Foursixty Inc. (“Foursixty”, “we”, “us”, “our”) is committed to the protection of personal information. As part of this commitment, we have set out this Privacy Policy to describe the manner in which we treat the personal information that we maintain on behalf of our customers (“Customers”), as well as the personal information we collect, such as through our website at https://foursixty.com/ (“Website”).
Collection and Use of Information
Information we maintain on behalf of our Customers
Foursixty provides social commerce and social content management services for brands, bloggers, and advertising agencies (“Customers”), including an API and related website services that enable Customers to create shoppable Instagram galleries on their websites (“Sites”), and to secure rights to use ephotos and videos that have been posted on Instagram (together, the “Services”).
We collect and maintain the following information on behalf of our Customers for the purposes of providing the Services:
· Individuals who visit a Customer’s Instagram gallery (end users):
o We collect log data (Internet Protocol address, cookies, date/timestamp, clicks) and cookie data to track if a session has interacted with a Foursixty post. We use this data for the purpose of tracking and analyzing which digital assets an end-user interacted with in order to show conversion data to Customers, analyzing the use of the Services by end users in order to improve the marketing, analytics and functionality of the Services.
· Individuals who post content on Instagram that may be collected and used by Customer (social media users):
o We collect social media user name as well as public uploads and posts from social media sites (including publicly posted photographs and videos and associated Instagram URL, date/time of posting and metadata and caption associated with the posts). We use this data to contact social media users in order to request rights to use photos posted on Instagram.
We also collect and use the above data to provide our Customer with reports in aggregate form regarding the usage of their Site so that they can better understand the engagement of their end users who access and interact with their Site.
We collect and use the first and last name and email address of authorized employees and independent contractors of our Customers in order to provide and administer accounts necessary to access and use the Services.
We rely on our Customers to ensure that they have obtained all authority in accordance with applicable privacy laws for us to provide the Services on their behalf.
Information we collect and use
We collect and use information about Customers and other visitors to our Website (collectively, “you” or “your”).
If You sign-up for an account on our Website, we will collect your name, brand name, email address and password for the purposes of creating and administering your account with us. We may also use services provided by third-party platforms (such as social networking and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your information for such purposes, please contact us at helpme@foursixty.com.
If you sign-up to receive marketing communications from Foursixty, we collect your name and email address in order to send you e-mail regarding our products and services that we believe are of interest to you. You can unsubscribe at any time by following the unsubscribe instructions in the marketing communications you receive or by contacting us as set out below. Please note that you may continue to receive certain transactional and account-related messages from us.
If you apply for a job at Foursixty, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.
If you contact us with a question, comment or complaint, we may collect your name and business contact information (such as your email address or mailing address) in order for us to respond to your request.
Website Information and Analytics
In general, you can visit our Website without indicating who you are or submitting any personal information. However, we collect and/or maintain the IP (Internet protocol) addresses of all visitors to the Website, and other related information such as page requests, browser type, operating system and average time spent on the Website. We use this information to help us understand our Website’ activity and to monitor and improve the Websites and our Services.
Cookies & Similar Technologies: The Website uses a technology called “cookies”. A cookie is data that the Website can send to your browser, which may then be stored on your hard drive so that you can be recognized when you return. We use cookies on pages on the Website where you are prompted to log in or that are customizable. If you registered an account on the Website, these cookies may: (i) let us know who you are and identify your browser as one that has visited the Website before; and (ii) may be necessary to access your account information (stored on our computers) in order to deliver products and personalized services. We also use cookies to provide us and our service providers with information about your use of the Website that we will use to personalize the Website or other content in accordance with your interests and preferences and improve your user experience. You may set your web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Website, you may not be able to take advantage of all of the features of the Website.
Tracer Tags & Web Beacons: The Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on the Website. These tracer tags are used to help us optimize and tailor the Website for you and other future visitors to the Website.
Analytics: We use third-party
service providers to help us provide certain features on the Website and
analyze our visitors' preferences, such as Google Analytics. These third
parties may use cookies and similar technologies described above to collect and
analyze information about use of our Websites. Information we collect about the
use of the Website may include the pages most read, areas visited, time spent,
search terms and other engagement data on the Website. We use this information
in order to better understand and improve our Website and Services, including
the user experience and convenience of the Website. You can learn more about
Google Analytics here: http://www.google.com/
Links: The Website may contain links to other websites that we do not own or operate. Also, links to our Website may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.
