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
- Registration information. When you create or modify an account, or subscribe to our Services, you provide Personal Data to us, such as your user name, password, postal address and email address.
- Profile information. You may provide us with additional profile information that you choose to make public or share with other users. You may also provide information to customize your account, such as a telephone number for the delivery of short message system (“SMS”) or text messages. We may use your contact information to send you information about our Services, any orders you place, or to market to you. You may use your account settings to customize notifications from us. If you email us, we may keep your message, email address and contact information to respond to your request.
- Location Data. We may ask for your postal address or your geographic location information, especially if you place an order for Services with us. When you post User Content to our website or to social media, you may provide your location information, including global positioning system (“GPS”) data or other location information embedded in or accompanying the User Content (e.g., in tags or captions).
- Communications between you and 4 Walls: We may send you emails, SMS or text messages, and other electronic communications for sales and delivery, account verification, notices of changes/updates to features of the Services, technical and security notices, and for other purposes. We may collect and store these communications.
Data we gather from your use of our Services
- We collect and may save private emails sent to us by users, and we may share your emails with any third parties or other users. Any public posts on Services may be viewed by any user and is public to anyone who visits the Services. You may elect to disclose certain Personal Data and Non-Personal Data. The information you submit in any public forums is not confidential or private, and 4 Walls does not protect it. All information you choose to provide publicly, including information that identifies you or others, can be read, collected, or used by other users and by other third parties, and could be used to send you unsolicited messages and for other
- We use third-party analytics tools to help us measure traffic and usage trends and other Non-Personal Data for the Services. These tools collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving our Services. We collect and combine this analytics information with analytics information from other users so that it cannot be used to identify any particular individual user.
- Metadata is usually technical data that is associated with other data, including User Content. For example, metadata can describe how, when and by whom an item of User Content was collected and how that User Content is formatted. 4 Walls may collect and store metadata, including about each user’s public posts on the Services.
- 4 Walls may keep track of how you interact with links across our Services, including our email notifications and third-party Services by redirecting clicks or through other means. We do this to help improve our Services, to provide more relevant local data, and to be able to share aggregate click statistics such as how many times a particular link was clicked on.
- Device Identifiers. We may access, collect, monitor, store on your device, or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your computer, phone or other device, which uniquely identifies your device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by 4 Walls. A device identifier may deliver information to us or to a third-party partner about how you browse and use the Services and may help us or others provide reports or personalized Content and ads. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.
- Log Data. Our servers automatically record information (“log data”) created by your use of the Services. Log Data may include information such as your Internet Protocol (“IP”) address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. We receive log data when you interact with our Services, for example, when you visit our website, sign into our Services or interact with our email notifications. 4 Walls uses log data to review how we provide our Services and to measure, customize, and improve the Services.
2. How We Store Your Data
- We provide the Services from within the United States, and we store all User Content, including Personal Data, that we currently collect and retain on servers inside the United States.
- In the future, we may store Personal Data and other User Content on servers located outside the United States.
- Certain types of User Content you submit to us might reveal your gender, ethnic origin, nationality, age, religion, sexual orientation, or other Personal Data about you or others.
- By using our Services, or by submitting your personal Data to us, you consent to the collection, storage, processing and onward transfer of your personal Data as stated in the current version of this Privacy Statement and the current version of our other online documents, including the Terms of Service.
3. How We Use Your Data
We share and use your Personal Data in the following circumstances:
- Opt-in with Your Consent. We may ask for your permission to share your Personal Data with other people, other Companies, and organizations outside of 4 Walls, including to help conduct studies or provide you with other services. As with any opt-in procedure, you are under no duty to agree to a request that you opt-in.
- Partners and Affiliates of 4 Walls. We may share your Personal Data with Partners and with our 4 Walls affiliates (meaning entities controlled by, controlling or under common control with 4 Walls) as necessary to sell and provide the Services. However, any Personal Data stored in one country or jurisdiction would not be forwarded to another country or jurisdiction, except in compliance with applicable laws and regulations.
- Opt-out Email or Postal Address. If you supply us with your postal or email address you may receive periodic mailings from us with information on current and new products and services, or upcoming events. If you do not want to receive such mailings, please let us know by sending an email to us at the “opt-out” address, below. We will remove your name from the list we use internally. Opting-out of these emails does not mean we remove your email from our system entirely, because we still retain your email addresses for other purposes.
- Service Providers. We employ third party companies and individuals to facilitate our Services (e.g., payment processing, maintenance, analysis, audit, marketing and development). These third parties may have limited access to your Personal Data only to perform these tasks on our behalf.
- Required by Law. We may access, preserve and share your Personal Data in response to a legal request (like a search warrant, court order or subpoena). We may also access, preserve and share Personal Data when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Data we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent
- National Security and Intelligence Activities. We may release your Personal Data to authorized federal officials for intelligence, counterintelligence and other national security activities when required by law. For example, under current law in the United States, certain federal officials may require that we provide Personal Data and other User Content in response to a national security letter, subpoena, demand, or court order. In some cases, we would be required not to tell you that we complied with that letter, subpoena, demand, or court order. Where permitted by applicable law, we reserve the right to comply with, or to fight or quash, any such letter, subpoena, demand, or court order.
