. We may occasionally share the Information with those clients’ service providers, such as a provider that prints or sends out mailings for a client.

With Our Partners: We may also share the Information, including personally identifiable information and Audience Segments, with business and data associates to help provide more tailored targeted marketing, advertising, and communications. Similarly, we may do so for analytical purposes, including assisting these other parties in measuring campaign performance, informing future campaigns, or managing, analyzing, or segregating this Information on our or our clients’ behalf.

With Our Service Providers: We share the Information with various service providers in order to operate, safeguard, and advertise our Solutions and maintain our website(s). For example, we may share the Information with our tech, hosting, and customer support providers, marketing and advertising providers, other data providers (to enhance or verify our Information), security vendors, payment vendors (as to our business-to-business details), and other firms that assist us in providing, securing, or developing our Solutions.

Corporate Transfers: If Smart Recognition, its capital stock, or its substantial assets are acquired by or merged into another entity, our Information will be transferred to that entity and may also be disclosed during the due diligence process leading to such a transaction or potential transaction.

Affiliates, Parent Companies, and Subsidiaries: Smart Recognition may share some or all of the Information we possess with affiliated or subsidiary companies (if we ever have any).

As Required by Law or to Protect Any Person or Entity: Smart Recognition may disclose Information if we believe such disclosure is necessary to (a) comply in good faith with relevant laws or respond to subpoenas or warrants served on us; or (b) protect or defend the rights, assets, or safety of Smart Recognition, our clients, or any other person or entity.

Your Marketing and Opt-Out Choices

There are multiple ways to opt-out of having the Information used for marketing purposes:

First, you may visit our opt-out page at https://smartrecognition.com/optout to request that your personal information be removed from our database. After receiving the opt-out request, we will generally remove your personal information from our active marketing databases within 15 business days. However, in some cases, we may require that you provide verification of the information you submit, such as through a verified email response or another verified response, where legally permitted.

If you wish to opt-out of email marketing from a specific brand that we work with, such as a customer of ours, you can click on the “opt-out” or “unsubscribe” link in the footer (located at the bottom) of any marketing email you receive.

Although we generally do not engage in direct mail marketing, some of our clients and partners might. To opt-out of receiving marketing materials via physical mail, such as those delivered to your mailbox, a valuable resource is the DMA Choice website at thedma.org. DMA Choice, which is run by the Direct Marketing Association, enables you to take a few simple steps to ensure that your marketing preferences are respected.

To opt-out of our Retargeting Services as described in Section 2, visit Database Optout webpage and click on the “Opt Out” bar featured there. Note that you will need to do this from each browser that you use (as the retargeting and opt-out methods are cookie-based), and if you clear your browser cookies, you will have to opt-out again. We do recognize and use the Global Privacy Control on browsers, browser extensions, or devices that support such a signal.

If we market to you via email as part of our corporate capacity, for example, as a customer or potential customer of ours and we provide you with information about our Solutions, you have the option to “unsubscribe” from our marketing emails by using the link provided at the bottom of our emails.

Smart Recognition and its business partners use certain industry-standard technologies, including cookies and similar functioning technologies, which we describe below. We and our service providers use these technologies on our website, and our partners may use these technologies in their own marketing services.

We may work with third parties or service providers to provide or enhance our services (e.g. for purposes of tailoring ads or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form. These partners may set and access their own cookies, pixel tags, and similar technologies on your browser, which may have cookies with varying expiration periods. Those partners may likewise collect various types of information about your browser, device, or browsing activities through use of these cookies. These partners have independent privacy policies that we do not control.

Cookies, in turn, are small data files that contain a string of characters, such as a unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages (such as the website of a marketer), pixel tags may generate a generic notice of the visit and permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed. Pixel tags are used in combination with cookies to track the activity on a site by a particular device. When you turn off cookies, pixel tags simply detect a given website visit.

We, our service providers, and other online marketing platforms that we or they work with, may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see. Cookies are used in this way to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

If you wish to disable the use of cookies in your web browser, most web browsers are set up to accept cookies, but you may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, please note that if you disable the use of cookies, some features of our website and other services provided by Smart Recognition may be difficult to use or become inoperable.

Smart Recognition collects information from users of our website(s) (including any page on which this Privacy Policy is posted), including:

-The domain name and IP address of a user’s web browser, as well as a user agent, time stamp, and other information about a user’s browser or device.

-Information about what content and pages users access, utilize, or visit on our website, or how they interact with our content — for instance, if they spent a certain amount of time reviewing a particular blog post or description of particular services.

