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Privacy Policy

This is the Privacy Statement and Policy (“Privacy Statement”) for 4C Compliance, LLC (4C).

 

This Privacy Statement was last updated in April 2023.

4C Compliance respects your privacy and is committed to protecting your personal information as you access and use materials on 4cCompliance.com. Information that you submit to 4C in response to an email request for information or other outreach will be treated in accordance with this Privacy Statement. If you are a California resident, please see the California Addendum at the end of this Privacy Statement for further details on how we handle your information and how to exercise your rights.

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4C may periodically amend this Privacy Statement. To ensure you are able to remain informed about the information we collect and how we use it, material changes to our statement will be reflected here. This Site may contain links to external sites which are not governed by this Privacy Statement. 4C shall not take responsibility for the privacy practices of any third-party sites to which we link. We encourage you to review the privacy policies of third-party sites before you submit information.

 

YOUR ACCEPTANCE OF THIS PRIVACY STATEMENT

Please read this Privacy Statement carefully. By browsing the Site or expressly consenting, you agree to be bound by this Privacy Statement.

 

INFORMATION THAT WE COLLECT, AND HOW WE USE IT

How do we use personal information?

The purposes and uses of your personal information will depend on the use of the Site and the personal information provided. We process your personal information:

  • For the purposes of safeguarding the legitimate business interests pursued by 4C. This includes:

    • Communication with you and management of your requests in relation to your account, subscriptions to 4C newsletters and publications, and surveys in which you participate.

    • Analyzing the Site’s user population and identifying subject areas of interest

    • Measuring and improving the effectiveness of 4C marketing programs across different channels

    • Improving our web content and navigation

    • Informing you about updates to the service and notifying you about other products and services offered by 4C that may be of interest to you, including information regarding publications and events and track email engagement activity for internal use only.1

  • Insofar as you have granted us consent to the processing of personal information for specific purposes, the lawfulness of such processing is based on your consent. You may withdraw your consent at any time.

  • For compliance with a legal obligation.

 

HOW WE MIGHT SHARE YOUR INFORMATION

Third-parties with whom we may need to share personal information to help us provide services and products to you and to run our Site include:

  • Service providers who process information on our behalf to run internal business operations

  • Law enforcement to comply with any legal obligation or court order.

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RETENTION OF YOUR PERSONAL INFORMATION

 

4C retains your personal information for so long as is necessary to fulfill the purpose for which it was collected. The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship and provide services to you (for example, for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise.

  • 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 in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations)

 

MARKETING

In our marketing communications with you we monitor and comply with applicable data privacy laws and if, at any time, you prefer not to receive further communications from us in any or all forms you will have the ability to unsubscribe from such communications by emailing the 4C at “support@4cCompliance.com.” 

 

COOKIES AND OTHER TRACKING TECHNOLOGIES

4C may use cookies on this Site and in our communications with you to keep track of your visit to our Site and our communications with you. A “cookie” is a small amount of data sent from a Web server to your browser and stored on your computer’s hard drive. Other tracking technologies work similarly to cookies and place a small amount of data on your devices to monitor your website activity to allow us to collect information about how you use our Site and our services. With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored on your computer. Please refer to your browser instructions or visit https://www.aboutcookies.org/ to learn more information. When you give 4C consent to use cookies, we shall store a cookie on your computer or device. At any time, if you wish to withdraw consent, you will need to delete our cookies using your web browsers settings. 

SECURITY PROCESSES

4C has in place appropriate technological and operational security processes designed to protect personally identifiable information from loss, misuse, alteration, or destruction. Only authorized employees and contractors will have access to any data provided by you, and that access is limited by need. Each employee or contractor having access to any personally identifiable information is obligated to maintain its confidentiality. Although we take steps that are generally accepted as industry standard to protect your personally identifiable information, 4C cannot guarantee that your personally identifiable information will not become accessible to unauthorized persons and 4C cannot be responsible for any actions resulting from a breach of security when information is supplied over the internet or any public computer network.

LINKS TO OTHER WEBSITES

This Site may contain links to other websites that are not operated by 4C.

