Privacy Policy

Effective: October 1, 2023

This Privacy Policy (the “Policy” or the “Privacy Policy”) is entered into by and between Four Pillars, Inc. and its affiliates (collectively referred to as the “Company,” “we,” “us,” or “our”). This Privacy Policy governs your use of the Company’s websites, mobile applications (“apps”), social media pages, or any other products or services offered by us (collectively, the “Services”). We are committed to protecting your privacy and providing transparency about how we collect, use, and protect any information that you provide to us when using our Services.

By using or accessing our website located at https://4pillars.io (the “Website”) or any of our Services in any manner, you acknowledge and agree to accept the practices and policies outlined in this Privacy Policy. Furthermore, you hereby consent to the collection, use, and sharing of your information as described herein.

Your use of the Website or the Services is at all times subject to the provisions of the Terms of Use. Any terms used in this Policy that are not defined herein shall have the meanings ascribed to them in the Terms of Use.

[1] OVERVIEW

[1.1] Scope of Policy.

This Privacy Policy governs the treatment of personally identifiable information (“Personal Information”) collected during your access or use of our Website or Services. We collect various types of Personal Information and employ it internally to provide, enhance, and personalize our Services. This includes user account setup, profile management, communication facilitation, fulfillment of product or service requests, and Service usage analysis. In specific instances, we may share select Personal Information with third parties, subject to the provisions below.

[1.2] Links to Third Party Services.

The Website and our other Services may contain hyperlinks to external third-party websites, applications, and services (“Third Party Services”) of potential interest. We disclaim control over such Third Party Services, and this Privacy Policy does not extend to them. Consequently, we accept no responsibility for safeguarding or preserving any information provided by you while visiting Third Party Services, as they operate under distinct privacy policies. You are encouraged to exercise caution and review the privacy statements governing the relevant Third Party Services.

[2] COLLECTION OF YOUR INFORMATION

[2.1] General Information

We collect information regarding your interactions with us through various channels, including direct submissions by you, automatic data collection, and data obtained from external sources, which may encompass data from other organizations, publicly available information, household information, or supplementary data that we may merge or align with the information collected or received by us. Your information, depending on your usage of our Services, may encompass, but is not limited to:

1. Registration: We gather information related to registration including but not limited to your name, addresses, email addresses, telephone numbers, occupation, and data granted to us through social login permissions.
2. Usage Data: We gather usage-related data automatically or through third-party services. This includes details about the Services you use, frequency of use, public posts via our Services, responses to our offerings and advertisements, collectively referred to as "Usage Data."
3. Technical Information: We collect technical data, such as browser and operating system specifics, Internet connection methods, IP addresses, referring and exiting websites or services, malfunction reports, and software information on your device (for security and improvement purposes).
4. Search Information: We collect data related to searches performed on our Website or Services, as well as your interactions with search results.
5. Transaction Information: We gather details concerning payment methods, billing information, credit card data, billing addresses, and purchase history via our Services.
6. Access Information: We gather information about devices, connections, and methods used to access and interact with our Services.
7. Communication Information: We collect information from text messages, emails, faxes, telephone calls, postal mail exchanges with users of our Services, and third-party sources, including database vendors.
8. Customer Service Information: We collect data regarding your user experience with our Services.

[2.2] Automatic Data Collection

Whenever you engage with our Services, we automatically obtain and record information from your device or browser. This Usage Data may include IP addresses, domain names, URI addresses, request times, submission methods, response details, country of origin, browser and operating system features, visit duration per Service page, page sequence, device, IT environment parameters, conversion data, marketing statistics, reports, analytics, reviews, and surveys. While Usage Data is often anonymous or aggregated upon collection, it may indirectly identify individuals.

[2.3] Tracking Preferences

To prevent potential miscommunications between browsers and our services, we do not support "Do Not Track" signals or requests at this time. We reserve the discretion to reevaluate our ability to honor "Do Not Track" signals as technology and communication between browsers and websites progress. You have the option to adjust your browser or operating system settings to restrict tracking or decline cookies. Nonetheless, such adjustments may limit your access to specific service features or hinder full utilization of our offerings. Consult your browser or operating system's "Help" menu for guidance on modifying tracking settings or cookie preferences. On mobile devices, you can configure privacy and advertising settings to control tracking for advertising or manage the receipt of more relevant advertisements. Please be aware that our systems may not detect "Do Not Track" headers or requests from certain browsers.

[2.4] Personal Data

In some regions, including the European Economic Area (EEA), specific elements of information as outlined in Sections 2.1 and 2.2 may be classified as “personal data” under applicable data protection laws. For further information, please review Section 7.