Online Interest-Based Advertising
We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies, tracer tags, web beacons and pixel tags) on the Website in order to provide you with tailored advertisements on our behalf across the Internet (including on social media websites). These companies may collect information about your activity across your different devices on our Website and third-party websites (such as web pages you visit and your interaction with our advertising) and use this information to deliver ads that are more relevant and tailored to you on our Website and third party websites. This information may also be used to evaluate our online advertising campaigns
We
adhere to the Digital Advertising Alliance of Canada’s (DAAC) Self-Regulatory
Principles for Online Behavioural Advertising. To learn
more about this interest-based advertising practice and to understand your
options, including how you can opt-out of receiving interest-based ads from
participating third-party advertising companies, please visit the Digital Advertising Alliance website
at http://www.aboutads.info/
To successfully opt-out, you must have cookies enabled in your web browser. Please see your browser’s instructions for information on cookies and how to enable them. Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each device that you use. Once you opt out, if you delete your browser’s saved cookies, you may need to opt-out again.
Please note that even if you opt-out interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.
Social Media
We offer individuals the opportunity to engage with us on or through third-party social networking websites, plug-ins and applications. When individuals engage with our content on or through third-party social networking websites, plug-ins and applications, they may allow us to have access to certain information associated with their social media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application.
Google Drive
Available upon request (contact helpme@foursixty.com for pricing information), Foursixty can import content from Google Drive. After you grant the Foursixty app read-only access to your Google Drive account, you will be able to manage a list of folders visible to that account: Foursixty will monitor these folders for image and video files, and will transfer any such files to our Content Delivery Network for display in your Foursixty galleries.
By connecting your Google Drive account to Foursixty, you grant us permission to transfer and store your media files for the purpose of displaying your Foursixty galleries. To revoke this permission you may delete the associated Foursixty posts and/or networks, after which your content will be removed from our Content Delivery Network in a timely manner.
Transfers and Disclosures of Personal Information
Foursixty does not disclose, trade, rent, sell or otherwise transfer personal information, except as set out in this Privacy Policy.
Service Providers: In connection with our Websites or Services we may transfer personal information to third-party service providers who provide services on our behalf. For example, we may use service providers to host the Website, send email or other communications, process payments, and provide analytics and advertising services. Our service providers are given the information they need to perform their designated functions, and we do not authorize to use or disclose personal information for their own purposes. For additional information about the way in which our service providers treat personal information, please contact us as set out in the “Contact Us” section below. Personal information may be stored and processed by us or our service providers in Canada, the United States or other jurisdictions.
Sale of Business: We may disclose or transfer personal information to a third party as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Foursixty, or as part of a corporate reorganization or other change in corporate control.
Legal obligations: We, our affiliates and our Canadian, U.S. and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, to other organizations in the case of a breach of an agreement or contravention of law or for the purposes of detecting, preventing or suppressing fraud, or as otherwise required or permitted by applicable Canadian, US or other law (which may include lawful access requests by courts, law enforcement and government institutions in such foreign jurisdictions). We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property. Where a disclosure of our customers’ information is required by applicable law, we promptly notify our customer prior to complying with such requirements (to the extent we are not prohibited from doing so) and fully co-operate with our customer’s instructions with respect to our response.
Safeguarding
We maintain reasonable administrative, technical and physical safeguards in an effort to protect personal information in our custody and under our control against unauthorized access, use, modification and disclosure.
Retention of Information
We will retain our Customer’s personal information for as long as necessary to provide the Services. We also retain some of our Customer’s information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, and to support our business operations.
Where we retain information for business operations, service improvement and development, we take steps to make that information non-personal, non-identifiable and anonymous.
If you would like us to delete your Customer Information from our Services, please send a request to the contact information set out under the Contact Us section below.
Individual Rights Regarding Personal Information
If we receive a request from an individual to access, update or delete personal information we maintain on behalf of a Customer, we will direct that individual to the relevant Customer. We will assist our Customers wherever possible in responding to individual requests.
Subject to limited exceptions prescribed by law, you may otherwise request access, deletion, updating or correction of your personal information under our control by submitting a written request and satisfactory identification to Foursixty at the contact information set out under the Contact Us below.
We may require that you provide sufficient identification to fulfill your request. Any such identifying information will be used only for this purpose.
Changes to this Privacy Policy
This Privacy Policy may be updated periodically to reflect changes to our personal information practices. The revised Privacy Policy will be posted on this Website. We strongly encourage you to please refer to this Privacy Policy often for the latest information about our personal information practices.
Contact Us
Please contact Foursixty at helpme@foursixty.com with any questions or concerns that you may have about this Privacy Policy or the manner in which personal information is collected, used, disclosed and otherwise managed by Foursixty or our service providers.
Last updated: June 2nd, 2023