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We are 4 Walls Inc. (“4 Walls”, “we”, “us” and “our”). Among other things, we provide digital marketing and web services (collectively, the “Services”) to a variety of businesses (each, a “Company”) for use by the Companies, their personnel and their customers.

Each person or entity who uses our Services is referred to as a “user” or “you” or “your.” If you subscribe to any of our Services, we will refer to you as a “registered user”. If you don’t register with us, we will refer to you as an “unregistered user”. This Privacy Statement and our Terms of Service (“Terms”) apply to each user.

This document is our statement of our privacy practices (“Privacy Statement”). Among other things, it explains how we and the companies we work with collect, use, share and protect the information you and other users provide to us (“your Content” or “User Content”, as appropriate). The User Content may include any personally-identifiable information, including without limitation name, address, telephone numbers, electronic mail and postal addresses, personal health information, personal financial information, and other sensitive information that identifies or is uniquely associated with an individual (collectively, “Personal Data”). This Privacy Statement also discusses your choices about the collection, storage and use of your Personal Data.

Any Content that is not Personal Data is referred to as “Non-Personal Data.” Non-Personal Data includes information about how users use the Services, what Services users select, how users respond to service offerings, how users share information with others, what users say they like and dislike, all of which we aggregate into larger data sets that do not identify individuals (“Behavioral Data”).

Among other services, 4 Walls connects users with other companies in the industry (collectively, “Partners”). This Privacy Statement does not apply to any Partners or to any other websites, mobile applications, or businesses. This Privacy Statement does not apply to any Personal Data or other Content collected via any means other than the Services.

By using our Services, you consent to the collection, transfer, analysis, transformation, storage, disclosure and other uses of your Content, including your Personal Data, as described in this Privacy Statement.

  1. Data We Collect

As noted above, we collect Content from you while providing the Services on our behalf and on behalf of our Companies. Some of the Content is Personal Data that we and the Companies use to contact you and our Partners, and which is necessary to provide the Services. After all, we can’t provide individualized Services for you unless we provide your name and other Personal Data to the other party. Other Content we collect from you includes Behavioral Data and other Non-Personal Data that we aggregate, share, and use to improve our Services, the services of our Partners, and others in the industry.

We collect many different types of information from you, both directly and indirectly.

Data you provide us directly

Data we gather from your use of our Services

  1. How We Store Your Data
  1. How We Use Your Data

We share and use your Personal Data in the following circumstances:

  1. Your Right to Review, Request Changes, and Disclose Personal Data

Subject to applicable laws and regulations, each user may inspect and receive a copy of the user’s own Personal Data as stored in the Services. In rare circumstances, we may deny a request, and we may provide you with an explanation. If we deny your request, you may request a review by another professional, who will be chosen by 4 Walls, and we will comply with the outcome of the review.

Subject to applicable laws and regulations, the Personal Data you provide to us remains completely under your control. If you believe the Personal Data we have is incorrect or incomplete, you may in writing request an amendment to your Personal Data. We will approve or deny each request, and notify you of our decision. If approved, we will amend the Personal Data. We will also make a reasonable effort to notify people to whom the Personal Data was released. In the case of a denial, we will provide the reason for the denial and instructions on how to appeal.

Any information or User Content that you voluntarily disclose for use of the Services, such as your user name, your Personal Data or your User Content, may become available to the public if you release it to other users or to the general public. Once you have shared your Personal Data or your User Content with other people, other Companies, or otherwise made it public, that Personal Data and your User Content may be re-shared by others.

  1. Children

Our Services are not directed to persons under age 18. If you are the parent or guardian of a person under 18, and you become aware that your young person has provided us with Personal Data or User Content without your express consent, please contact us at legal@4walls.us and we will remove the information or User Content, and we will terminate the young person’s account.

  1. Changes to this Privacy Statement

We may modify our Privacy Statement from time to time by posting the revised version on our Services. We may also provide prior written notice sent to the email address we have for you. For any user who has not provided us with an email address, the revised Privacy Statement will become effective when posted on the Services. If you choose not to be subject to a revised version of this Privacy Statement, then you may terminate your account with us promptly after the revised version takes effect, and the unrevised version of the Privacy Statement will apply to you.

