Our Collection and Use of Information

Information You Provide to Us

We collect personal information, such as your personal and business name, email address, physical address, and your phone number when you register and agree to our COU and utilize our Service. This information is referred to herein as your “Personal Information.” Our Service may utilize your Personal Information to integrate with third-party service providers.

You may utilize the Service to integrate with a third-party credit card payment processing company to collect payment information, including your credit card number, billing address and phone number. We will share this payment information with the third-party processing company as detailed below in “How We Share Your Information: With Trusted Service Providers and Business Partners.” We do not store your payment information.

We may use your Personal Information to send you Service-related notices (including any notices required by law. We may also use your email address to send you announcements and information about other products or services (including third party services) that you may be interested in (together, the “Marketing Messages”).

Your Content

Your use of the Service may involve you uploading or inputting various content into the Service; including but not limited to: end-customer names, product information (including name, image, descriptions and pricing), workflow permissions and rules, attachments, project names, and group names, (together, the “Content”).

Four51 and its Service may view and utilize your Content only as necessary (i) to maintain, provide and improve the Service; (ii) to resolve a support request from you; (iii) if we have a good faith belief, or have received a complaint alleging, that such Content is in violation of our COU; (iv) as reasonably necessary to allow Four51 to comply with or avoid the violation of applicable law or regulation; or (v) to comply with a valid legal subpoena or request that meets the requirements of our Law Enforcement Guidelines. We may also analyze the Content in aggregate and on a de-identified basis, in order to better understand the manner in which our Service is being used.

Data Retention

For active Four51 customers and contracts, all data is retained during the customer lifecycle. Once a customer has terminated a contract, data associated with that contract is retained for a period of 90 days after termination. After this time, the data is deleted. Data deleted by Four51 customers is flagged in the database, not available through the interface, and deleted after 90 days. Customers may request a different timeframe to meet their requirements.

Information We Collect Automatically

Log Files

When you use the Service, our servers automatically record certain information in server logs. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type and settings, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, mobile carrier, date and time stamp information and other such information. Log files help us to monitor, analyze, improve and maintain the Service and to diagnose and fix any Service-related issues.

Device Identifiers

When you access the Service using a mobile device, we collect specific device information contained in your mobile device’s “device identifier.” This device identifier includes information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We may associate this device identifier with your Service account and will use data associated with your device identifier to customize our Services to your device and to analyze any device-related issues.

Location Information

We may collect and process information about the location of the device from which you are accessing the Service. Location data may convey information about how you browse the Service and may be used in conjunction with personally identifiable information.

Our Cookie Policy

Four51 uses technologies like cookies, pixel tags and web beacons to provide, monitor, analyze, and improve the Service. For example, a session cookie is used for user authentication to provide temporary access to the data you can see based on your identity and assigned permissions.  You can block cookies on your web browser; however please be aware that some features of the Service may not function properly if the ability to accept cookies is disabled. We may utilize third-party service providers to provide us with analytics services and to serve advertisements on our behalf across the Internet. These parties may utilize cookies or similar technologies to gather information about your browsing activities over time and across different websites following your use of the Service. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyze how users use the Service and to enhance their experience when they use the Service. To opt-out of having your data used by Google Analytics please go to: https://tools.google.com/dlpage/gaoptout/.

How We Share Your Information

We may share the information we collect from you with third parties as detailed below.

As Directed By You

We will display your content within the service as directed and controlled (as directed by our COU through your issuance and maintenance of end-user logon credentials) by you.

We will display your Personal information within your Service account and elsewhere on the Service at your direction and in accordance with the site configuration that you have designed and/or instructed us to employ. You can review and revise (subject to the Service capabilities) the use of your Personal information at any time.

If you elect to use a third-party application to access or integrate with the Service, then we may share or disclose your account and Personal information and your Content with that third-party application as directed by you. Please remember that we are not responsible for the privacy practices of such third parties, so you should make sure you trust the application and that it has a privacy policy acceptable to you.

