Last updated: April 20, 2020
- Who we are
- About this privacy notice
- Changes to this privacy notice
- How to contact us
- Personal data we collect and how
- Aggregated data
- How we collect personal data
- Marketing Choices
- Sharing your personal data
- UK and EU users: international transfer of your personal data
- Retaining your personal data
- Third-Party Sites
- Privacy information for EEA and UK users
- Privacy Information for California Residents
1. Who we are
2. About this privacy notice
4. How to contact us
5. What personal data we collect and how
5.1 Personal data you provide to us.
We collect data you provide directly to us.
- Account data. If you sign up for a 4CSN.com account (“Account”), we will collect data you give us related to your Account, including your name, email address, username and password. We describe this more fully in Section 5.4 below.
- Additional Account data. You may provide additional data as part of your Account (such as your personal description). This data will be publicly visible to others. If you do not wish to share this information with us or others, do not provide the information as part of your Account.
- Other data. You may provide us with data when you fill in a form, conduct a search, update or add information to your Account, respond to surveys, post to community forums, provide us with feedback, participate in promotions, or use other features of the Services.
5.2 Data that indirectly identifies you and automatically collected data.
When you access or use the Services, we collect data that indirectly identifies you and we automatically collect other data about you, including:
- Log Data. We automatically receive and record information from your device or web browser when you interact with the Services. For example, we collect your internet protocol (IP) address, mobile device ID, time zone setting, language preference, operating system, platform, internet service provider (ISP), and links you have clicked on or shared with others, including through email and social media. If you sign up for an Account, we also create a user ID that indirectly identifies you. We use this information to collect data about your activities through the Services. We associate information that indirectly identifies you with your Account (if you have one) and other information we have collected about you.
We also may use these technologies to collect data about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically may include personal data, or we may maintain it or associate it with personal data we collect in other ways or receive from third parties.
5.3 Location data.
We use your IP address to infer your approximate location. We may also collect the language option or country you choose. When we provide certain services, such as providing you with a version of our Services that is localized to your country, we link location data to other information we have collected about you in order to do so.
5.4 Profile data.
If you sign up for an Account, we will collect certain data you give us as part of your Account sign-up as described above, information you give us in connection with purchases or orders made by you, and your interests, preferences, feedback and survey responses. Your interests and preferences are inferred from data we collect regarding what types of content you have interacted with, how long you interacted with them, how often you interacted with them, and the nature of your interaction with the content. We do not disclose email addresses to other users except where it is necessary to comply with the law, to protect our rights, or to protect the rights of our users.
5.5 Special category data.
When we conduct research or carry out surveys and you participate in our research or surveys, we may collect sensitive personal data about you, for example, information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life or sexual orientation. We will get your explicit consent for our collection, use, or sharing of this data as required by law.
6. Aggregated data
6.1 We analyze and aggregate personal data we collect, such as the number and frequency of your visits to the Services, to produce anonymized metrics and statistical information that does not identify you as an individual.
7. How we collect personal data
7.1 You may give us your personal data directly, for example when you create an Account, subscribe to our newsletters, opt-in to marketing communications, publish posts or comments, enter a competition, participate in a promotion or survey, ask for user support, or contact us for any reason.
7.3 Third parties who provide advertising and related services (such as analytics providers and ad networks) may give us your personal data so that we can compare it to personal data we hold in order to determine if you are the same individual (this is sometimes called “cookie-matching”). We may collect data from unaffiliated third parties so we can better understand you and provide you with information and offers that may be of interest to you. For example, we may receive information about your interests or preferences as well as contact information, such as email address.
7.4 We may receive your personal data from third parties when you buy things through our Services or when you buy things from a third party after clicking on an affiliate link in our content. This information may include your contact details and financial and transaction data (such as items purchased and purchase price) from providers of technical, payment and delivery services.
7.5 If you access our Services using your Facebook or Google credentials, we will automatically collect certain information, such as your Facebook or Google user ID. We will use any information collected from Facebook or Google, including the user ID Facebook or Google attribute to you, only in accordance with Facebook’s or Google’s policies and your preferences selected through Facebook or Google.
