Last Updated: July 29, 2021.

1. Introduction

We (4Sided, INC, or “4Sided”) collect, use, and otherwise process various kinds of information from or about you or your device, including your personal information, to provide you with our Services. As used in this Privacy Policy, “Services" means the services provided by 4Sided for discovering, assessing, and interacting with its services, including its mobile applications (“App”), its websites (“Website”), and its marketing campaigns.

We may use all personal information in the manner described in this Privacy Policy.

If you do not consent to the collection and use of personal information in accordance with this Privacy Policy, then do not use the Services.

2. Information We Collect

4Sided may collect the following categories of personal information from the sources identified below:

a. Information you actively provide to us: We collect the information you actively provide to us, which may include personal information. For example, when you create an account with 4Sided, you will be asked to provide your name, email, and address. We may also collect information you submit through other means including email lists, customer service, surveys, contests, promotions, comments directed to us, and your settings.

b. Usage and log data: We collect information when you use and interact with the Services. For example, we may collect your IP address, device type, device language setting, screen size, device identifiers, advertising identifiers, mobile carrier, browser type, and your actions in the Platform.

c. Data collected through cookies and similar technologies: We use cookies and similar technologies to help collect usage information and store your preferences. For more information about cookies visit our Cookies and Similar Technologies Notice. We do not currently respond to browser do-not-track signals because there is currently no consensus among the industry as to what “Do Not Track” signals mean and how to respond to them.

d. Data from other parties: We work with other parties to support our Services, better reach potential users, to monetize our Services, and for other reasons as described below. These parties may send us information about you, your device, or browser (such as demographics and online history) for the purposes described in this Privacy Policy. For example, we may receive information on when you click on the links in the emails we send you so we can better optimize our messaging.

3. Use of Information We Collect

a. Use of Personal Information:

We use the categories of personal information listed above for the following purposes:
• providing the functionality of the Services and fulfilling your requests;
• contacting you, including for promotional purposes;
• enabling interactive content and advertising;
• improving our Services and developing new products and Services;
• business reporting and analysis, including compiling aggregate or anonymized data;
• fraud and security monitoring;
• conducting research;
• facilitating social sharing, including deep-linking;
• protecting the rights of you, our other users, and us;
• customer support;
• managing payments, subscriptions, and free trials;
• performing obligations and exercising rights under our Terms of Service and this Privacy Policy; and
• any other purpose that is disclosed to you at the time we collect the information or that is related to a request made by you.

We will engage in these activities to manage our contractual relationship with you; to comply with a legal obligation; where we have a legitimate interest in doing so; to protect the vital interests of you, other users’, or 4Sided staff; or with your consent.

b. Use of Aggregated or De-Identified Information:

We may collect and use information that is not reasonably linked to an individual, device, or household for any purpose. This includes aggregated or de-identified personal information.

4. Sharing Information with Third Parties

We may share your personal information as follows:

a. Service providers: We may share personal information with third-party service providers for them to facilitate services they provide to us, e.g., the use of a vendor’s software, integration with third party platforms, or embedding SDKs or tags in the App or Website. These services include things like website hosting; data storage; data analysis; personalized advertising, ad measurement and verification; conversion tracking; social sharing; payment processing; order fulfillment; information technology and related infrastructure provision; customer service; email and notifications delivery (including marketing messaging); and auditing.

b. For legal reasons: We may share personal information as we believe necessary or appropriate to comply with applicable laws and regulations; to cooperate with law enforcement; to enforce our terms and conditions; to protect our rights, privacy, safety, or property and/or that of our affiliates, you, or others; to prevent or take action regarding possible illegal activities or a violation of our policies; or for other legal reasons. These obligations may arise from laws or requests from authorities outside your country of residence.

c. In connection with a sale or business transaction: We may disclose or transfer your personal information to a potential or actual buyer in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), including any due diligence related to such a transaction, in accordance with applicable law.

d. With your consent or when you otherwise choose to share: We may share personal information with any party when we have your consent or when you otherwise choose to share such information, for example by using our social sharing functions or participating in contests (which may have their own terms).

5. Security

We use organizational, technical, physical, and administrative data security measures intended to protect personal information within our organization. Note that if you allow others to access your account, they may be able to view information about or stored within your account, including what content you’ve viewed.

6. Advertising

a. Ads for 4Sided

We advertise 4Sided on publishers such as Facebook, Snapchat, and YouTube. When you use 4Sided or view a 4Sided ad on one of those publishers, whether or not you click on it, 4Sided, publishers, and other service providers that perform advertising-related services for us may collect personal information. We may also send them personal data for help optimize and measure our ad campaigns. Publishers may use personal information to optimize the kinds of ads you see and may offer choices about the way they handle personal information. For example, to learn about how Google processes your personal information in relation to serving ads and what choices you may have, visit their site here.

b. Ads on 4SidedIf you are subscribed to an ad-supported plan, the ads you see may be tailored for you based in part on the personal information we collect from your use of the Services (e.g. your year of birth), as well as information we receive from third parties. Under these plans, you cannot opt out of seeing ads or from having us measure your engagement with the ads, but you can opt out of certain ad targeting based on your activity outside of the 4Sided App or Website. To opt out of that kind of ad targeting, see the Choices section below.