With Four51 Trusted Service Providers and Business Partners

We utilize trusted third-party service providers to assist us in delivering, improving, and protecting our Service. For example, we use third parties to host our Service, send out email updates, perform monitoring and analysis related to the operation and security of our Service, or process payments. We also store Personal Information in locations outside of our direct control (for instance, on servers or databases owned and operated with third-party hosting providers).

These service providers may have access to your Content and Personal Information for the limited purpose of providing the service we have contracted with them to provide. They are required to have a privacy policy and security standards in place that are at least as protective of your Content and Personal Information as is this Privacy Policy (including those provisions related to compliance with the EU-US and Swiss-US Privacy Shield). Four51 will take all reasonable and appropriate steps necessary to ensure that any third party who is acting as a “data processor” under EU and Swiss terminology is processing the personal information we entrust to them in a manner that is consistent with the EU-US and Swiss-US Privacy Shield Principles. Four51 is potentially liable in cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, respectively.

With Law Enforcement or In Order to Protect Our Rights

We may disclose your information (including your personally identifiable information) in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We may also disclose your information to our legal counsel, governmental authorities or law enforcement if we believe that it is reasonably necessary to do so in order to comply with a law or regulation; to protect the safety of any person; to address fraud, security or technical issues; or to protect Four51’s rights or property.

In an Aggregate and Non-Personally Identifiable Manner

We may disclose aggregated non-personally identifiable information (such as aggregated and de-identified usage data, etc.) about the overall use of our Service publicly or with interested third parties to help them understand, or to help us improve, the Service.

In Connection with a Sale or Change of Control

If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Service can continue to operate. In such case, your Content and Personal Information would remain subject to the promises and commitments contained in this Privacy Policy until this Privacy Policy is updated or amended by the acquiring party upon notice to you.

How We Protect Your Information

The security of your information is important to us. When you enter sensitive information (such as a credit card number) as part of our service, we encrypt the transmission of that information using industry-standard encryption, and do not store such information.

Four51 uses commercially reasonable and industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your information. For example, we continuously and regularly back-up your data to help prevent data loss and aid in data recovery. We also guard against common web attack vectors, host data in secure SSAE18 audited data centers, maintain SOC 2+ and PCI compliance, and implement firewalls and access restrictions on our servers to secure our network and better protect your information.

If you have any questions about the security of our Service, you can contact us at security@four51.com

Risks Inherent in Sharing Information

Although you control your Content and what Personal Information is included, and we take reasonable steps to maintain the security of the Personal Information utilized with our Service, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you share your Content and we are not responsible for third party circumvention of any privacy settings or security measures ofthe Service.

Your Choices About Your Information

You may, of course, decline to submit personally identifiable information through the Service, in which case Four51 may not be able to provide certain elements of our Service to you. You have a right to access information we hold about you. You may update or correct your account information at any time by logging in to your Four51 account. For questions or inquiries regarding the correction or deletion of your personally identifiable information on the Service you may contact us at privacy@four51.com.

Residents of EU/UK may have additional rights under GDPR

If you are a resident of the European Union (“EU”) or the United Kingdom (“UK”), you may have certain additional rights, as detailed below. For purposes of this notice, “personal data” has the meaning ascribed in the EU General Data Protection Regulation.

Processing Basis and Consequences

To process your personal data, we rely on the following legal bases: We comply with ICO justification 6(1)(f ) – Necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.

Your Rights

To the extent a specific element of our processing of your personal data relies upon your consent, you may withdraw such consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. You may withdraw your consent at any time by notifying us via the Contact Us section in this document. If you wish to object to the processing of your personal data on the basis of legitimate interest to you directly, please Contact Us. If you do not provide us with your personal data, we may not be able to fulfill the requested purpose of collection, such as to provide online ordering services. However, unless otherwise specified, not providing your personal data will not result in any consequences for you.

Additional data privacy rights:

Below please find information on additional rights you may have under applicable law:

Access:

Access: You may request that we confirm whether or not we are processing your personal data. If we are, you may request a copy of your personal data, which we will provide free of charge, together with information about the such processing, such as the purposes of the processing and the categories of personal data concerned. However, this is not an absolute right and the interests of other individuals may restrict your right of access. For further copies, we may charge a reasonable fee based on administrative costs. We may decline requests which are excessive, particularly if repetitive.