7.6 What we use your data for:
We use the data we collect to provide, maintain, and improve our Services. We also use the data we collect to:
- Send you technical notices, updates, security alerts, and support and administrative messages, and to respond to your comments, questions and customer service requests;
- Communicate with you about products, services, offers, and events offered by 4CSN and others, and provide news and information we think will be of interest to you;
- Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests. Your interests and preferences are inferred from data we collect regarding what types of content you have interacted with, how long you interacted with them, how often you interacted with them, and the nature of your interaction with the content;
- Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
- Monitor and analyze trends, usage and activities in connection with our Services and personalize and improve the Services;
- Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of 4CSN and others;
- Carry out any other purpose described to you at the time the data was collected.
8. Marketing choices
When you sign up for a promotion like a sweepstakes, or subscribe to or create an Account to use our Services, we use your personal data to help us decide which products, services and offers may be of interest to you. We will send marketing messages to you if you have asked us to send you information, bought goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion. If you opt out of receiving marketing messages, we may still send you non-promotional emails, such as those about your Account or our ongoing business relations. We will ask for your consent before we share your personal data with any third party for direct marketing purposes.
You may unsubscribe from marketing messages through a link we include on the messages we send you. You can also ask us to stop sending you marketing messages at any time by contacting us at firstname.lastname@example.org
9. Sharing your personal data
- With vendors, consultants, and other service providers who process your data on our behalf when they provide services to us, for example, data analytics, ad networks, research, marketing and financial services;
- With third parties who use it for their own purposes if you have provided consent;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
- We may be legally required to disclose or share your personal data without your consent in some circumstances, for example, to comply with a court order or law enforcement. In such circumstances, we will only disclose your personal data if we have a good-faith belief that such sharing is required under applicable legal obligations.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. For example, we may share aggregated or de-identified information with our ad partners and service providers so that we, and they, can understand how people use our Services; this helps us grow our business and improve and develop our products and services. We may also share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
10. UK and EU users: international transfer of your personal data
10.1 When we process your personal data within 4 CSN, we will do so in countries in which we have offices. We have put into place intra-group controls (including the standard contractual clauses approved by the European Commission) to ensure that your rights continue to be protected.
10.3 Our agreements with those third parties include Commission-approved standard contractual clauses and otherwise make clear the standards we expect of them in order to safeguard your information and your legal rights.
11. Retaining your personal data
11.1 We keep your personal data for as long as we need it for the purposes for which it was collected.
11.2 When we decide how long we will keep your information we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, why we need it, and any relevant legal requirements (such as legal retention and destruction periods).
11.3 We may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes.
12. Third-Party Sites
12.2 The Services may offer social sharing features and other integrated tools, which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. We also use the analytics tools provided by the social media platforms to help us to understand how people interact with our social media presence, to identify trends and to carry out joint promotional activities with those platforms. For example, sometimes we agree with a social media platform that we will jointly promote certain content.
We also use the analytics tools provided by the social media platforms to help us to understand how people interact with our social media presence, to identify trends and to carry out joint promotional activities with those platforms. For example, sometimes we agree with a social media platform that we will jointly promote certain content.
We receive from the platform aggregated statistical information about the performance of our posts and promoted content, such as numbers of views and kinds of viewers. This data is aggregated and anonymized by the platform prior to being made available to us.
We also use the paid advertising and paid content tools provided by the social media platforms to help us carry out advertising campaigns for our ad partners and to promote our content on the social media platforms. For example, we use the “Promoted Pins” tool on Pinterest to promote editorial or paid content to visitors to Pinterest. Again, we receive from the social media platforms only aggregated statistical information about interactions with our ads and paid content, such as number of views, number of times shared and so on.
We process information provided to us by the social media platforms on the basis of our legitimate interest in interacting with our audience on social media and using social media to promote our content.