[3] USE OF YOUR INFORMATION

[3.1] Purpose

1. Service Operation and Enhancement: Your information serves various purposes, including, but not limited to, operating and improving our Services, fulfilling your requests for tools, software, features, and products.
2. Usage Data Analysis and Research: We analyze Usage Data to better serve visitors and end users, customize Services based on preferences, and compile statistical insights about Service use.
3. Content Curation: We tailor content based on your interactions, offering relevant products, features, services, personalized content, advertisements, and partner offers.
4. Marketing: We use your information for communication, responding to inquiries, and marketing efforts.

[3.2] Cookies

We employ technologies like cookies, flash cookies, local shared objects, web beacons, pixels, single pixel GIFs, and clear GIFs in conjunction with your information to enhance your experience and collect data for Service optimization. You may configure your browser or device settings to restrict cookie acceptance, but this may limit access to certain features. Third-party cookies are not covered by this Policy, and we disclaim responsibility for their privacy statements or practices.

Our use of cookies includes:

1. Session Cookies: Active during an online session and expire when you close your browser, facilitating unique identification during your session or while logged in.
2. Persistent Cookies: Remain on your device after browser closure, tracking aggregate user activity and displaying third-party site ads.
3. Advertising Cookies: Personalized online ad delivery, assigning pseudonymous IDs to track served ads and user clicks. Opt-out options are available.
4. Analytics Cookies: Compile aggregate site traffic and interaction data to enhance future website features and tools. These analytics cookies typically do not access personal information. Third-party service providers may assist in analytics services, subject to contractual limitations on personal data usage. We use Google Analytics for these services, with opt-out options at https://tools.google.com/dlpage/gaoptout.

[4] SHARING OF YOUR INFORMATION

[4.1] General Disclosure Policy

We do not lease or sell your Personal Information (e.g., name, address, telephone number, credit card details) to third parties for marketing purposes. We may share your information with select third parties to fulfill your requested products and services, with your consent, or as delineated in this Policy. Personal Information disclosure is subject to the conditions detailed below. Usage Data, on the other hand, may be disclosed without limitations.

[4.2] De-Identified Information

We may transform your Personal Information into a format where individual identification is not possible (de-identification). This aggregated, non-personally identifiable information may be shared publicly or with partners such as publishers, advertisers, or affiliated websites. For instance, we might publicly share information to illustrate general trends in our Website and/or Services’ usage. We never disclose aggregate or de-identified information in a manner that could identify you as an individual.

[4.3] User Profiles and Submissions

Specific user profile details (including, but not limited to, name, location, and user-uploaded text, images, or videos) may be viewable by other users to facilitate interactions or cater to your Service requests. Account privacy settings may permit you to restrict which users can access Personal Information in your user profile and what aspects of your user profile are visible to others. Please be aware that any content uploaded to your public user profile, along with voluntarily disclosed online content or Personal Information viewable by other users (e.g., on discussion boards, in messages or chat areas, etc.), becomes publicly accessible and may be indexed by search engines, copied, forwarded, saved, or archived by anyone. Your username may also be visible to other users when you send messages, make comments, upload text or images, or share features publicly (e.g., a public watchlist) through the Services, potentially enabling other users to contact you via messages or comments.

[4.4] Affiliated Entities

We reserve the right to share your personal information and Usage Data with affiliated entities, including our subsidiaries. Affiliated entities are those either under our control or controlling us.

[4.5] Business Partners

Business partners or other third parties may receive data concerning groups of our users, but they do not receive information that personally identifies you unless otherwise stated herein. On occasion, businesses or third-party websites with which we maintain affiliations may offer products or services to you through or in conjunction with our Services, either independently or jointly with us. These affiliated businesses will be clearly identified as such. We may disclose your Personal Information to these affiliated businesses only to the extent relevant to such transactions or services; however, we do not sell your personal information to third parties for their marketing pursuits. We have no control over the policies and practices of third-party websites or businesses, including matters related to privacy. Therefore, if you choose to partake in any transaction or service linked to an affiliated website or business, we recommend reviewing all associated policies.

[4.6] Service Providers

We reserve the right to grant access to your personal information and Usage Data to trusted service providers who aid us in managing and operating our sites and services. We may engage third parties to process payments, host our servers, ensure security, and deliver production, fulfillment, optimization, analytics, and reporting services. We will exert commercially reasonable efforts to ensure that our service providers access your information only to the extent essential for fulfilling their contracted services. Please note that we may embed Google Analytics trackers to gather user information and Usage Data using cookies or data stored in separate storage pursuant to Section 3.2 of this Privacy Policy. You may opt out of Google Analytics' tracking, where applicable, at any time

[4.7] Co-Marketers, Cross-Promotion, and Sponsorships

We may collaborate with other companies or individuals to jointly promote our products, services, promotions, or contests, as well as theirs. For these purposes, we may share Personal Information with them, covering:

1. Compensation, Transaction Processing, Fulfillment, and Support: Sharing information necessary for compensation, transaction processing, order fulfillment, and customer support.
2. Offering Additional Products, Services, Promotions, or Contests: These marketing partners may also reach out to you regarding other related products, services, promotions, or contests.

