Members engage with their network, gain professional insights and find business opportunities. Content on some of the Services is available to Visitors on a limited feature and time basis.
1. Information We Collect
1.1 Information You Provide to Us
To create an account you provide data including personal information such as your name, email address and/or mobile number, a password and allow us to access your email messages and settings, view your contacts and view your calendars. If you register for a premium Service, we ask you for payment (e.g., credit card) and billing information.
You provide data to create an account with us.
Profile and Email Access
You have choices about the information on your profile and the extent to which we have access to your email messages and settings, contacts and calendars (“Member Collected Data”), which includes Meta-Data as defined below. Member Collected Data helps you to get more from our Services. It’s your choice whether to include sensitive information on your profile. Please do not post or add personal data to your profile that you would not want to be publicly available.
In order to operate our Services, we need access to certain meta-data contained in your email messages, calendars and contacts (“Meta-Data”), including information about your contacts’ personal and/or professional information. Our access to the body of emails and calendar items is controlled by you (“Body-Data”).
You create your profile and determine our access level with respect to certain Member Collected Data (a complete profile helps you get the most from our Services).
To provide you a fast and efficient resolution, we will collect information such as your name, email address, as well as other content you may provide if you contact us. We also may create event logs to diagnose product related issues, and gather information related to service issues. To improve customer service, subject to applicable laws, we may also analyze any feedback provided through voluntary customer surveys.
You may choose to provide us information when you fill in a form, conduct a search, update or add information to your Account, respond to surveys, provide feedback, request support or use other features of our Services. We may also collect information at other points in our Services when clearly stated that information is being collected.
Member Collected Data
We collect Member Collected Data from you when you provide, post, upload, import, sync or integrate it to or with our Services, such as when you fill out a form or provide feedback to our Services by confirming, rejecting or refining our suggestions and other insights provided to you or complete email, contact and calendar integration at registration. When you import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list). When you sync your email or calendars with our Services, we will collect Meta-Data such as your “email header” and calendar meeting information (e.g. times, places, attendees and contacts) and, subject to your settings, Body-Data such as the text from the main body of email correspondence.
You give other data to us, such as by syncing your email, address book or calendar.
1.2 Information From Others
Content and Email Information
You and others may post content in the public domain, or others may allow access that includes or yields information about you on our Services (as part of Member Collected Data we receive from them that includes information about you). Unless you opt-out, we collect this information and make it available as part of our Services (e.g. suggestions for your profile, or notifications to others for their contact purposes and network insights and other information), which we may use from time to time to enrich our Services, our data and the data-based insights and recommendations provided thereby. You cannot opt-out of our collection of Member Collected Data about you that we collect from other Members, which we may also use from time to time to enrich our Services, our data and the data-based insights and recommendations provided thereby.
Others may post or add information about you.
Contact and Calendar Information
We receive Member Collected Data about you when you or others import or sync their address book or calendar with our Services, or send messages using our Services to the extent available.
Others may sync their contacts or calendar with our Services.
We receive personal data about you when you use the services of our customers and partners, such as employers and your customers or vendors providing us their data.
Customers and partners may provide data to us.
1.3 Service Use
We log usage data when you visit or otherwise use our Services, including our websites, applications and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., contact information) or ads (on or off our sites and apps), perform a search or install one of our mobile apps. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
We log your visits and use of our Services, including mobile apps.
1.4 Cookies, Web Beacons and Other Similar Technologies
We collect data through cookies and similar technologies.
1.5 Your Device and Location
When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location. Most devices allow you to prevent location data from being sent to us and we honor your settings.
We receive data from your devices and networks, including location data.
We collect information about you when you send, receive, or engage with messages in connection with our Services.
If you communicate through our Services, we learn about that.
1.7 Workplace Provided Information
An employer (or other person or entity procuring our Services for your use) may provide us information about their employees or contractors who make use of these Services.
When your employer buys a premium Service for you to use at work, they may give us data about you.
1.8 Sites and Services of Others
We receive information about your visits and interaction with services provided by others when you log-in with 4Degrees or visit others’ services that include our plugins, ads, cookies or similar technologies.
We get data when you visit sites that include our plugins, ads or cookies or log-in to others’ services with your account.
We are improving our Services, which means we get new data and create new ways to use data.
2. How We Use Your Data
How we use Member Collected Data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use Member Collected Data that we have about you to provide, support, personalize and make our Services (including ads) more relevant and useful to you and others.
We use your data to provide, support, personalize and develop our Services.
Our Services help you connect with others, find and be found for work and business opportunities, stay informed and be more productive.
We use your data to authenticate you and authorize access to our Services.
Our Services allow you to stay in touch, in communication and up to date with colleagues, partners, clients, and other professional contacts.
We will use Member Collected Data about you (such as contacts you have viewed or data provided through address book uploads or partner integrations) to suggest ways and times for you to connect with others (e.g. people within your contacts) that we have reason to believe will improve your “network health”. It is your choice whether to act on the recommendations provided to you by our Services.
