Privacy Policy

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

1. Key Terms.

1. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

1. This personal information is required to provide products AND/OR services to you and/or to connect you with products or services in which you have indicated or demonstrated an interest. If you do not provide personal information we ask for, it may delay or prevent us and/or our customers from providing such products AND/OR services to you.
2. How Your Personal Information is Collected.

1. • From publicly accessible sources (e.g., social media);

1. • Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);

1. • From a third party with your consent (e.g., companies you do business with);

• From cookies and similar technologies on our website or that of our customer(s) and/or through direct email communications with you.

1. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

1. • To comply with our legal and regulatory obligations;

1. • For the performance of our contract with you or to take steps at your request before entering into a contract;

1. • For our legitimate interests or those of a third party; or

1. • Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

The above table does not apply to special category personal information, which we will only process with your explicit consent.

1. Promotional Communications. We may use your personal information to send you or assist in sending you updates (by email, text message, telephone or post) about our products AND/OR services or those of our customers, including exclusive offers, promotions or new products AND/OR services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and will only share it with other organizations for marketing purposes with your consent or pursuant to legitimate interests.

You have the right to opt out of receiving promotional communications at any time by:

1. • Contacting us at support@identified.ai;

1. • Using the “unsubscribe” link in emails or “STOP” number in texts; or

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products AND/OR services in the future, or if there are changes in the law, regulation, or the structure of our business.

1. Who We Share Your Personal Information With. We routinely share personal information with:

1. • Our affiliates;

1. • Service providers we use to help deliver our products and/or services and those of our customers to you, such as payment service providers, warehouses and delivery companies;

1. • Other third parties we use to help us run our business, such as marketing agencies or website hosts;

1. • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;

1. • Our customers in whom you indicate or demonstrate interest in their products and/or services.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

1. Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have not sold to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

1. • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her signature, social security number, physical characteristics or description, passport number, driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;

1. • Characteristics of protected classifications under California or federal law;

1. • Commercial information (e.g., records of personal property, products or services purchased, obtained);

1. • Biometric information;

1. • Geolocation data;

1. • Audio, electronic, visual, thermal, olfactory, or similar information;

1. • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and

1. • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

In the preceding 12 months, we have sold, subject to the permission control mechanisms described in this Policy, to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

1. • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);

1. • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, address, telephone number, and current employment;

1. • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);

1. • Commercial information (e.g., records of products or services considered, or other purchasing or consuming histories or tendencies);

1. • Professional or employment-related information;

1. • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences.

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

1. • Identifiers (e.g., a real name, alias, work postal address, work phone number, work email address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers);

1. • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, work address, work telephone number, work email address, education, employment, employment history;

1. • Commercial information (e.g., records of products or services considered, or other purchasing or consuming histories or tendencies);

1. • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);

1. • Professional or employment-related information; and

1. • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences.

1. Where Your Personal Information is Held. Information may be held at our offices and third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

1. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products AND/OR services to you or for your benefit. Thereafter, we will keep your personal information for as long as is necessary:

1. • To respond to any questions, complaints or claims made by you or on your behalf;

1. • To show that we treated you fairly; or

1. • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

1. Transferring Your Personal Information Out of the EEA.

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

1. • With our offices outside the EEA;

1. • With your and our service providers located outside the EEA;

1. • If you are based outside the EEA; or

1. • Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.

If you would like further information, please contact us (see “How To Contact Us” below).

1. Your Rights Under the GDPR.

1. For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.
2. Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

1. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
2. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

1. • Complete a data subject request form available on our website at identified.ai;

1. • Call us, toll-free, at 727-472-9099; or

1. • Email/write to us at support@identified.ai.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly, you will need to provide us with:

1. • Enough information to identify you [(e.g., your full name, address and customer or matter reference number))];

1. • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and

1. • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

1. How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

1. Children Under the Age of 13 Our Services are designed to be compliant with the Child Online Privacy Protection Action. As such, our Services are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Services, unless an account is set up by a parent or legal guardian. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Services or on or through any of its features without parental consent. Any personally identifiable information regarding a child under the age of 13 must be provided by a parent or legal guardian following completion of our verification process used to ensure that the person entering the information has the legal authority to do so. For more information on what constitutes a verifiable method of parental consent, please review 16 C.F.R. § 312.5. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us using the contact information set forth below.
2. Changes to This Privacy Notice. This privacy notice was published on December 08, 2023 and last updated on December 13, 2023.

We may change this privacy notice from time to time—please visit this page to review for changes.

1. How to Contact Us.  Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

1. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).