[4.8] Business Transfers and Successors

In the course of evaluating and engaging in asset transactions, we may opt to purchase or sell assets, potentially involving the sharing or transfer of customer information. Furthermore, if we (or our assets) are acquired, undergo changes in control, file for bankruptcy, or cease operations, Personal Information could be among the assets transferred to or acquired by a third party. In the event such actions lead to a material change in how your information is used, you will receive notification (possibly via updates to this page) regarding the option to refuse such a transfer.

[4.9] Legal Process, Enforcement, and Security Notice

We reserve the right to access, review, safeguard, and disclose any Personal Information under the following circumstances:

1. Legal Compliance: Complying with applicable laws, regulations, legal proceedings, or enforceable governmental requests (e.g., responding to subpoenas or court orders).
2. Fraud Prevention and Criminal Activity: Detecting, preventing, and addressing fraud or other unlawful activities.
3. Rights Protection and Security: Investigating, responding to, or enforcing breaches of our rights, security concerns within our Website and Services (including agreements and Terms of Use), or those pertaining to the Company, our employees, or our users.

[5] ACCESS TO AND CONTROL OF YOUR INFORMATION

[5.1] Accessing Your Information

Changes to our Services may affect the information available for you to view, update or delete. You can access, and in certain instances, modify or delete the following information you've supplied to us through your account settings:

1. Account Credentials: Your account email address and password.
2. Identity Information: Your identifying name, username, or legal name.
3. Location: Your designated location.
4. User Profile Content: Information encompassing text, images, and other content you may have uploaded to the Website.

[5.2] Choices Regarding Your Information

You have the option to control the collection and usage of your Personal Information through the following means:

1. Information Submission: When prompted to complete a form on our Website or other Services, consider which information to include or exclude. You may sometimes encounter a checkbox that permits you to indicate your preference for or against the use of your information for direct marketing purposes.
2. Account Settings: We may provide access to your registration information and the ability to edit such details within your account settings dashboard and profile pages. Please note that even if you delete or update information within our Services, residual copies may not be promptly removed from our active servers or backup systems. Additionally, certain information may remain indexable by search engines (including public profile information) and may not be automatically updated by such search engines when we make changes. Old versions of your information may be archived by these search engines or third parties beyond our control.
3. Service-Specific Privacy: You should also review some of our Services that may provide additional information and choices concerning your privacy.
4. Direct Marketing Preferences: If you had previously consented to the use of your Personal Information for direct marketing purposes, you retain the right to revise your preferences at any time by contacting us through the provided contact information below. Any aggregated data derived from or incorporating your Personal Information may still be employed after you update or delete it; however, such use will not lead to your personal identification.

[5.3] Legal Basis for Data Processing

Our grounds for collecting and utilizing your Personal Information are as follows:

1. Consent: We collect and use your Personal Information with your consent, which you can withdraw at any time.
2. Contractual Necessity: When we need your Personal Information to fulfill a contract or provide a requested service.
3. Legitimate Interests: In cases where the collection and use of your information align with our or another party's legitimate interests, and this does not override your data protection rights or fundamental freedoms.
4. Legal Obligation: When we have a legal obligation to collect specific Personal Information. You acknowledge and agree that we may collect, use, disclose, and process any information you provide, regardless of your location, including if you are outside of the United States.

[6] ADDITIONAL SAFEGUARDS

[6.1] Protection for Children

The Children's Online Privacy Protection Act ("COPPA") mandates that online service providers must obtain parental consent before knowingly collecting personally identifiable information from children under 13 online. We do not knowingly collect or request personally identifiable information from children under 13. If you are under 13, please refrain from attempting to register for our Services or submitting any Personal Information about yourself to us. If we become aware that we have collected Personal Information from a child under 13, we will promptly delete such information. If you suspect that a child under 13 may have provided us with their Personal Information, please contact us.

[6.2] Special Notice for California Users

We may share your Personal Information with third parties and affiliated third parties (such as local, state, and regional affiliates, and affiliate alliances) for their direct marketing purposes. Since these third parties and affiliated third parties fall under the definition of an &quote;unaffiliated party&quote; according to California law, California residents have two options:

1. Opt-Out: Decline our disclosure of Personal Information to third parties for their direct marketing purposes or
2. Request Information: Request a notice that identifies the categories of Personal Information shared with affiliates or third parties for marketing purposes, along with contact information for these affiliates or third parties. This request aligns with California's &quote;Shine the Light&quote; law (California Statute § 1798.83). To exercise these rights or receive the mentioned notice, please contact us using "support@4pillars.io".