  1. Different Locations, Different Laws

The laws and regulations that address privacy rights and responsibilities (collectively, “Laws”) are different from one to another. Indeed, some of the Laws do or do not apply depending on different factors, including:

Several of the Laws that concern unregistered users, registered users, and 4 Walls are discussed in this Section, but these are not all of the Laws that may apply. In addition, if there is any conflict or ambiguity between the statements made in this Privacy Statement and an applicable Law, then the Law will control.

    1. United States Federal Laws

Several of the federal Laws in the United States may apply to the Personal Data collected by us.

Currently, all Personal Data of users resident in the United States is stored on servers and other machines physically located within the United States.

      1. Children’s Online Privacy Protection Act (“COPPA”)

Currently, COPPA does not apply to the Services. Each registered user and other user must be 18 years of age or older. As noted in this Privacy Statement, if we learn of any registered user or user is under the age of 18, or if any parent or guardian contacts us, we will close that person’s account and remove all information provided by the individual from our Services.

    1. State Laws in the United States

Individual states in the United States have passed and enforce information privacy and security laws.

7.3 Your California Privacy Rights

This section supplements the information contained elsewhere in our Privacy Statement and applies to all visitors, users, and others who reside in the State of California (“consumers”). This notice of privacy rights has been adopted in order to comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this notice. For further information about your rights under California’s privacy laws, see California’s Privacy Laws website at https://oag.ca.gov/privacy/privacy-laws.

You have the right under the CCPA and certain other privacy and data protection laws, as applicable, to exercise these rights free of charge.

7.3.1 Disclosure of Personal Data We Collect About You

7.3.1.1 You have the right to know:

Please note that we are not required to:

7.3.1.2 Disclosure of Personal Data Sold or Used for a Business Purpose

7.3.1.3 Disclosure of Personal Data to Third Party for Direct Marketing

7.3.1.4 Right to Deletion

7.3.1.5 Protection Against Discrimination

7.3.1.6 Categories of Data We Collect

Category

Collected

Business Purpose

Shared with 3rd party in past 12 months?

Sold to 3rd party in past 12 months?

      1. Identifiers, such as your name, IP address, email address

Yes

Required for the website’s functionality.

Yes

No

      1. Personal information categories in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as Social Security number, driver’s license or passport number, address, phone number, financial or medical information

Yes

Required for the website’s functionality.

Yes

No

      1. Characteristics of protected classifications under California or federal law, such as age, race, religion, military status. California provides a list of its classes at https://www.senate.ca.gov/content/protected-classes. The Federal EEOC provides a list of Federal classes at https://www.eeoc.gov/laws/types/

No

No

No

No

      1. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

No

No

No

No

      1. Biometric information

No

No

No

No

      1. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement

Yes

Improving the website’s functionality and ensuring security

No

No

      1. Geolocation data

Yes

Improving the website’s functionality and ensuring security

No

No

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

No

No

No

No

      1. Professional or employment-related information

No

No

No

No

      1. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)

No

No

No

No

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

Yes

Improving the website’s functionality and ensuring security

No

No

7.3.1.7 Why We Collect Your Personal Data

7.3.1.8 Parties With Whom We Share Your Personal Data

7.3.2 Your Right to Opt-Out

If you are a California resident 16 years of age or older, you have the right to opt-out from the collection and sale of your Personal Data. Please note that we do not sell your Personal Data, so no opt-out is required. As we’ve stated in the section titled “Children,” minors are not permitted to register to use our site.

7.3.3 Rights of Minors

As stated in the section titled “Children,” minors are not permitted to register to use our site. However, if you are a California resident under the age of 18, and a registered user of any site where this Privacy Statement is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email or letter with a detailed description of the specific content or information to the addresses provided in the section below titled “How to Exercise Your Rights”. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal, even if requested.

By submitting any Personal Data or other User Content to us, or placing any order with us, you consent to the storage, processing, use and onward transfer of your Personal Data and User Content to us in the United States.

7.3.4 How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy and Policy Statement, please:

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

7.3.5 Verifying Your Identity

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

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

  1. Use of Email Addresses and Other Contact Data

We collect the email addresses of those who voluntarily provide them to us, including unregistered users and registered users.

  1. Contact Us

If you have questions or concerns about this Privacy Statement, please contact us online at legal@4walls.us, or by postal mail addressed to:

Attn: Privacy, 4 Walls Inc., P.O. Box 248, Narberth, Pennsylvania 19072, USA.

  1. Revision Date and History

These Terms were last revised: May 8, 2020.

Prior versions of this Privacy Statement are listed below:

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