We are Consumer Privacy Alliance of America (“CPAOA”). CPAOA takes the privacy of its customers data very seriously. Please read the following policy to understand how we will treat your personal data after it has been collected by us through your use of one of our distribution channels. Those distribution channels will include our website, email services, ansaphones and other channels as they evolve. If this policy changes then we will let you know via our homepage but we assure you that we only use your data as specified here and for our legitimate business reasons.

Privacy Notice

DATA PRIVACY NOTICE

Updated: 11-4-2016

Any revisions to this notice will be effective thirty days after the above date. The prior version of this privacy notice is available here (N/A, this is the first release)

Fourleaf, LLC. (“FourLeaf,” “we” or “us”) is committed to letting consumers (“consumers” or “you”) know how we collect, store, use and share the information we collect about them, and the choices and control they can exercise with regard to their data.

This Privacy Notice is applicable to the consumer data FourLeaf collects through our Data Platform and other services (the “Services”), third party websites, our own websites and other sources. It will let consumers know:

• What we information collect
• How we collect your information
• The tracking technologies we use
• How we use and share your information
• How you can opt-out of certain collection and sharing
• How we secure your information
• Other Important Information

This Privacy Notice does not apply to:

• Some of our websites may have their own Privacy Policies.  A complete list is available here: [N/A].
• Websites maintained by other companies or organizations to which we may link or who may link to us. We are not responsible for the actions and privacy policies of third party websites.

What Information Does FourLeaf Collect and Store?

We collect two basic types of information about you: personally identifiable information (“PII”) and non-personally identifiable information (“non-PII”). Personally identifiable information is any information that can be used to individually identify you, such as your name, email address, postal address, and/or telephone number. Non-personally identifiable information does not personally identify you, but it may be linked to a particular computer or device, such as device identifiers, IP addresses, user identification numbers, hashed email addresses and mobile device IDs.  We do not currently permanently merge your PII with your non-PII even if you have consented to such activities under our or our partners’ privacy policies;  We do, however, reserve the right to do so in the future if appropriate consent has been granted, either directly via one of our websites (or a clarification/revision of this privacy policy) or indirectly through consenting to a third party’s’ privacy policy which such permits data sharing.   

We will temporarily use various “connectors”, especially hashed email addresses, to temporarily associate your PII with specific non-PII for the purposes of targeting advertisements to you online and offline. The non-PII we may collect includes, but is not limited to:

• Human and Non-Human identifying activities, such as your interactions with web-pages and our Services
• Demographic and interest data, such as:
  • Age range
  • Gender
  • Marital status
  • Military status
  • Language you speak
  • Education level
  • Occupation
  • Whether you are a parent and the approximate number of children in your household
  • General health and wellness information, such as whether you suffer from allergies or express an interest in yoga
  • Housing information, such as whether you rent or own your home
  • Financial information, such as whether you have a mortgage or are looking for a car loan
  • Your intent to purchase certain goods or services
• General location data, such as the country, city or zip code in which you reside
• Device Information about your computer, mobile phone or other device, including IP address, unique device identifiers, advertising IDs, browser type, browser language, and other transactional information
• Anonymized PII, such as a one-way hashed email address

How Is Your Information Collected?

We may collect PII and Non-PII (collectively, “your data”) from you directly through the FourLeaf Services, from the websites, emails, mobile applications, and other digital and nondigital properties on which our services are displayed, and from third parties.

Collection of Data through the FourLeaf Services

We will collect your information in various contexts when our customers request our services which include but are not limited to: to help better understand or target their users, track conversions reliably, detect advertising and publishing fraud, detect automated activity (bots), etc.  In these cases, our JavaScript or other code will run inside of other digital properties.