For more information about the purpose and scope of data collection and processing in connection with social sharing features or your use of the social media platforms, please visit the privacy policies of the respective entities at the following links:
- Facebook and Instagram – https://en-gb.facebook.com/policy.php
- Twitter – https://twitter.com/en/privacy
- YouTube – https://policies.google.com/privacy?hl=en
- Snapchat – https://www.snap.com/en-US/privacy/privacy-center/
- Twitch – https://www.twitch.tv/p/legal/privacy-policy/
- TikTok – https://www.tiktok.com/en/privacy-policy
- Pinterest- https://policy.pinterest.com/en/privacy-policy
- Tumblr – https://www.tumblr.com/privacy
- LinkedIn – https://www.linkedin.com/legal/privacy-policy
Cookies and similar technologies allow us to collect the following types of personal data: a unique ID assigned to your device; IP address; device and browser type; operating system; referring URLs; content viewed or other actions taken through our Services; time and date of those actions; country and language selected.
Browsers and devices have tools that allow you to disable cookies on sites and apps. If you disable cookies you may not be able to access all the features of our services. We suggest that you keep our essential cookies (described below) active for a better user experience and to help us keep improving and developing our products and services.
13.2 Our Services use our own cookies to recognize you and remember you as a unique user.
- Session cookies remember you during your session on our Services. They are deleted when you log out of the Services and when you close your web browser. Session cookies are used to ensure you are served content correctly, to balance and monitor load on our servers, and for other technical matters essential to the operation of our Services. You can configure your device to reject these cookies, but our Services will probably not work correctly, or at all if you do.
- Consent cookies are used by our consent management platform we employ to record your preferences about third-party cookies described below and to store and share your preference with those third parties. These cookies are essential for compliance with the legal obligations imposed on us and on third parties with whom we have a business relationship to ensure we request your consent, record your consent preferences, and act on such consent preferences.
13.3 Analytics cookies
Analytics cookies are used by us and by third parties who process data for us for data analytics purposes (for example Google Analytics) so that we can manage and improve the performance and design of our Services and for monitoring, auditing, research and reporting.
We have activated Google’s IP anonymization function on our Sites. This will cause your IP address to be cut by Google within Member States of the European Union or in other countries party to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Sites, to compile reports on Site activity and to provide us with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
With respect to Google Analytics, you can read about how Google uses data gathered for that purpose here.
13.4 Third party cookies: advertising and affiliate links
Our ad partners and our affiliate links partners collect personal data from you for the purposes they disclose through our cookie consent management platform.
- Ad partners include ad networks such as third party ad servers, ad agencies, ad technology vendors and research firms.
- Affiliate links partners pay us when you buy things from them or another third party after clicking on an affiliate link in our content.
14. Privacy information for EEA and UK users
14.1 Information for UK/EU Users (including legal bases)
We will use your personal data only for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for another purpose, we will explain the legal basis we rely on.
The table below shows what we use your personal data for and the lawful basis for processing it in each case.
|Purpose||Type of data||Lawful basis|
|Communicate legal information to you.||Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information you include in your user profile).||Legitimate interest.|
|Analyze comments and feedback you have given us including comments, feedback and reviews you have posted on our Services in order to use the information to carry out journalistic activities, to improve our services and content offerings, and to enforce our Terms of Service.||Data that directly identifies you (such as your name, username, and email address) and data that indirectly identifies you (such as your IP address or mobile device ID and location data).||Legitimate interest.|
|Provide you with communications and services you’ve signed up, for such as our newsletters.||Data that directly identifies you such as your name, username, email address and location data.||Consent.|
|Register you as a user of our Services and other products and services and administer your Account.||Data that directly identifies you (such as your name, username, and email address and other information included in your user profile).||Creation or performance of a contract.|
|Publish content on our Services including articles, feedback, reviews and user comments about our posts.||Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information included in your user profile).||Creation or performance of a contract.|
|Fulfill orders for subscriptions, products or services placed through our Services.||Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data.||Creation or performance of a contract.|