4C is not responsible for the privacy practices or the content of any non-4C websites to which we link from the Site. We are not responsible for the protection and privacy of any information you provide whilst visiting other websites and sites not governed by our Privacy Statement. We cannot control the content or security of such websites. We cannot be held responsible for any loss or damage incurred by a user as a result of visiting such websites. No links are intended to be, nor should be construed as, an endorsement of any kind by 4C.

 

COMPLIANCE WITH LAW

4C complies with all applicable data privacy laws. 4C may be compelled to surrender personal user or customer information to legal authorities if presented with a court subpoena or similar legal or administrative order, or as required or permitted by the laws, rules and regulations of any nation, state or other applicable jurisdiction. In the event of a violation of the terms and conditions of use of the Site or a violation of any restrictions on use of materials provided in or through the Site, we may disclose personal user information to our affected business partners or legal authorities.

 

YOUR RIGHTS

In accordance with applicable data privacy laws, including but not limited to the GDPR and the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), you have a right to request a copy of the personal information we hold about you and details of how we use that information. If any of the information held about you is incorrect or out of date, you have the right to amend or rectify it. Please follow the process outlined below and we will amend our records where appropriate. You also have the right to request that we erase your personal information, stop processing your personal information, restrict the processing of your personal information, and provide your personal information in a portable format. Where processing is based on your consent, you may withdraw your consent to processing. This may not apply if there are other legal justifications to continue processing. If you think we may have incorrect personal information, or would like a copy of the personal information we hold on you, or to exercise any other data protection right, please contact us. Please note that we will need to authenticate your identity before we can provide you with any information.

 

CHILDREN

4C understands the importance of protecting children's privacy, particularly in their online interactions. This Site is not designed for and does not intentionally target or solicit to children 18 years of age and younger.

 

USE OF 4C WEBSITES

Your access to and use of the Site are subject to this Privacy Statement and certain other terms and conditions, contained in our Terms and Conditions of Use.

CONTACT US

For further questions you may contact the Privacy Officer at “privacy@4cCompliance.com.”

CALIFORNIA ADDENDUM

This California Addendum applies to California residents and supplements the information provided above in the Privacy Statement. This Addendum does not apply to our job applicants, employees, or contractors where the personal information we collect about those individuals relates to their current, former, or potential role with us.

Collection, Disclosure, and Sharing of Personal Information

The following list details which categories of personal information we have collected and processed, both online and offline, within the 12 months preceding the date this Privacy Statement was last updated: 

  • Identifiers, such as IP address, and online identifiers

  • Geolocation data, such as approximate location derived from IP address

  • Internet or network activity information, such as browsing history of 4C sites, assets or prior visits, and interactions with our online properties

  • Inferences drawn from any of the personal information listed above to create a profile about, for example, an individual’s preferences or characteristics

  • We may share the following information with our affiliates and subsidiaries; third-party service providers; ad networks; external legal, financial, and other professional advisors; legal authorities for operational business purposes

Identifiers, such as name IP address, and online identifiers, contact information, unique personal identifiers,

Internet or network activity information, such as browsing history of 4C sites, assets or prior visits, search history and interactions with our online properties

Geolocation Data, such as approximate location derived from IP address

Inferences drawn from any of the personal information listed above to create a profile about, for example, an individual’s preferences or characteristics or for statistics and visitor tracking

  • Browser fingerprint and IP address

  • Audio/Video Data. Audio, electronic, visual, and similar information

  • We may share your following information with our joint business partners for publications and co-organized events

  • Identifiers such as name and contact information

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We may also disclose your personal information to a third party in the event of any reorganization, financing transaction, merger, sale, joint venture, partnership, 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).

We do not, and have not, sold personal information, including your sensitive personal information, in the preceding 12 months. Without limiting the foregoing, we do not sell the personal information, including the sensitive personal information, of minors under 16 years of age.

 

 

Sources of Personal Information

We collect this personal information directly from you and from third-party sources, such as public databases, joint marketing partners, and social media platforms, where permitted under applicable local laws.