Rectification:

You may edit some of your personal data in your Four51 user account. You may also ask us to change, update or fix your personal data in certain cases, particularly if it’s inaccurate.

Ensure:

You may request the erasure of your personal data. We will process requests within 30 days from the date of receipt.

Restrict Processing:

You may ask us to restrict the processing of your personal data under certain circumstances, such as if their Personal Data is inaccurate or unlawfully held.

Data Portability:

You may ask for a copy of the specific personal data you provided to us in a structured, commonly used and machine-readable format and you may have the right to transmit this data to another entity.

Object:

You may object to the processing of your personal data on grounds relating to your particular situation. If you have a right to object and you exercise this right, your personal data will no longer be processed by us, unless there are overriding compelling legitimate grounds for the processing or as otherwise provided under applicable law.

Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law.

To exercise data subject rights under EU General Data Protection Regulation, please submit your request by following the instructions in the Contact Us section below.

Four51 Support Sites

Information you provide in comments to our public facing support sites, including blogs are public and may be read, collected, and used by others who view those sites. Your posts will remain even after you cancel your Service account.

EU-US Privacy Shield Framework

Four51 complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the European Union and Switzerland to the United States, respectively. Four51 has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

In compliance with the EU-US Privacy Shield and Swiss-US Privacy Shield Principles, Four51 commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Four51 at: privacy@Four51.com.

Four51 has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Four51, please visit the BBB EU Privacy Shield web site at www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Four51 is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to its compliance with the provisions of the EU-US and Swiss-US Privacy Shield.

Children’s Privacy

Our Service is not directed to persons under 18. Four51 does not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register for an account on the Service. If we become aware that we have collected personal information from a child under age 18 without verification of parental consent, we take steps to remove that information. If you believe that we might have any information from or about a child under 18, please contact us at privacy@four51.com.

International Data Transfer

We may transfer information that we collect about you, including personally identifiable information, to affiliated entities, or to other third parties (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Privacy Policy.

Links to Other Web Sites

We are not responsible for the practices employed by websites linked to from within the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Four51 service to another website, our Privacy Policy is no longer in effect and your activities on that third-party website are subject to such third party website’s own rules and policies.

Do Not Track Signals

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. We currently do not respond to “do not track” signals.

Changes to Our Privacy Policy

If we change our Privacy Policy, we will post those changes on this page to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you represent a licensee of Four51’s eCommerce technology (AKA Controller)

If you have any questions about this Policy or the data we process for you, please contact us using our online Customer Support system. To do this, begin by logging on to your Four51 administrative environment, then follow these steps:

  1. In the upper right-hand part of the Four51 Storefront Admin screen, hover over Resources and then select Knowledge Base
  2. Select Cases
  3. Select Create New Case
  4. From the Select Case Record Type drop-down menu, select Privacy Policy Inquiry and then click Continue
  5. Complete the required fields and select Submit

You will receive an automated email reply acknowledging receipt of your inquiry. A Four51 employee will make best and reasonable efforts to respond to your inquiry within 24 hours excluding weekends and holidays. Four51’s response may be a request for more information or acknowledgement that the action you requested has been completed and the inquiry will now be closed.

If you are an end-user of a Four51-powered eCommerce site (AKA Data Subject)

Four51 is the underlying eCommerce technology that branded-products vendors use to enable online ordering. These vendors are responsible for end-user account set-up and administration, and the creation, ordering, and fulfillment of the products you order.

If you have any questions about this Policy or the data we process, please contact the vendor who set up your online storefront. (Note that this may be an internal function at your company.) Check the homepage of your online storefront — many vendors put a Contact Us link there.

If you don’t know the name of the vendor that set up your catalog, your company’s Marketing or Purchasing departments are good places to start.

Finally, you may send email to privacy@four51.com and Four51 will attempt to contact the vendor responsible for your online storefront.

You may also contact us by postal mail at:

Four51, Inc.
110 North 5th Street, Suite 300
Minneapolis, MN 55403
Attention: Legal Department