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
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”).
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):
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):
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.
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
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.
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 firstname.lastname@example.org.
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
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
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.
Information and Analytics
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
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
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
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/policies/privacy/partners/
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
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.
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
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/choices/ or the Digital Advertising
Alliance of Canada website at www.youradchoices.ca/choices.
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.
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.
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.
and Disclosures of Personal Information
does not disclose, trade, rent, sell or otherwise transfer personal
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
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.
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.
we receive a request from an individual to access or update 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 access requests.
to limited exceptions prescribed by law, you may otherwise request access,
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 Contact Us below.
for the latest information about our personal information practices.
contact Foursixty at email@example.com with any questions or concerns that
information is collected, used, disclosed and otherwise managed by Foursixty or
our service providers.
Last updated: July 4th, 2018