Purposes for the Collection, Use, or Sharing of Personal Information

We collect, use, or share personal information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including to:

  • Develop, improve, operate repair, and maintain our products and services

  • Provide support and respond to requests for information

  • Advertise and market our products and services, and personalize user experiences

  • Conduct research, analytics, and data analysis

  • Operate and maintain our facilities and infrastructure

  • Undertake quality and safety assurance measures, and conduct security control and monitoring

  • Detect and prevent fraud and perform identity verification

  • Facilitate and implement any reorganization, financing transaction, merger, sale, joint venture, partnership, 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)

  • Maintain records, comply with law, legal process, and internal policies, and exercise and defend legal claims.

Purposes for the Collection and Use of Sensitive Personal Information

We may use sensitive personal information of account login, password, or other credentials allowing access to an account which qualify as sensitive personal information for purposes of performing services for our business, providing goods or services as requested by you, ensuring security and integrity, short-term transient use such as displaying first party, non-personalized advertising, order processing and fulfillment, servicing accounts, providing service, verifying client information, and activities relating to quality and safety control or product improvement.

Individual Requests

You may, subject to applicable law, make the following Request for Disclosure: 

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    • The categories of Personal Information we collected about you and the categories of sources from which we collected such personal information

    • The business or commercial purpose for collecting or sharing personal information about you

    • The categories of personal information about you that we shared (as defined under the applicable privacy law) and the categories of third parties to whom we shared such personal information; and

    • The categories of personal information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such personal information (where applicable)

  • You may request to correct inaccuracies in your personal information

  • You may request to have your personal information deleted

  • You may request to receive the specific pieces of your personal information, including a copy of the personal information you provided to us in a portable format

  • You may request to opt out of the “sharing” of your personal information for purposes of cross-context behavioral advertising

We will not unlawfully discriminate against you for exercising your rights under applicable privacy law. To make a privacy request, contact us via support@4cCompliance.com. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you to verify your identity and protect against fraudulent requests. 

Authorized Agents

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Individual Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.

 

If you are a resident of California, the California Consumer Privacy Act (“CCPA”) provides you with additional rights regarding your Personal Information. This section describes the Personal Information we collect about you, how we use and disclose it, and how you can exercise your privacy rights under the CCPA.

Your privacy rights under the CCPA do not apply to all information that we might collect, use or disclose. For example, the CCPA does not apply to PHI governed by HIPAA, “medical information” governed by the California Confidentiality of Medical Information Act (“CMIA”), or other patient information we maintain in the same manner as PHI or “medical information.” The CCPA also excludes other categories of information. When we collect, use or disclose information not covered by the CCPA, we do so as described in this Privacy Policy. If you would like to learn more about how we collect, process, or disclose your information that is not covered by the CCPA, or to exercise the rights that may be available to you under HIPAA and other laws, please review this Privacy Policy or contact us at support@4cCompliance.com.

For your Personal Information covered by the CCPA, your rights are described below.

Personal Information Disclosures

In the last twelve (12) months, we have collected the following categories of Personal Information about you:

- Identifiers (e.g., name, mailing address, email address, and telephone number, as well as unique identifiers such as your IP address, cookies or similar data)

- Characteristics of protected classifications under California or Federal law (e.g., your gender or age)

- Internet or Other Electronic Network Activity Information (e.g., browsing history, activity, and service pages visited to help you get started, and information regarding your interactions with our Platform)

- Geolocation Data

- Professional or employment-related information (e.g., your occupation)

- Audio, electronic, or similar information when you contact our customer care center by phone

- Inferences drawn from the information identified above

We collect this Personal Information directly from you when you provide it to us; automatically as you navigate through the Platform; or from third party sources to help us determine the best product or service for you. For more information about the sources from which we collect your Personal Information, please see 

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect and use your Personal Information:

  • for our own operational purposes to provide services to you

  • to audit interactions on the Platform;

  • to secure our Platform and detect, protect, and investigate against security incidents; 

  • to improve our Platform (e.g., identify bugs, repair errors, and ensure that services function as intended). 

 

For more information about the purposes for which we use your Personal Information, please see the Section: HOW WE USE YOUR INFORMATION.
 