-Information, including personally identifiable and contact information that you provide, which could include (for instance) survey information, sign-up information (e.g., if you sign up for our webinars, events or newsletters), requests for information, mailing addresses, and email addresses.

Smart Recognition uses the information, including from cookies and similar technologies, we collect through our website(s) to:

-Create and manage your user account.

-Provide services you have requested.

-Respond to and communicate with you (including regarding news and updates about our services).

-Send you offers and ads for our products and services when you browse the website(s) or other companies’ websites on the internet (such as to “retarget” you with information about our services).

-Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you, such as invitations to events and webinars.

-Perform data analysis (including market research).

– For internal and operational purposes.

-We may combine the information with other information we obtain from third parties, publicly available sources, and any other product or service we provide to further improve the relevance and effectiveness of products and advertisements offered, including (but not limited to) those provided on or through our services.

Smart Recognition may use IP addresses to diagnose server problems and manage our website(s). We may also use IP addresses to identify visitors to our website(s) during a session and gather demographic information about our visitors. Clickstream data may be used to determine how visitors navigate through our website(s), how much time they spend on each page, and how we can improve our website(s) to better meet their needs. Additionally, we use this information to comply with our legal obligations, policies, and procedures, including enforcing our terms and conditions.

If we collect information from “offline” sources, such as business cards provided at a trade show, we will maintain and use that information for marketing and business purposes.

Smart Recognition may share or disclose the information we collect about you as described in this privacy policy or as otherwise stated when you provide us with the information.

Smart Recognition may share the information we collect with service providers who help us deliver or develop the services you request. This may include tech and customer support providers, marketing and advertising providers, data providers (to enhance or verify our information), security and data hygiene vendors, payment vendors (for business-to-business information), and other companies that assist us.

We may also share the information to communicate with you and market to you through email, direct mail, and display media.

This website may contain links to other websites that Smart Recognition believes may be useful or of interest to users. Smart Recognition is not responsible for the privacy practices of these other sites or their content. The links to third party website or locations are for convenience only and do not signify our endorsement of such third parties or their products, content, or websites.

In terms of security and data integrity, Smart Recognition takes measures to ensure that the data we collect is securely stored and transmitted. This includes physical and electronic security measures such as firewall protection, encryption, data hashing or truncation, and access controls to personal information. However, it is important to note that no platform or system can guarantee complete safety from hacks or illegal intrusion.

Our Privacy Policy may be updated periodically, and any changes to it will be effective once posted on our website. We encourage you to check back frequently to stay informed of any changes.

If you access our website from outside the United States, please note that your connection is likely to be through servers located in the US. As a result, any information you provide to us will be stored and processed in our US-based web servers and internal systems. It’s important to be aware that accessing our website or communicating with us may result in the collection or receipt of your information being subject to different privacy standards than those in your own country.

If you are a California resident, the California Consumer Protection Act (CCPA) provides you with certain rights regarding the disclosure, access, and deletion of your information, outlined in the “Addendum for California Residents” located at the end of this Privacy Policy.

If you are a resident of Colorado, Nevada, Virginia, Connecticut, Utah, Iowa, Indiana, Tennessee, Montana, Florida, Texas, Oregon, or Delaware, please see the applicable “ADDENDUM FOR _________ RESIDENTS” located at the end of this Privacy Policy.

Our Website and Services are not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use]. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy[at]smartrecognition.com.

Last updated: [POSTING DATE, 2023]

ADDENDUM FOR CALIFORNIA RESIDENTS

NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY PROTECTION ACT

The California Consumer Privacy Act of 2018 (“CCPA”) grants certain rights to California residents. This section of our Privacy Policy applies if you are a California resident (“California Consumer”) who uses our Services. This Addendum adds to the information in our Privacy Policy, but is only applicable to California Consumers. If you are not a California Consumer, this Addendum does not apply to you.

In the sections and tables below, we describe (as required by the CCPA):

Our Collection of Personal Information – refers to the types of personal information (which are broadly defined by the CCPA) we collect from various sources.

Our Disclosure and Sale of Personal Information – relates to the types of personal information that we may disclose or sell to various recipients.

Our Business Purposes – pertains to our reasons for collecting and sharing personal information, which are typically the same.

Your California Privacy Rights and Choices – outlines your rights under the CCPA, such as the right to request that we exclude your information from our marketing database (“do not sell” rights), or access the categories and personal information that we may have collected about you.