Visitors have choices about how they act on our recommendations.
Our Services allow you to stay informed about your professional network and your “network health”. We use the information about you to recommend relevant actions with our Services that you might assist you in to pursuing your next opportunity. We use your content, activity and other data, including your name and picture (all of which is sourced via enrichment partners or publicly available sources), to provide notices to your network and others.
Our Services allow you to collaborate with colleagues, search for potential clients, customers, partners and others to do business with. Our Services offer suggestions to allow you to communicate with other professionals and schedule and prepare meetings with them. Subject to your settings, we may scan messages to provide “bots” or similar tools that prompt tasks such as scheduling meetings, draft responses, summarize messages or recommend next steps.
We will contact you through email, notices posted on our websites or applications, messages to your 4Degrees inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices. We may also enable or suggest communications between you and others through our Services, subject to your settings.
We contact you and suggest communications between members. We offer settings to control what and how often you receive some types of messages.
2.3 No Advertising
2.4 Developing Services and Research
We develop our Services and conduct research.
We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.
We seek to create opportunity for members of the global workforce and to help them be more productive and successful. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data. These insights will not be based on email derived Meta-Data or Body-Data.
Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys and you have choices about the information you provide. You may opt out of survey invitations.
2.5 Customer Support
We use Member Collected Data (which can include your communications) needed to investigate, respond to and resolve complaints and Service issues (e.g., bugs).
We use data to help you and fix problems.
2.6 Aggregate Insights
We use Member Collected Data to produce aggregate insights that do not identify you. For example we may use your data to generate statistics about our users, their profession or industry or the demographic distribution of visitors to a site.
We use data to generate aggregate insights.
2.7 Security and Investigations
We use data for security, fraud prevention and investigations.
2.8 Enriching Contact Records
By selectively combining your contacts and relationship information with publicly available data, and aggregated information from other 4Degrees users we can provide you and other users with enhanced features and Services. A limited set of information about your Contacts may be combined with similar information from other Users’ Contacts, as well as Public Data and other publicly available information and information we receive from third parties, to build more complete contact records of individuals. These records reside in the 4Degrees Database and may be processed for the purposes described in the remainder of this section.
Your Contact information may be combined with other Users of our Services data to provide contact enrichment. In contact enrichment, a User is able to match a Contact that they possess to our completed records, and receive back a subset of the contact information from the relevant Completed Contact Data for that individual. For example, we may share an individual’s name to support features including but not limited to contact search. We also may share public social handles to support Contact Enrichment. Certain professional information including but not limited to organizational affiliation and job title, that can be inferred or extracted from a business card or email signature, may also be shared. We will never share physical addresses, personal phone numbers, or email addresses unless you have given us your specific and unequivocal permission to share that information or we have secured the information via pseudonymization (e.g., through cryptographic hashing). We will never share any of your private notes or emails with any other User.
We also use Completed Contact Data to provide Contact Search, such as when an User of our Services wants to retrieve a set of Completed Contact Data for a contact they already know, based on a set of search criteria (e.g., inputting their email address). With the exception of the shareable contact elements described above, all contact elements in a Completed Contact are considered private and are not shared with other Users of our Services . However, any contact element (including those private elements) may be used for lookup and matching purposes.
2.9 Purposes and Legal Basis for Processing.
The purposes for processing are described in detail in the above subsections of Section 2. In the Use of our Services when we act as data controller the legal basis for processing is as follows:
– Providing Services: This enables us to deliver the Services to you and honor our Terms of Service to fulfill our contracts with our customers.
– Developing the Services and Research: This use is based on our Legitimate Interest in improving our services for you and other users.
– Communications: This use is based on our Legitimate Interest in marketing our Services to grow our business.
– Enriching Contact Records: This use is necessary to deliver certain Services to you and is based on your explicit Consent.
3. How We Share Information
3.1 Our Services
Your contact profile information (from public sources or our enrichment partners) is fully accessible to us for providing such information to other Members and customers of our Services in order to provide network insights and other information to such parties just as we might access their profile information to provide you with network insights and other information. As detailed in our setup and general settings, the extent to which we may access and provide information about you to other Members is subject to certain limitations determined by you; however, the more restricted our access, the greater impact it may have on our ability to provide our Services.
Subject to your settings, any information you include on your profile will be seen by others.
Your employer may offer you access to our enterprise Services. They can also buy access for you to our other products. Your employer can review and manage your use of such enterprise Services.
Depending on the enterprise Service, before you use such Service, we will ask for permission to share relevant data from your profile or use of our non-enterprise Services. We understand that certain activities are sensitive and so we will allow you to determine which information is shared with your employer through our Services to the extent you use non-enterprise Services and enterprise Services.
In certain cases, your employer can see how you use Services they provided for your work. We will not show them your information as it pertains to Services that they did not procure for your benefit.