The Personal Information we disclose is described in Section xx DISCLOSURE OF YOUR INFORMATION. In the last twelve (12) months, we have disclosed certain information to third parties (such as our service providers) as set out below for a business or operational purpose:

Categories of Personal Information

Categories of Third Parties

- Identifiers (e.g., such as your email address, IP address, account login information, cookies or similar data)

- Service providers who provide professional or technical support functions; Professional service organizations; Analytics providers for our Platform.

- Internet or other similar network activity (e.g., browsing history, activity, and service pages visited to help you get started, search history, and information regarding your interactions with our Platform)

- Service providers who provide professional or technical support functions; Analytics providers for our Platform.

- Geolocation data

- Service providers who provide professional or technical support functions; Analytics providers for our Platform.

Like many organizations, we engage third parties to help deliver interest-based advertisements to you and may make use of third-party tracking technologies or other online marketing services. In doing so, we may make available or transfer your Personal Information (e.g., Identifiers such as your IP address, Geolocation data, and Internet or other similar network activity) to third parties, such as advertising agencies, advertising services, analytics providers, sponsored content providers, social media platforms, and other similar technology companies. In certain cases, sharing data with these providers could be considered a “sale” under CCPA even though it is not a sale in the traditional sense. In the prior twelve (12) months, we may have, as defined by the CCPA, sold or disclosed for consideration certain categories of your Personal Information.

California Resident Privacy Rights

If you are a California resident, you have the following rights:

- Right to Know: You have the right to know about the Personal Information we collect, use, and disclose about you in the twelve (12) months preceding your request. Upon verifying your identity, we will provide you with the specific pieces of Personal Information we have collected about you. We also will disclose the categories of Personal Information we have collected about you and purposes for doing so; the categories of sources of that data; the categories of third parties with whom we shared it for a business purpose and our purposes for doing so; and the categories of third parties to whom we sold Personal Information and our purposes for doing so.

- Right to Deletion: You have the right to request that we delete the Personal Information we collect about you. We will honor your request unless an exception applies, such as when the information is necessary to complete the transaction or contract for which it was collected.

- Right to Opt-out of the Sale: You have the right to request that we do not sell your Personal Information to third parties. While we do not “sell” your data in the traditional sense, the CCPA defines this term broadly to include our use of certain third-party advertising and marketing services as described above.

- Right to Non-Discrimination: We do not discriminate against you for exercising any of your privacy rights under CCPA or applicable law, including discrimination in the form of: denying you goods or services; charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing you a different level of quality of goods or services; or suggesting that you will receive a different price or rate for goods or services or a different level of quality of goods or services.

How to Exercise Your Privacy Rights

- For “Right to Know” and “Right to Deletion” requests, visit and complete our web form here. We must verify your identity or authority to make the request and confirm the Personal Information relates to you, or others. To do so, we collect your name, e-mail address, phone number to verify your identity. We also may contact you by e-mail or by telephone to verify your identity and ask you additional questions so that we can match your identity with the data we have about you. In some instances, we may ask you to declare under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

- You also may designate an authorized agent to make a request for you. To use authorized agent, you or your authorized agent must:

submit proof that the authorized agent is registered with the California Secretary of State and that you have authorized be able to act on your behalf,

submit evidence that you have provided the authorized agent with power of attorney pursuant to the California Probate Code, or

provide the authorized agent written and signed permission to act on your behalf, verify your identity with us, and directly confirm with us that you have provided the authorized agent permission to submit the request.

We may deny a request from an authorized agent who does not submit sufficient proof to act on your behalf.

- For “Right to Opt-out of the Sale” requests, please note that we collect cookies on our website. You may request to opt-out of these cookies on this website by emailing “support@4cCompliance.com. Please refer to Section xx CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION for more information about options you may have for managing the collection of your Personal Information for analytics and advertising purposes.

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Revisions to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page. The date this Privacy Policy was last modified is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically monitoring and reviewing any updates to this Privacy Policy. Your continued use of our Platform after such amendments will be deemed your acknowledgement of these changes to this Privacy Policy.

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