- Change of Control. If we sell or otherwise transfer part or the whole of 4 Walls or our assets to another organization (e.g., in a merger, acquisition, or reorganization), your Personal Data such as user name and email address, User Content and any other information collected through the Services may be among the items sold or
- Non-Personal Data. We may share Non-Personal Data publicly and with publishers, researchers or connected sites. For example, we may share aggregated Non-Personal Data publicly to show trends about the general use of our Services. Non-Personal Data includes aggregated or collective information about multiple users that does not reflect or reference an individually-identifiable user.
- Additional Uses. In addition to some of the specific uses of information we describe in this Privacy Statement above, we may use Personal Data that we receive to:
- Help you efficiently access your information after you sign in.
- Remember information so you will not have to re-enter it during your visit or the next time you visit the Services.
- Provide personalized Content and information to you and others, which, in the future, could include online ads or other forms of marketing.
- Provide, improve, test, and monitor the effectiveness of our Services. develop and test new products and features.
- Monitor metrics such as total number of visitors, traffic, and demographic patterns. diagnose or fix technology problems.
4. 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.
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 firstname.lastname@example.org and we will remove the information or User Content, and we will terminate the young person’s account.
6. 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.
7. 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:
- Location or residence of the user.
- Location or residence of the individual that is the subject of the Personal Data (“Data Subject”).
- Location or residence of the person or organization that employs or contracts with the Data Subject.
- Location of each server or other machine where the Personal Data is received, stored, processed or forwarded to.
- Location of the relevant office of 4 Walls.
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.
7.1 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.
7.1.1 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.
7.2 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
220.127.116.11 You have the right to know:
- The categories of Personal Data we have collected about you;
- The categories of sources from which the Personal Data is collected;
- Our business or commercial purpose for collecting or selling Personal Data;
- The categories of third parties with whom we share Personal Data, if any; and
- The specific pieces of Personal Data we have collected about you.
Please note that we are not required to:
- Retain any Personal Data about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Data; or
- Provide the Personal Data to you more than twice in a 12-month period.
18.104.22.168 Disclosure of Personal Data Sold or Used for a Business Purpose
- In connection with any Personal Data we may sell or disclose to a third party for a business purpose, you have the right to know:
- The categories of Personal Data about you that we sold and the categories of third parties to whom the Personal Data was sold; and
- The categories of Personal Data that we disclosed about you for a business purpose.
- We have provided a table of this information below.
22.214.171.124 Disclosure of Personal Data to Third Party for Direct Marketing
- If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Data by us to third parties for the third parties’ direct marketing purposes. To make such a request, see the section “How to Exercise Your Rights”, below.
- Pursuant to California Civil Code Section 1798.83(c)(2), we do not share users’ Personal Data with affiliate companies or others outside 4 Walls for those parties’ direct marketing use, unless a user elects that we do so.
126.96.36.199 Right to Deletion
- Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your Personal Data from our records; and
- Direct any service providers to delete your Personal Data from their records.
- Please note that we may not delete your Personal Data if it is necessary to:
- Complete the transaction for which the Personal Data was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with an existing legal obligation; or
- Otherwise use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information.
188.8.131.52 Protection Against Discrimination
- You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide a different level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
- Please note that we may charge a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to you by your Personal Data.
184.108.40.206 Categories of Data We Collect
- The CCPA defines Personal Data as “information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.” The Services collect Personal Data, Non-Personal Data, and Behavioral Data, which could potentially be combined to become Personal Data.
- This list provides categories of Personal Data and indicates whether we collect this data, the commercial or business purpose behind the collection, and whether the PI is shared with, or sold to, a third party.
|Category / Business Purpose||Collected||Shared in past 12 months?||Sold in past 12 months?|
A. Identifiers, such as your name, IP address, email address
Purpose: Required for the website’s functionality.
B. 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
Purpose: Required for the website’s functionality
C. Characteristics of protected classifications under California or federal law, such as age, race, religion, military status. California provides a list of its classes. The Federal EEOC provides a list of Federal classes at https://www.eeoc.gov/laws/types/
D. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information
F. 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
Purpose: Improving the website’s functionality and ensuring security
G. Geolocation data
Purpose: Improving the website’s functionality and ensuring security
H. Audio, electronic, visual, thermal, olfactory, or similar information
I. Professional or employment-related information
J. 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)
K. 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.
Purpose: Improving the website’s functionality and ensuring security
220.127.116.11 Why We Collect Your Personal Data
- We use your Personal Data for the following reasons:
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- Debugging to identify and repair errors that impair existing intended functionality;
- Short-term, transient use, provided the Personal Data that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
- Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider;
- Undertaking internal research for technological development and demonstration; and
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
18.104.22.168 Parties With Whom We Share Your Personal Data
- We routinely share Personal Data with:
- our affiliates;
- service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies;
- other third parties we use to help us run our business, such as marketing agencies or website hosts;
- third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
- credit reporting agencies; and
- our insurers and brokers.
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
- Call us, toll-free, at (800) 492-5570 x 730; or
- Email us at email@example.com; or
- Write to us at Attn: Privacy, 4 Walls Inc., P.O. Box 248, Narberth, Pennsylvania 19072, USA.
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:
- Enough information to identify you (e.g., your full name and address)
- 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
- 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 Data we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
8. 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.
9. Contact Us
If you have questions or concerns about this Privacy Statement, please contact us online at firstname.lastname@example.org, or by postal mail addressed to:
Attn: Privacy, 4 Walls Inc., P.O. Box 248, Narberth, Pennsylvania 19072, USA.
10. Revision Date and History
These Terms were last revised: May 8, 2020.
Prior versions of this Privacy Statement are listed below:
- December 5, 2017
- June 16, 2011