3.2 Communication Archival
Some Members (or their employers) need, for legal or professional compliance, to archive their communications and activity, and will use services of others to provide these archival services. We will seek enable such archiving outside of our Services. For example, a financial advisor needs to archive communications with her clients through our Services in order to maintain her professional financial advisor license.
Regulated Members may need to store communications outside of our Service.
3.3 Others’ Services
If you opt to link your account with other services, certain data will become available to them. The sharing and use of that data will be described in, or linked to, a consent screen when you opt to link the accounts. You may revoke the link with such accounts.
Subject to your settings, excerpts from your profile will appear on the services of others (e.g., search engine results, mail and calendar applications). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.
You may link your account with others’ services so that they can look up your profile or your Member Collected Data on such platforms.
Subject to your preference, other services may look-up your profile.
3.4 Service Providers
We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated to not to disclose or use it for other purposes.
We may use others to help us with our Services.
3.5 Legal Disclosures
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of 4Degrees, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
We may need to share your data when we believe it’s required by law or to protect your and our rights and security.
3.6 Change in Control or Sale
3.7 Onward Transfer and Consent to International Processing
If you are visiting from the European Union, Switzerland or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data, including sensitive data, by us from your region to countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area, including the United States. By providing your personal information, you consent to any transfer and processing in accordance with this Policy. In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-US Privacy Shield or Swiss-US Privacy Shield, 4Degrees is potentially liable.
4. Your Choices & Obligations
4.1 Data Retention
We retain Member Collected Data you provide while your account is in existence or as needed to provide you Services. Even if you only use our Services infrequently, we will retain your information and keep your profile open until you decide to close your account. This includes information that you have made available to 4Degrees for the purposes of improving the Services for both you and other Users of our Services. In some cases we choose to retain certain information in a depersonalized or aggregated form
We keep most of your personal data for as long as your account is open.
4.2 Rights to Access and Control Your Personal Data
We provide many choices about the collection, use and sharing of your Member Collected Data, from deleting or correcting data you include in your profile and controlling access to the body of email messages to calendar settings and contact relationship controls. We offer you access to the Member Collected Data we have about you.
You can access or delete your personal data. You have many choices about how your data is collected, used and shared.
4.3 Account Closure
If you choose to close your 4Degrees account, your profile will generally stop being visible to others on our Services promptly within a short period of time. We generally delete closed account information within 30 days of account closure, except as noted below.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.
Meta-Data that we have collected from information you have shared with us or others (e.g., through access to your email, contacts or calendars) will remain available to us for inclusion in our data archive after you closed your account or deleted the information from your own profile; however, Body-Data that you provided to us will be destroyed within a reasonable amount of time once you closed your account or deleted the information from your own profile. Notwithstanding the foregoing, we do not control data that other Members provided to us and that will remain included in the Services or copied out of our Services. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.
We keep some of your data even after you close your account.
4.4 Data Subject Rights
The purpose for processing, categories of Personal Data, and categories of recipients of Personal Data are described above. Our lawful basis for processing is our legitimate interest in providing relationship management services to our Users, enabling them to better manage and build their relationships with you. Personal Data will be retained as long as necessary to serve that purpose or until you decide it is not in your best interest to keep your information in the 4Degrees Database. You have the right to object to the processing of your Personal Data at any time.
If you have contacted us directly for the purposes of exercising your rights under the applicable privacy framework (e.g., GDPR), we may ask for your explicit permission to share some of your Personal Data. If you choose to give permission to share that information, then our lawful basis for processing is your Consent. You have the right to withdraw your Consent at any time. You also have the right of portability for any data that you have provided us.
You have the right to request from us access to and rectification or erasure of Personal Data or restriction of processing. You may exercise these rights by contacting us directly. Requests for erasure cannot be met because erasing your Personal Data would not achieve the desired result of your Personal Data not being in our system: we receive data continuously and would likely have your Personal Data in our system again quickly. Instead, we will mark your Personal Data as “hidden” and “restrict processing” such that your data is no longer used in providing our service and is no longer made available to anyone.
You have the right to request the sources of your Personal Data. You may do so by contacting us as indicated in the “Contact Us” section below. Please note that to protect the rights of other data subjects, we may only be able to provide you with the general categories of sources. We may transfer, store, and process your information with service providers based in the United States.
5. Other Important Information
We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please take precautions to safely use our Services, including two-factor authentication.
We monitor for and try to prevent security breaches. Please use the security features available through our Services.
5.2. Direct Marketing and Do Not Track Signals
We currently do not share Member Collected Data with third parties for their direct marketing purposes without your permission.
5.3 Privacy Shield Notice
In compliance with the Privacy Shield Principles, 4Degrees commits to resolve complaints about our collection or use of your personal information. EU or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact 4Degrees at firstname.lastname@example.org.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, 4Degrees is subject to the authority of the Federal Trade Commission. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles. 4Degrees has committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.
5.4. Contact Information
If you have any questions or complaints about this Privacy Notice, please contact us at: email@example.com.
Data Protection Officer (DPO)
You can contact us or use other options to resolve any complaintsc,