The categories of information that we collect and the purposes for which we use personal information of California Consumers are laid out below. The specific table also details how we gather and utilize these categories of information:

OUR COLLECTION OF PERSONAL INFORMATION

Depending on your interactions with Smart Recognition, we may collect various categories of personal information from different sources. The table below will provide an overview of these categories, as well as how we collect and use them.

Category

Sources of Categories

Identifiers, such as name, alias, postal address, mobile ad or cookie identifiers, IP address, phone number, email address, and social network handles

Data compilers and consumer data resellers, informational and retail websites (referred to as “Commercial Source Categories”)

Public records and other publicly available sources

Government entities

Social networks

Commercial or transactions information

This category includes products or services purchased, obtained, or considered, as well as other purchasing or consuming histories or tendencies.

Commercial Source Categories

Public records and other publicly available sources

Internet or other electronic network activity information

This category includes browsing history and online interests.

Commercial Source Categories

Professional or employment-related information

This category includes current or past job history or job title.

Public records and other publicly available sources

Commercial Source Categories

Inference Data

This category includes consumer information or preferences.

Commercial Source Categories

OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION

At Smart Recognition, we may share the personal information we have collected from you for various business purposes, with service providers, and with third parties, including our customers. The table below details how and with whom we disclose or share personal information. It also indicates whether we believe we have “sold” a particular category of information within the past 12 months based on the CCPA’s definition.

Category	Categories of Third Parties We Share With	Whether We “Sold” This Category of Personal Information in the Last 12 Months
Identifiers, e.g., name; alias; postal address; mobile ad identifiers; IP address; telephone number; email address; social network handles	Data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, content publishers, non-profit organizations, business-to-business services and organizations, consumer surveys and survey companies, affiliate networks (“Commercial Recipient Categories”) Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers Social networks	Yes
Commercial or transactions information E.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Commercial Recipient Categories Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers Social networks	Yes
Internet or other electronic network activity information E.g., browsing history; online interests.	Commercial Recipient Categories Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers, and social networks	Yes
Inference Data E.g., consumer information or preferences.	Commercial Recipient Categories Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers Social networks	Yes
Inference Data E.g., consumer information or preferences.	Commercial Recipient Categories Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers Social networks	Yes

We may also disclose any personal information we collect under the following circumstances:

Disclosure for Legal Reasons: Additionally, we may share personal information with third parties to: (a) comply with applicable legal regulations or a regulatory inquiry (such as a subpoena or court directive); (b) enforce our Terms of Service, Privacy Policy, or other agreements with you, which includes investigating potential violations; (c) respond to allegations that any content infringes on the rights of third parties; and/or (d) safeguard the interests, property, or personal safety of ourselves, our platform, our clients, our agents and partners, their users, and/or the general public. We may also give data to other businesses and organizations (such as law enforcement) for the prevention of fraud, spam, malware, and similar purposes.

Disclosure during Corporate Transactions: In the event of a significant corporate transaction, such as a merger, investment, buyout, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or in connection with any such transaction’s due diligence, we may also share personal information.

Smart Recognition shares any collected personal information with service providers who help us in providing, maintaining, and improving our services. These service providers may include those involved in customer support, technical operations, data hosting, billing, accounting, security, data management, validation, hygiene, or marketing.

We may also aggregate and/or de-identify the information we gather so that it is no longer directly linked to you or your device (“Aggregate/De-Identified Information”). We can use this Aggregate/De-Identified Information for any purpose, such as research and marketing, and may also, at our discretion, disclose it to third parties, including sponsors, advertisers, and promotional partners.

OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION:

Generally, we gather and disclose Personal Information for the objectives mentioned in our Privacy Policy and/or on our website, such as data marketing services.

Smart Recognition’s main objective is to build data marketing tools and products for our clients in compliance with our Privacy Policy on our website. This includes providing datasets, data appends, data scoring, data hygiene services, and security measures as required. We also assist our clients in obtaining a better understanding of their consumers’ requirements and behaviors, designing customer loyalty programs, and creating scoring products.

To locate users across different channels, we create identity graphs or associations between data points based on device-based, network-based, or personal identifiers such as IP address, cookie, device identifiers, and email address.

Furthermore, we provide additional marketing services that include creating data marketing tools and products described in our Privacy Policy. Our services also aid our clients in understanding their customers better, which includes managing loyalty programs, providing financial and other rating services, and assisting clients in offering excellent service to their existing and potential customers.