7. Choices

You have the following choices when it comes to our use of your personal information:

a. Ad Targeting
‍
• Opt Out of Advanced Ad Personalization
         • On the ad-supported version of 4Sided, we will always personalize ads based on your interactions with the app. When Advanced Ad Personalization is enabled, we may further personalize ads based on your activities outside of 4Sided and permit our partners to use your data to improve their services. To opt out of this activity, please visit the settings of the 4Sided app, click on Legal & Privacy and Advertising Privacy, and disable “Advanced Ad Personalization.” Alternatively, if you opt out of cross-app advertising on your device, you will be opted out of this activity.
• Opt Out of Cross-App Advertising
       • Cross-app advertising is the collection or use of data collected across different apps to infer your interests and tailor advertising. To opt out of cross-app advertising on your device (including the App), select “Limit Ad Tracking” in your iOS settings or “Opt out of ad personalization” in your Android settings. Details and instructions on how to find these settings on commonly used mobile devices can be found here.
• Opt Out of Interest-Based Advertising On Your Browser
       • To opt out of interest-based advertising from many online advertisers (including some or all of 4Sided’s digital advertising partners) on your browser, please use the tools available at the appropriate links for your region below.
               • In the US: Network Advertising Initiative (NAI); Digital Advertising Alliance (DAA)
               • In Europe or the UK: European Interactive Digital Advertising Alliance (EDAA)
               • In Canada: Ad Choices: Digital Advertising Alliance of Canada (DAAC) / Choix de Pub: l'Alliance de la publicité numérique du Canada (DAAC)

b. Ad Measurement

The App includes software that enables third parties to measure ad viewership and similar statistics. When you enable the “Limit Ad Tracking” or “Opt out of ad personalization” option on your device, user-level demographic measurement on the App will be disabled for certain vendors.  This will not disable ad measurement for aggregate statistical purposes. Details and instructions on how to find these settings on commonly used mobile devices can be found here.

c. Marketing Emails and Text Messages

If you no longer want to receive marketing-related emails or text messages from us on a going-forward basis, you may opt out by following the instructions contained in each such email or text message or by opting out from the Settings page in the App. Please note that if you opt out of receiving marketing-related emails or texts from us, we may continue to send you other types of messages from which you cannot opt out, such as information about your account or a significant change to our privacy policy.

d. Push Notifications

You can choose to receive or disable push notifications from us by adjusting your device settings. A shortcut to those options is available in the App’s settings.

8. Your Rights

If you would like to request to access, correct, update, suppress, restrict, or delete personal information, object to or opt out of the processing of personal information, withdraw your consent for the collection, use, or disclosure of your personal information, or if you would like to request to receive a copy of your personal information (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the Contact Us section below. Please clearly describe your request. We will respond to your request consistent with applicable law.

In your request, please make clear what personal information you would like to have provided or changed, or whether you would like to have your personal information deleted. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and you will be required to verify your identity before we begin implementing your request. If you do not provide information sufficient to verify your identity, we may, in some circumstances, be unable to carry out your request.

We will work to comply with your request as soon as reasonably practicable or as required by applicable law. Please note that if you choose to delete personal information, we may need to retain certain information for purposes such as recordkeeping, security, fraud prevention, legal requirements, and/or to complete any transactions that you began prior to requesting a change or deletion.

9. Retention

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
• how long we have a legitimate business need in keeping the personal information, or, if our collection is based on consent, whether you have revoked your consent;
• the length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• whether retention is advisable to protect our rights or the rights or freedoms of our users (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

10. Third-Party Access Points or Links

This Privacy Policy does not address, and we are not responsible for, the privacy, security, information, or other practices of any third parties, including any third party operating any website or service to which our Services link. The inclusion of a link in our Services does not imply endorsement of the linked site or service by us.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with the Services.

11. International Processing

Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers. By using the Services, you understand that your information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information

.Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA or UK standards (the full list of these countries is available here). For transfers from the EEA or the UK to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your personal information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.

12. Sensitive Information

Unless we request it, do not send or disclose to us any sensitive personal information (e.g., social security or social insurance numbers, copies of personal identification cards such as drivers licenses, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services, through customer service, or otherwise.

13. Third-Party Payment Services

We use third-party payment services (through the Apple and Google app stores) or subscription partners (such as T-Mobile and Bell) to process payments. If you subscribe to our Services, your payment information will be collected by such third parties and will be subject to the applicable third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your personal information. We have no access to your payment information.

14. Updates to This Privacy Policy

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to revise this Privacy Policy from time to time. Any changes will become effective when we post the revised Privacy Policy on the Services or as otherwise stated in the revised Privacy Policy.

15. Contact Us

4Sided, Inc is located at 2500 Plaza 5 The Waterfront, 25th Floor, Jersey City, NJ 07311 and is the company responsible for the collection, use, and disclosure of your personal information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at privacy@4sided.com.

16. Additional Information for California Residents

The California Privacy Protection Act (“CCPA”) provides its residents with certain rights. If you are a California resident, the law permits you to request that we disclose to you the following information covering the past twelve months: the categories of personal information we collected about you and the categories of sources from which we collected such personal information; the specific pieces of personal information we collected about you; the business or commercial purpose for collecting or selling (if applicable) personal information about you; the categories of third parties with whom we shared personal information about you; the categories of personal information about you that we sold and the categories of third parties to whom we sold such personal information (if applicable); and the categories of personal information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or disclosed such personal information (if applicable). Additionally, you may request that we delete personal information we have collected from you as defined under the California Privacy Protection Act (“CCPA”).

To make a request to use one of these rights, please contact us in accordance with the “Contact Us” section above. You must use the email used in your account to make the request. Alternatively, you may designate an authorized agent to make a data request to us on your behalf under the CCPA. In order for such an agent to make a request, they must provide proof of their power of attorney and valid government identification of both the requester and the agent. In some instances, we may decline to honor your request where an exception applies, such as where the disclosure of personal information would adversely affect the rights and freedoms of another California resident. Consistent with California law, we will not charge you different prices or provide a different quality of service if you use your rights unless it relates to the value of the information.