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Privacy Policy

This Privacy Policy (the “Privacy Policy”) describes the types of personal information Internet Investments Group Limited and its successors or assignees, subsidiaries and affiliates (“Fourth Estate”, “us”, “we”, or “our”) may collect from you or that you may provide when you visit our website located at https://fourthestate.app/ (the “Website”) or when you access and use the services, applications, tools and features provided by Fourth Estate (collectively the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.

By visiting our Website or accessing or using our Services, you acknowledge and agree to this Privacy Policy. If you do not agree with our Privacy Policy, you must immediately leave our Website or refrain from any further usage of the Services.

For the purposes of this Privacy Policy, the terms “Personal Data,” “Controller,” and “Processor” shall have the same meaning as in and be inclusive of similar concepts under applicable privacy and data protection laws and regulations. This includes, but is not limited to, the General Data Protection Regulation (GDPR) in the European Union, the California Consumer Privacy Act (CCPA) in the United States, the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, UK Data Protection Law, the Brazilian General Data Protection Law (LGPD), the Singapore Personal Data Protection Act (PDPA), the Swiss Data Protection Act (FADP), and other relevant laws related to privacy and data protection.

Capitalized terms used but not defined in this Policy have the meaning given to them in the Terms of Services.

The original language of this Policy is English. We may make available translations of this Policy in other languages for convenience. In case of conflicts between the original English version and any translation, the English version shall prevail.

1. ROLES & RESPONSIBILITIES

Fourth Estate is a Controller of your Personal Data, unless otherwise stated. Fourth Estate acts as a Processor when handling the Personal Data of the End Users on behalf of our Users. Fourth Estate has no direct relationship with the End Users whose Personal Data it processes. If an individual wishes to request access, correct, amend, or delete inaccurate Personal Data processed by Fourth Estate on behalf of our Users, the individual should direct his or her query to the relevant User. If you are looking for contractual provisions about how we will treat and secure Personal Data of the End Users, please see our Data Processing Addendum.

2. WHAT PERSONAL DATA DO WE COLLECT

We collect various Personal Data regarding you or your device. This includes the following:

Personal Data you provide us:

Account Information. When you create the Account, you may provide us with Personal Data, such as name, email address, phone number.

Information you provide if you sign up for the Services.

This will include your billing address as well as a portion of your payment information which is provided to us from our Payment Processor (such as the last four digits, the country of issuance and the expiration date of the payment card).

Subscriptions. When you subscribe to our newsletter(s), you may provide us with the Personal Data, such as name, email address, phone number.

Invoice. When you fill out the Invoice, you may provide us with the Personal Data, such as name, email address, phone number.

Contact with Fourth Estate.

If you contact us, for example through our pages on social media sites, or otherwise, you may provide us with the Personal Data, such as name, email address, phone number, as well as any other content included in or associated with the message you send.

Online forms. When you fill in online forms on the Website, we ask you for the Personal Data such as name, email address, phone number.

Interactions with Fourth Estate. We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other users.

Ownership Disputes. When we try to determine the rightful owner of the Account and/or User Platform, as defined in Terms of Services, you may provide us with the Personal Data contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).

Automatically Collected Information:

Information from browsers, devices and servers.

When you visit, download, and/or use our Website or Services, we may collect aggregated usage Personal Data, such as your browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Data regarding your device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.

Personal Data we collect from other sources:

Signups using federated authentication service providers. You can create the Account using supported federated authentication service providers such as Google Workspace. This service will authenticate your identity and give you the option to share certain Personal Data with us, such as your name and email address. You should check your privacy settings on integrated service to understand what Personal Data that integrated service makes available to us, and make changes as appropriate. Please review integrated service’s terms of use and privacy policy carefully before using their services and connecting to the Services.

Personal Data from the Payment Processor. If you sign up for the Services, we obtain limited Personal Data about your payment card from our Payment Processor, such as the last four digits, the country of issuance and the expiration date. Currently, our Payment Processor is Stripe. Stripe uses and processes your complete payment information in accordance with Stripe’s privacy policy.

Personal Data from social media sites and other publicly available sources. When you provide feedback or reviews about the Website or Services, interact, or engage with us on marketplaces, review sites or social media sites such as Facebook, Twitter, LinkedIn and Instagram through posts, comments, questions and other interactions, we may collect such publicly available Personal Data, including profile information, to allow us to connect with you, improve the Website or Services, better understand user reactions and issues, or to reproduce and publish your feedback on the Website. We must tell you that once collected, this Personal Data may remain with us even if you delete it from these sites. We may also add and update Personal Data about you, from other publicly available sources.

Personal Data from the providers and partners. We may receive Personal Data about you from:
a) security providers, fraud detection and prevention providers for example to help us screen out users associated with fraud;
b) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.