Smart Recognition assists in optimizing direct mail and email campaigns, display advertising, mobile, and social media marketing for our clients. We also measure the efficiency of online and offline ad campaigns and determine which messages or ads are most likely to result in purchases from different consumer groups.

Moreover, we provide analysis and optimization services for proprietary databases of our clients and help identify and mitigate potential fraud. We also provide services to update or clean databases by verifying, correcting, or removing old, incorrect, or outdated information.

Smart Recognition operates by developing new products, testing, verifying, improving, and securing our services, and improving our own database. We also use the information collected from our website, social networks, or other B2B interactions to aid our clients’ campaigns and our marketing purposes.

Lastly, we utilize the collected data for internal operations such as auditing, research, security monitoring, quality control, and legal compliance.

As a California resident, Smart Recognition acknowledges your right to request access, deletion, and opt-out of the sale of personal information, subject to legal restrictions. We will not discriminate against you for exercising these rights. You may also designate an authorized person to make such requests on your behalf.

As a service provider to our clients, we may forward consumer requests for access, deletion, or opt-out to the respective client, where feasible. This applies when we act as a service provider in processing or managing data that we have received from the client.

Moreover, you have the right to request us to not sell your personal information. If you want to make such a request, you can use the “Do Not Sell” web form available at https://www.smartrecognition.com/ccpa-do-not-sell/ or contact us at privacy[at]smartrecognition.com. We will maintain your information on an “internal suppression” list and remove your data from our active database in case we obtain it again at a later date.

As a California resident, you have the right to request the deletion of personal information Smart Recognition has collected from you, subject to certain legal restrictions. To initiate a deletion request, or to request certain information under California Civil Code Section 1798.83, you can email us at privacyt[at]smartrecognition.com. We may interpret your request as a “Do Not Sell” request and add it to our suppression list if we believe that’s what you intended while making the request.

However, we may retain some personal information for specific purposes such as fraud protection, technical debugging, lawful enforcement requests, scientific research, or compliance with legal obligations.

You also have the right to request access to your personal information and learn about the categories of data collected, used, or sold by Smart Recognition. You can make a request through the “request” web form available at https://smartrecognition.com/request. We may withhold some personal information where the disclosure may pose risks to your or others’ privacy.

For security reasons and legal compliance, we will verify your identity before responding to your requests. This verification may require you to provide certain information, such as your email address, which we will use to confirm your identity.

If you are a California resident, you have the right to request access to the personal information categories that Smart Recognition collects, uses or sells, as well as specific pieces of information collected from you. You can initiate such a request using our “request” web form available at https://smartrecognition.com/request. However, we may refuse to disclose certain information if the risk to your privacy or others’ rights is significant.

To ensure security and compliance with the law, we will verify your identity by requesting certain information whenever you submit a request. For example, if you request specific pieces of information, you may need to confirm your possession of an identifier, such as an email address, to prove your identity.

It is important to note that exercising your rights will not lead to any discrimination on our side in terms of pricing, quality, or access to our services.

You also have the right to opt-out of the sale of your personal information, which includes the exchange of various information for valuable consideration, as defined by California law. If you want to opt-out, you can use our “Do Not Sell” web form available at https://www.smartrecognition.com/ccpa-do-not-sell/ or email us at privacy[at]smartrecognition.com. We will add your details to our suppression list, which means we will not sell your information in the future, subject to certain exceptions permitted under the law.

We at Smart Recognition do not intentionally collect personal information from minors under the age of 16 in California, unless we have obtained the necessary legal authorization to do so. In case we discover that we have collected personal information from such minors, we will take appropriate steps to erase their details from our database, or will seek legally required consent.

You also have the option of designating an authorized agent to exercise your CCPA rights on your behalf. To ensure security and compliance with the law, we will verify the identity of the person exercising their rights and the agent’s authorization via a signed written authorization or legally adequate power of attorney. We reserve the right to ask you to verify your identity, depending on the nature of your request.

ADDENDUM FOR COLORADO RESIDENTS

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified or identifiable individual.” “Personal data” does not include de-identified or publicly available information.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data it has collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Colorado Attorney General.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose sensitive personal information for the purposes provided in this Policy. You may withdraw your consent to any use or disclosure of your personal sensitive information at any time by contacting us.

If you would like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you in order to comply with your request. We will only use the information it receives to respond to your request. We will not be able to disclose information or comply with your request if it cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf.

ADDENDUM FOR NEVADA RESIDENTS

Smart Recognition does not sell, rent, or lease your personally identifiable information to third parties. However, if you are a resident of Nevada and would like to submit a request not to sell your personally identifiable information, you may do so by emailing us at privacy[at]smartrecognition.com or by using this form.