Collection of Personally and Non-Personally Identifiable Information From Other Sources

We also may collect and store information about you that we receive from other sources (including by us from our offline interactions with you) to, among other things, enable us to verify, update and correct the information contained in our database and to better customize advertisements to you both online and offline. We strive to obtain this data from reputable data providers and other companies with rights to share user data and who follow industry codes and guidelines with regard to data collection, use and sharing.

Collection of Data through Cookies, Pixels, Web Beacons and Other Tracking Technologies

FourLeaf uses session and persistent “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We use cookies to track use of our Service, but we may also use cookies to collect non-PII demographic, location and device information.

Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your web browser to decline cookies, some features of the Service may not work or may not work as designed. To learn more about cookies generally, and how to disable them, the Interactive Advertising Bureau provides more information at www.allaboutcookies.org.

We may also use pixels, web beacons and other tracking technology. A web beacon is an invisible graphic on a web page that is programmed to collect non-personally identifiable information about your use of a given website. We may also collect information from your browser that may enable us to track your device across unaffiliated websites for security purposes related to our advertising services (e.g., click fraud prevention).

Your browser or device may include “Do Not Track” functionality. Because a “Do Not Track” compliance protocol has not yet been finalized, FourLeaf’s information collection and disclosure practices, and the choices that we provide to customers, will continue to operate as described in this Privacy Notice, whether or not a Do Not Track signal is received.

Third Party Collection

We work with third parties who may utilize cookies, pixels or other technologies to collect your Non-PII when you use the Service. They may collect information about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based advertising or other targeted content across the Internet. We do not control these third parties’ tracking technologies or how they may be used. To learn more about the use of this information or to choose not to have this information used by our third party advertising partners by opting out, please visit the Network Advertising Initiative by clicking http://www.networkadvertising.org/managing/opt_out.asp. To learn more about how advertisers generally use cookies and the choices they provide, visit the Digital Advertising Alliance at http://www.aboutads.info/, the Internet Advertising Bureau at http://www.iab.net, or the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp.

III. How Do We Use and Share Your Information?

How Do We Use Your Data?

We use your data to help us continually improve your experience on the Service, as well to help create a more personalized experience for the online community. We may use your data to:

• provide you with the content you request;
• enable the proper functioning of the Service;
• provide you with advertising including advertising based on your activity on our digital properties or activity on third party sites, applications, and digital and nondigital properties;
• Optimize or improve our products, services and operations;
• detect, investigate, and prevent fraudulent or other illegal activities; and
• perform statistical, demographic, and marketing analyses of users of the Service and their purchasing patterns
• Provide third parties, including advertisers, with targeted lists or audiences that we believe may be interested in a particular advertisement or advertisements.

Unless previously and explicitly prevented in this privacy policy, we may combine the information from the Service with information gathered from various other sources into a single user record. We may also use and/or combine information that we collect off-line, or that we collect or receive from third party sources, to enhance, expand, and check the accuracy of user records.

How Do We Share Your Data?

Except as disclosed in this Privacy Policy, we do not disclose the personally identifiable information you provide to us to any organizations that are not part of FourLeaf or its subsidiaries or related entities, except as described below. Although, as disclosed below, we may provide your PII to our affiliates, partners and law enforcement, in no event will we engage in any form of distribution or sale of your PII to third parties for their own promotional use without your consent.

• Advertising Customers: If we you have provided appropriate consent to have your PII shared, we may sell or transfer your PII to various advertising customers who wish to contact you via email, postal mail, or other various channels.  Once this information is sold we cannot control its use, but, we do provide safeguards and protections to ensure that your PII is transferred securely and to reputable third parties

.

• Third-Party Service Providers: Certain third parties perform service functions on our behalf, including, but not limited to, marketing and analytics. These entities may have access to personally identifiable information if needed to perform their functions. If such access is required, the third parties will be contractually obligated to maintain the confidentiality and security of that personally identifiable information. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to the Website.