Personal Data from third party providers of business information. We may receive Personal Data about you from third party providers of business information, including your name, email addresses, phone numbers, and others, for the purposes of the Services, that may interest you, delivering personalized communications, event promotion. We may combine these Personal Data with Personal Data we collect through other ways described above. The collection of your Personal Data by these third party providers is governed by their privacy policies.

3. COOKIES

We and our Third Party Service Providers may use various technologies to collect and store your Personal Data, which may include cookies and similar tracking technologies. We use this Personal Data to measure the performance of our email campaigns, to provide analytical information, and for other purposes described in this Privacy Policy.

Cookies are small text files sent by us to your computer or mobile device, which enable us to improve the Website. They are unique to your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. The cookies placed via the Website cannot damage your device or the files stored on it.

You will be notified about the use of cookies when you first visit the Website. If you do not want us or our Third Party Service Providers to collect your Personal Data through the use of cookies, you can set up your choices via the Cookies Preference Center at any time.

Most browsers give you the ability to manage cookies to suit you. In some browsers, you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. This means you can disallow cookies from all sites except those you trust.

If you limit the ability of websites and applications to set cookies, you may worsen your overall user experience and/or lose the ability to access and use the Website or Services, since it will no longer be personalized for you. It may also stop you from saving customized settings, like login information.

To find out more about cookies, visit this website.

4. WHY DO WE COLLECT PERSONAL DATA

We use your Personal Data for the following purposes:

Performance of contract:

  • To set up and maintain the Account, and to do all other things required for providing the Services.
  • To provide, operate and maintain the Website or Services.
  • To provide support.
  • To communicate with you (such as through email) about your use of the Website and Services, changes to this Privacy Policy, Terms of Use, Terms of Services, and to all applicable legal agreements or other important notifications.

Legitimate interests:

  • To analyze and improve our interactions with you.
  • To send you newsletters, promotional materials, and other information that we think will be of interest to you.
  • To ask you to participate in surveys, or to solicit feedback on the Website or Services.
  • To monitor and improve marketing campaigns and make suggestions relevant to you.
  • To understand how you use the Website or Services, to monitor and prevent problems, and to improve the Website or Services.
  • To prevent misuses of the Website and Services, and to protect the security of our systems, the Website and Services.

Compliance with legal or regulatory obligations:

  • To comply with legal obligations and legal process.
  • To detect and prevent fraudulent transactions and other illegal activities, report spam, and protect the rights and interests of you, your End Users, Fourth Estate, our Affiliates, third parties, and the public.
  • To cooperate with investigations by law enforcement or other authorities of suspected violations of law.

Consent:

  • When you give us consent to do so for a specific purpose.

Where we rely on legitimate interests to process your Personal Data, you can object to that processing as described below under “YOUR CHOICES” In response to your objection, we will stop processing your Personal Data for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. We may also process your Personal Data for direct marketing purposes and you have a right to object to our use of your Personal Data for this purpose at any time.

5. TO WHOM WE DISCLOSE PERSONAL DATA

Service Providers. We have partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, our legal and financial advisors, and others (collectively, the “Third Party Service Provider(s)”). We limit your Personal Data provided to the Third Party Service Providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such Personal Data.

Process payments. We may transmit some of your Personal Data via an encrypted connection to our Payment Processor.

Affiliates. We may share your Personal Data with any subsidiaries, joint ventures, or other companies or products under our common control (the "Affiliates"), in which case we will require the Affiliates to honor this Privacy Policy.

Corporate Restructuring. We may share your Personal Data when negotiating, or taking part in a merger, acquisition, sale transfer, divestiture, financing, or disclosure of all or a portion of Fourth Estate’s business or assets. If Fourth Estate suffers from insolvency, bankruptcy, receivership, Personal Data may form part of the assets of Fourth Estate. Nonetheless, Fourth Estate will attempt to convince any recipient of Personal Data to honor this Privacy Policy in its spirit and form.

Advertising and Marketing. We partner with third-party ad networks to display advertising on the Website or to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect information about your activities on the Website and other websites to provide you with targeted advertising based on your interests. If you wish not to have this information used for the purpose of serving you targeted ads, you may opt-out by using these services: https://optout.networkadvertising.org/ or https://optout.aboutads.info/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising, you will continue to receive generic ads.

Law Enforcement, Legal Process and Compliance. We may disclose your Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose your Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Website, Services, and any facilities or equipment used to make the Website and Services available, or (v) protect our property or other legal rights, enforce our legal agreements and policies, or protect the rights, property, or safety of others.

Chargeback. We may disclose your Personal Data to credit card companies or financial institutions when disputing any received Chargeback.

Notice of intellectual property infringement. As set forth in the Terms of Services, we may forward copies of your notice of intellectual property infringement, including your contact information, to the alleged infringer.