|Collect money you owe us.||Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data.||Legitimate interest.|
|Verify or obtain payments due to us when you buy something from a third party after clicking on an “affiliate” link in our content, measure the performance of affiliate links, analyze and develop this part of our business.||Data that indirectly identifies you (such as your IP address or mobile device ID) or data that directly identifies you (such as your name, username, email address and location data).||Legitimate interest.|
|Communicate our terms, notify you about changes to them and communicate with you about non-compliance.||Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username and email address).||Creation or performance of a contract.|
|Conduct surveys or undertake similar types of research so that we can improve and develop our business, our Services.||Data that directly identifies you (such as your name, username, name, email address and location data)||Consent.|
|Allow you to take part in a prize draw, sweepstake, or other competition or other promotional activity.||Data that directly identifies you such as your name, username, and email address.||Creation or performance of a contract.|
|Administration and protection of our business including troubleshooting, data analysis, testing, system maintenance, user support, reporting and hosting data, administration and IT services, network security, fraud prevention, customer services and business reorganization, including exchanging information with third parties for fraud protection and spam/malware prevention.||Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address).||Legitimate interest.|
|Send marketing communications to you if you subscribe to our newsletters or other products and services. We explain how we comply with the law and how you can manage your preferences in our “Marketing choices” section.||Data that directly identifies you such as your name and email address.||Consent|
|Communicate with you about our services that you sign up to receive when you create an Account and transactions that you conduct using our services, including published content you visit, content you submit for publication on 4csn.com, and content posted by you on 4csn.com (including your comments on content, feedback and reviews).||Data that directly identifies you such as your name and email address.||Creation or performance of a contract|
|Comply with applicable laws, regulations and legal and regulatory processes.||Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and/or data that directly identifies you (such as your name, username, and email address).||Creation or performance of a contract|
14.2 Legal rights for EEA and UK users
If you are an EU or UK resident, you have certain rights in respect of the information that we hold about you. Below is a short overview of those rights:
- Access. With some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that we hold about you. Where the data is data that you have given to us, you have the right to receive your copy of it in a common electronic format, and to provide copies of it to other people if you wish.
- Correction. You have the right to have the personal data we hold about you corrected if it is factually inaccurate. This right does not extend to matters of opinion, such as views expressed in editorial content.
- Deletion. In some limited circumstances, you have the right to have personal data that we hold about you erased (the “right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, because we are obliged to do so by law).
- Objection. You have the right to object to our processing of your personal data where we rely on “legitimate interests” as our legal basis for processing, but we may be able to continue processing if our interest outweighs your objection.
- Withdrawing consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue.
14.3 How to exercise your rights
To exercise your rights, email email@example.com. In order to protect your privacy and that of others, we will ask you to prove your identity before we take any steps in response to a request you have made. If a third party is making a request on your behalf, we will ask them to prove that they have your permission to act for you.
We may contact you to ask you for further information to help you exercise your legal rights or to speed up our response. We will try to respond to requests within one month and we will let you know if we need to take longer, for example, because your request is complicated. We may have an overriding lawful basis for processing your personal data, or certain exemptions may apply. If we refuse your request, we will explain why.
You have the right to complain about data privacy matters to the Information Commissioner’s Office (www.ico.org.uk), or the relevant data protection regulator in your country of residence. You can contact the ICO on 0303 123 1113. We invite you to raise your concerns with us first, so that we can try to resolve them.
15. Privacy Information for California Residents
15.1 California Privacy Rights
This section provides you with our practices regarding the collection, use, and disclosure of your personal data. It also explains your rights regarding your personal data that we collect (as set forth in the California Consumer Privacy Protection Act or the “CCPA”). The following chart summarizes our personal data collection, use, and sharing practices in the preceding 12 months since we last updated this Policy on January 1, 2020.