• Business Partners and Other Third Parties: From time to time, we may share your personally identifiable information with our business partners, such as the owners of the websites where our Services are used. Although our treatment of your PII is governed by this Privacy Policy, the business partner’s treatment of your personally identifiable information will be governed by the business partner’s privacy policy. You may withdraw your consent to our sharing of your personally identifiable information with business partners at any time by following our opt-out process.

• Assignment and Transfers: We may change our ownership or corporate organization, or sell certain assets associated with the company and the Service. As a result, please be aware that in such event we may transfer some or all of your information to an entity acquiring all or part of our assets or to another company with which we have merged. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, we cannot promise that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Privacy Policy.

• Law Enforcement, Legal Process, and Emergency Situations: We may also use or disclose personally identifiable information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with valid legal process; (b) protect and defend our rights or property, the Service or our users, and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Service or the public.

• Non-Personally Identifiable Information: We may disclose or share non-personally identifiable information (or other information, other than personally identifiable information) in any other manner that we deem appropriate or necessary, including with unaffiliated third parties, subject to your opt-out choices, as described below.

How to Opt-Out of Certain Data Collection and Sharing?

FourLeaf believes that consumers should not only understand how data is being collected, used and shared, but have the ability to limit those activities, as well. We can’t allow you to opt-out of everything – we still need to collect and use your information to enable our Service – we can allow you to opt-out of non-service related data collection and sharing through the FourLeaf opt-out process.

You may also limit FourLeaf’s association of your mobile device with other non-PII and online activities by resetting the advertiser ID on your Apple or Android device. For more information about how to change these settings go to:

• Apple: http://support.apple.com/kb/HT4228
• Android: http://www.google.com/policies/technologies/ads/
• Remove your Cookies from us directly: https://privacy.cpaoa.org/

Security and Retention

The security of your data is important to us. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. This includes, but is not limited to the use of encryption or hashing of your personally identifiable information. No method of transmission over the Internet or method of electronic storage is 100% secure, however therefore we cannot guarantee the absolute security of your data.

The time period for which we keep information varies according to how the information is used. In some cases, there are statutory and contractual requirements to keep data for a minimum period. We will retain your data as long as necessary for the purposes for which it was collected or for which it is to be further processed.

Other Important Information

Notice to Non-US Users

This Website is published in the United States. We attempt to protect the personally identifiable information of all users of our Website and we attempt to comply with local data protection and consumer rights laws to the extent they may apply to FourLeaf’s services, but our Website is targeted to United States citizens and our policies are directed at compliance with those laws. If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your personally identifiable information to FourLeaf.

If you are located outside the United States of America, you should be aware that your personally identifiable information will be transferred to the United States of America, the laws of which may be deemed by the your country to have inadequate data protection. If you are located in a country outside the United States of America and voluntarily submit personally identifiable information to us, you thereby consent to the general use of such information as provided in this privacy policy and to the transfer of that information to, and/or storage of that information in, the United States of America.

Children’s Information

Unless otherwise disclosed during collection and with parent or guardian consent through the web page on which the FourLeaf Service is displayed, we do not knowingly collect personal information from children under 13 years of age.

Your California Privacy Rights

California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding its disclosure of their personally identifiable information to third parties for their direct marketing purposes. While we do not disclose your PII to third parties for their direct marketing purposes without your consent, you may request a list of all of the third parties with whom we share your non-PII by sending an e-mail privacy@fourleaf.cloud and place “California Third Party Disclosure” in the subject line. Please allow up to thirty days for a response.

Changes in Our Privacy Practices

We may change this Privacy Notice from time to time. We encourage you to periodically review this page for the latest information on our privacy practices.

How to Contact Us

If you have questions about this Privacy Policy, please contact FourLeaf via e-mail at privacy@fourleaf.cloud with “PRIVACY POLICY” in the subject line or by mailing us at the following address:

30 N Gould St., Ste #5479

Sheridan, WY 82801

We will investigate your question, respond to your inquiry, and attempt to resolve any concerns regarding your privacy question.