ADDENDUM FOR VIRGINIA RESIDENTS

Personal information or “personal data” means “any information that is linked or reasonably linkable to an identified or identifiable natural person.” “Personal data” does not include de-identified data or publicly available information.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data provided by or obtained about you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

If you would like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you in order to comply with your request. We will only use the information received for this purpose to respond to your request. We will not be able to disclose information or comply with your request if it cannot verify that the person making the request is the person about whom we collected information, or if such person is a known child, that child’s parent, or their legal guardian.

ADDENDUM FOR CONNECTICUT RESIDENTS

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.
Request to Delete. You may request that we delete the personal data it has collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.
Right to Data Portability. You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.
Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Connecticut Attorney General or submit a complaint online at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.
Withdraw Consent for Your Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information. However, if you believe that we may have collected sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you’d like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

ADDENDUM FOR UTAH RESIDENTS

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual.” “Personal data” does not include deidentified data, aggregated data, or publicly available information.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.
Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Right to Data Portability. You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising.
Withdraw Consent for Your Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information. However, if you believe that we may have collected sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you’d like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

ADDENDUM FOR IOWA RESIDENTS

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising.
Appeal. If we notify you that no action is to be taken in response to your request to access, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Iowa Attorney General.
Withdraw Consent for Your Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information. However, if you believe that we may have collected sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you’d like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

ADDENDUM FOR INDIANA RESIDENTS

Request to Access. You may submit a request to confirm or to obtain a copy or representative summary of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.
Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.
Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Indiana Attorney General.
Withdraw Consent for Your Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information. However, if you believe that we may have collected sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you’d like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

ADDENDUM FOR TENNESSEE RESIDENTS

“Personal information” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual.” Personal information does not include deidentified data, aggregated data, or publicly available information.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal information that we have collected on you including what the information is, how it’s been used, whether it’s been sold, and who it’s been disclosed to. Your personal information may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
Request to Correct. You may correct or update your personal information at any time by logging into your account or by contacting us.
Request to Delete. You may request that we delete the personal information that you have provided to us. We will delete your personal information from our records and direct any service providers to do the same unless retention is required by law.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal information. We do not sell, rent, or lease your personal data to third parties and do not process your personal information for targeted advertising or consumer profiling.
Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Tennessee Attorney General.
Withdraw Consent for Your Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information. However, if you believe that we may have collected sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you’d like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

ADDENDUM FOR MONTANA RESIDENTS

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.
Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.
Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Montana Attorney General.
Withdraw Consent for Your Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information. However, if you believe that we may have collected sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you’d like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

ADDENDUM FOR FLORIDA RESIDENTS

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual” and includes pseudonymous data when such data is used with additional information. “Personal data” does not include deidentified data or publicly available information.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.
Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Requests to Opt-Out. You may submit a request to opt out of the sale of your personal data; however, we do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling. We also do not collect, use, or disclose sensitive personal information (also referred to herein as “sensitive data”), but if you believe that we may have collected any other sensitive data about you, such as precise geolocation, you may withdraw your consent to any use or disclosure of your sensitive data and opt-out of the collection and processing of such sensitive data. We further do not collect personal data through the operation of a voice recognition or facial recognition feature; however, you may also opt out of such collection in the event we do use such features.
Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Florida Attorney General.

If you’d like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

ADDENDUM FOR TEXAS RESIDENTS

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.
Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.
Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Texas Attorney General.
Withdraw Consent for Your Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information. However, if you believe that we may have collected sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you’d like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

ADDENDUM FOR OREGON RESIDENTS

Personal information or “personal data” means “data, derived data or a unique identifier that is linked to or is reasonably linkable to a consumer or to a device that identifies, is linked to or is reasonably linkable to one or more consumers.” “Personal data” does not include deidentified data or publicly available information.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.
Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.
Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Oregon Attorney General.
Withdraw Consent for Your Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information. However, if you believe that we may have collected sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you’d like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

Addendum for Delaware Residents

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.
Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising, consumer profiling, or automated decisionmaking.
Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Delaware Attorney General.
Withdraw Consent for Your Sensitive Personal Information. We do not collect, use, or disclose sensitive personal information. However, if you believe that we may have collected sensitive personal information about you, you may withdraw your consent to any use or disclosure of your personal sensitive information.

If you’d like to make any of the above requests, you can contact us at privacy[at]smartrecognition.com or by using this form. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.