|Category of Information||Source of Information||Purposes of Collection||Vendors and Other Entities with Whom We Share this Information||Disclosed or Sold for a Business or Commercial Purpose|
|A. Identifiers, e.g., your name, address, email address, and username||You||To process your requests for products/services and/or information, to communicate with you, to improve our Services, to enforce our User Agreement, to register your Account, for the administration and protection of our business, and to comply with applicable law, regulations, and legal and regulatory processes. If you opt-in to do so, we may use your name and email address for our marketing purposes and to help our business partners with their marketing.||Service providers who assist in providing services on our behalf If you opt-in to do so, our business partners.||Yes|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), e.g., your name and address||You||To process your requests for products/services and/or information, to communicate with you, to improve our Services, to enforce our User Agreement, to register your Account, for the administration and protection of our business, and to comply with applicable law, regulations, and legal and regulatory processes. If you opt-in to do so, we may use your name and email address for our marketing purposes and to help our business partners with their marketing.||Service providers who assist in providing services on our behalf If you opt-in to do so, our business partners.||Yes|
|C. Protected Classification characteristics under California law, e.g., your racial or ethnic origin, religion, or sexual orientation||You||If you are in the U.S. ONLY and you opt-in to do so, to improve our Services, better understand our customer base, meet our diversity and inclusion goals; and to help our business partners do the same.||Service providers who assist in providing services on our behalf. If you are in the U.S. ONLY and you opt-in to do so, our business partners.||Yes|
|D. Commercial Information, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||You and your device||To fulfil your requests for products or services, to improve our Services||Service providers who assist in providing services on our behalf. Our business partners.||Yes|
|E. Internet or Electronic Network Activity Information, e.g., browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, or questions and other messages you address to us directly through online forms or by email||You and your device||To process your requests for products/services and/or information, to communicate with you, to improve our Services, to enforce our Terms of Service, to register your Account, for the administration and protection of our business, and to comply with applicable law, regulations, and legal and regulatory processes.||Service providers who assist in providing services on our behalf. Our business partners.||Yes|
|F. Other Identifiers and Internet Activity Information, e.g., IP address; similar information||You and your device||To process your requests for products/services and/or information, to communicate with you, to improve our Services, to enforce our Terms of Service, to register your Account, for the administration and protection of our business, and to comply with applicable law, regulations, and legal and regulatory processes.||Service providers who assist in providing services on our behalf. Our business partners.||Yes|
|G. Inferences about personal preferences and attributes drawn from profiling||You and your device||To improve our Services, to help us better understand our customer base and to help our business partners improve their offerings.||Service providers who assist in providing services on our behalf. Our business partners.||Yes|
If you are a California resident, you have the right to know what personal data we collect, disclose, and “sell” about you (as that term is used in the CCPA). Additionally, you have the right to access, delete and opt out from the “sale” of your personal data. Specifically, California residents may request that we:
- Inform you about the specific pieces of personal data we collected about you (also called a data portability request)
- Provide you access to and/or a copy of certain personal data we hold about you.
- Delete certain personal data we have about you.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
Note for non-California residents: We will seek to honor requests to exercise the above rights made by non-California residents to the extent required by applicable law.
Please note that certain data may be exempt from such access, data portability, and deletion requests under California law. For example, we need to retain certain data in order to provide the Services to you.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal data. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require you to create an Account with us. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
15.2 California Notice of Right to Opt-Out of “Sale”
California residents may opt out of the “sale” of their personal data. California law broadly defines “sale” in a way that may include allowing third parties to receive certain data, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on our Services or other sites and apps. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you content relevant to you.
Depending on what Services you use, we may sell (as defined by California law) the following categories of data for such advertising purposes:
- A. Identifiers
- B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- D. Commercial information
- E. Internet or electronic network activity information
- F. Other identifiers and internet activity information
- G. Inferences about personal preferences and attributes drawn from profiling
If you would like to opt-out of our use of your personal data for such purposes, you may do it by contacting us at firstname.lastname@example.org This will cause data to cease to be added to any cookies or other tracking technologies that have been set on our Services or block them entirely. Please note that you will need to opt-out again if you visit one of our Services from a different device or browser or if you clear your cookies. Please note that we do not knowingly sell the personal data of minors under 18 years of age without legally-required affirmative authorization.
15.3 California Shine the Light Disclosure
Under California Civil Code sections 1798.83- 1798.84, California residents are entitled to ask for a notice identifying the categories of personal customer data which we share with our affiliates and/or third parties for their own direct marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a request to the following address: email@example.com