[7] FOR USERS FROM THE EUROPEAN ECONOMIC AREA (EEA) AND THE UNITED KINGDOM (UK)

[7.1] Legal Basis for Data Processing

If you are a European resident, our reasons for collecting and using your personal data or information are as follows:

1. Consent: We collect and use your personal data or information with your consent, and you can withdraw it at any time.
2. Contractual Obligation: When we need your personal data or information to fulfill a contract.
3. Legitimate Interests: When the collection and use of personal data or information align with our legitimate interests and do not override your data protection rights.
4. Legal Obligation: In cases where there is a legal obligation to collect specific Personal Information. If your personal data was collected with your consent, you have the right to withdraw it at any time. We retain your personal data and may contact you based on our legitimate interest in providing you with relevant materials, considering factors like your location, role, or company. You can always opt out of receiving future communications. When we transfer Personal Information from the EEA or the UK to a jurisdiction outside of these areas without an adequate data protection determination by the European Commission (e.g., the United States), we ensure its protection through appropriate contracts or other approved methods.

[7.2] Additional Rights

If you reside in the EEA or the UK, you have the following rights:

1. Information Access: Learn if we use your Personal Information, access it, and obtain copies of your Personal Information.
2. Data Correction: Update or correct your personal data, and request to have it corrected or amended if such data or information are deemed to be inaccurate or incomplete.
3. Withdraw Consent: Withdraw your consent for Personal Information processing, including deletion, if we lack other legal grounds.
4. Data Processing Restrictions: Restrict the processing of your Personal Information if you believe it's inaccurate, no longer needed for our business purposes, or object to our processing (pending our investigation and confirmation of such claim).
5. Data Portability: Request the transfer of your Personal Information to another provider.
6. Object to Automated Decisions: Object to automated decision-making.
7. Complaints: Send complaints to your local data protection authority at any time.

[8] INFORMATION SECURITY

[8.1] Our Security Commitment

We have implemented reasonable safeguards to safeguard the information we collect. These measures are designed to prevent loss, misuse, unauthorized access, disclosure, alteration, or destruction of your data. However, we can't guarantee that your information will never be disclosed in a way that doesn't align with this Policy. For example, if unauthorized third parties violate the law or policies, your data may be at risk. Remember, despite our efforts, no security system can ensure absolute protection.

[8.2] Your Responsibilities

Your account's security relies on a password to maintain your privacy and safety. We might use passwords and other technologies to register or verify you and enable our Services. To safeguard your account and Personal Information, please make sure to:

1. select a strong password and keep it safe and
2. be cautious with your computer, device and browser access, and
3. sign out promptly once done.

If your password is lost, stolen, or compromised, or if unauthorized activity occurs on your account due to password issues, we are not liable for such situations.

[9] DATA STORAGE AND RETENTION

[9.1] Where Your Data Is Stored

Your Personal Information is stored and processed on servers maintained by AWS in Seoul, South Korea. It may also be processed in other countries by our service providers, provided that it complies with applicable laws. Regardless of your location, you understand and agree that the Company may collect, use, disclose, and manage your information as outlined in this Policy. In certain situations, your Personal Information may be disclosed in response to government inquiries, requests, or judicial processes in South Korea. We will retain your Personal Information for as long as necessary to provide you with our Services or fulfill any legal or contractual obligations we may have.

[9.2] Special Note for EEA Users

If you are an EEA user, please note that your Personal Information will be transferred to and processed on servers maintained by AWS in Seoul, South Korea. South Korea may have different data protection laws compared to your home country, and they may not offer the same level of protection.

[10] GENERAL

[10.1] Contacting Us

If you have questions or concerns about this Privacy Policy or its implementation, you can reach out to us at "support@4pillars.io". If you believe your information is incorrect, we will provide ways for you to promptly update or remove it, unless we are required to retain that information for legitimate business or legal reasons. For identity verification purposes, we may request you to confirm your identity before addressing your request. Please note that we may reject requests that are excessively repetitive, pose privacy risks to others, involve disproportionate technical efforts (e.g., developing a new system), or are highly impractical (e.g., requests for information stored in inaccessible backup storage).

[10.2] Changes to this Policy

We may periodically update our Privacy Policy, so it's a good practice to review it occasionally. We may notify you of changes through the Website, email notifications, or other means. Even if you choose not to receive legal notice emails from us or haven't provided your email address, these legal notices will still govern your use of the Services. You are responsible for reading and understanding the Policy, and by continuing to use the Services, you accept any such changes.