6. INTERNATIONAL DATA TRANSFERS

We may transfer your Personal Data to countries other than the one in which you live, including transfers to the European Union. To the extent that Personal Data is transferred abroad, we will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with our obligations. We use Standard Contractual Clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK where appropriate) for transfers to countries not subject to an adequacy decision by the European Commission or your local legislature and/or regulator.

7. COMMUNICATIONS FROM FOURTH ESTATE

You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe' function included in all such messages or by sending an email to the address provided in the “HOW TO CONTACT US” section. Please note that you will continue to receive essential notices and emails such as security incident alerts, security and privacy update notifications, and essential transactional and payment related emails.

8. YOUR CHOICES

Your rights with respect to information we hold about you as the Controller:

  • Right to access – you have the right to know which data we hold about you.
  • Right to data rectification – you have the right to require corrections to your Personal Data in case they are inaccurate or incomplete.
  • Right to data deletion – you have the right under certain circumstances to request the deletion of your Personal Data such as in situations where the processing of your Personal Data is no longer necessary for the purposes for which it was collected, or if the processing of your Personal Data was based on your consent and you wish to withdraw your consent, and there are no other grounds for processing your Personal Data. We may not always be able to comply with your request for data deletion for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Right to restriction of processing – you may also have the right to request to restrict the use of your Personal Data in certain circumstances, such as when you have objected to our use of your Personal Data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Right to withdraw consent at any time – applicable only where we are relying on your consent to process your Personal Data. Any withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide some features or functionalities of the Website or Services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Right to data portability – you have the right under certain circumstances to receive your Personal Data in a “structured, commonly used, and machine-readable format” and to transmit your Personal Data to another Controller without hindrance.
  • Right to object – you have the right to object to the use of your Personal Data in certain circumstances, such as the use of your Personal Data for direct marketing.
  • Right to complain – you have the right to complain to the appropriate supervisory authority, if you have any grievance against the way we collect, use or share your Personal Data. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.

    • Additionaly, you may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Website or Services.

    If you would like to exercise any of these rights, you may contact us as set forth in the “HOW TO CONTACT US” Section.

    If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact our Data Protection Officer by email at [email protected]

    9. DATA RETENTION

    We will retain your Personal Data for a period of time that is consistent with the original purpose of the data collection, or as necessary to comply with our legal obligations, resolve disputes, prevent fraud and abuse, enforce our legal agreements and policies, and/or protect our, our Affiliates legal rights and other interests. When we no longer have a legitimate need to process your Personal Data, we will delete or anonymize your Personal Data from our active databases. We will also securely store your Personal Data and isolate it from further processing on backup discs until deletion is possible.

    10. SECURITY

    We take data security very seriously. We have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us. However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including your Personal Data, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and other authentication factors, as well as maintaining the security of your devices. If you believe your Personal Data has been compromised, please contact us as set forth in the “HOW TO CONTACT US” section. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

    11. THIRD PARTY SERVICES

    The Services enable you to engage, connect, further develop, and procure various third-party services and applications (collectively, the “Third Party Services”) that may make their content, products, or services available to you. Any information that a Third Party Service collects, stores, and processes from you or your User Platform will be subject to such Third Party Service’s terms of service, privacy policy, or similar terms, and will not be subject to our Privacy Policy or Data Processing Agreement. Your interactions with any Third Party Services are governed by their applicable terms of service and privacy policy.

    12. THIRD-PARTY WEBSITES

    Our Website and Services may contain links to other websites. We are not responsible for such websites’ privacy practices. We encourage you to be aware when you leave our Website or Services and to read the privacy statements of each and every website you visit before providing your Personal Data. This Privacy Policy does not apply to such linked third party websites.

    13. USER CONTENT

    If you upload any User Content, you do so at your own risk. We have put adequate security measures in place to protect your Personal Data. However, we cannot control the actions of other users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Platform. You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any parties (including any of your End Users) have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.

    14. MINORS AND CHILDREN’S PRIVACY

    Protecting the privacy of young children is especially important. The Website and Services are not directed nor intended to children under the age of eighteen (18) years old, and we do not knowingly collect Personal Data from children under the age of eighteen (18) years old. If you are under eighteen (18) years old, then please do not use or access the Website or Services at any time or in any manner. If we learn that Personal Data has been collected from persons under eighteen (18) years old and without verifiable parent or guardian's consent, then we will take the appropriate steps to delete this Personal Data.

    15. CHANGES AND UPDATES TO THIS POLICY

    Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through this page, and indicate the date of the latest revision, and will comply with applicable law. If we make changes that materially alter your privacy rights, we will provide additional notice via email. Your continued use of the Website or Services after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

    16. HOW TO CONTACT US

    Please contact us by email at [email protected] with any questions or comments about this Policy, or our data collection, disclosure or processing practices.