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FOUR WINDS INTERACTIVE - PRIVACY POLICY

Four Winds Interactive LLC ("FWI") values your privacy and FWI desires to ensure
your experience with FWI and its subsidiaries and related companies
(collectively "FWI", "we," "our" or "us") and all our websites and all our
related subdomains (the "Sites") and all our products, mobile applications,
software, blogs, forums, channels, sharing and quizzing services (collectively
with the Sites, the "Services") are as satisfying and safe as possible. In that
regard, we have established for the Sites and/or Services the following privacy
policy to explain and describe what personal information FWI collects on our
Sites and/or Services, how FWI uses it and your options regarding information
FWI may collect about you. By accepting this Privacy Policy, you expressly
consent to the information handling practices described in this Policy. Your
continued use of our Sites and/or Services or any other content, products or
other services covered by this Policy constitutes your acceptance and agreement
to this Policy and any updates.
FWI is the controller of your Personal Information as described in this Privacy
Policy, unless specified otherwise. This Privacy Policy does not apply to the
extent we process Personal Information in the role of a processor or service
provider on behalf of our customers, including where we offer to our customers
various products and services through which our customers (or their affiliates):
(i) deploy content not provided by FWI; (ii) manage and develop their own
internal or external communications via the Services; (iii) otherwise collect,
use, share, or process Personal Information via our products and services.
Contacting Us
If you have questions about this policy, please feel free to contact us at:
Four Winds Interactive LLC
1221 Broadway
Denver, CO 80203 USA
Privacy@fwi.com
303-313-3000


1. INFORMATION WE COLLECT
In describing our collection, use, and sharing of information in this Policy, we
refer to our collection and use of "Personal Information." "Personal
Information," as used in this Policy, is personally identifiable information,
which is information that directly identifies an individual,  including:
•    First and last name
•    Business contact information (company, email, phone, physical business
address)
•    Personal contact information (email, cell phone)
•    Picture
•    Title
•    Position
•    Employer
•    ID data
•    Professional life data
•    Personal life data (in the form of security questions and answers)
•    Connection data
•    Localization data
•    Billing Information
•    IP addresses
•    Demographics
•    Passwords or other online contact information
We collect Personal Information, as well as non-personally identifiable
information on FWI Sites and/or Services. The collection of personal information
is limited to what is necessary to meet FWI’s objectives.

2. HOW DO WE COLLECT YOUR DATA
We collect Personal Information in two ways. First, we collect information you
provide to us in optional, voluntary submissions, such as in registration forms,
user profiles, promotional sign ups, requests for customer service, resumes and
curriculum vitae submissions. Second, some Personal Information may be collected
automatically. This is described below in "Passive Data Collection."
We may also obtain information, including Personal Information, from third party
sources. If we directly combine information from third parties with Personal
Information that we have collected, we will treat the combined information as
Personal Information and handle it in accordance with this Policy. In addition,
please note that we may solicit third parties to collect Personal Information on
our behalf and in such cases we instruct those third parties to comply with this
Policy and all applicable data protection laws.
Please be aware that we are prohibited from conditioning a child's participation
in any activity on that child disclosing more personal information than is
reasonably necessary to participate in that activity. You are under no
obligation to provide, and can decline to provide, any requested information at
any time. However, if you decline to provide personal information that is
reasonably necessary to participate in certain activities, you may not be able
to participate in those activities on certain Sites and/or Services.
PASSIVE DATA COLLECTION
We may receive passively-collected information through a variety of methods
including but not limited to:
•    Register online or place an order for any of our products or services.
•    Voluntarily complete a customer survey or provide feedback on any of our
message boards or via email.
•    Use or view our website via your browser's cookies
COOKIES
We may use a variety of methods, including "cookies" to collect information.
WHAT IS A COOKIE?
Cookies are text files containing small amounts of information which are
downloaded to your device when you visit a website. Cookies are then sent back
to the originating website on each subsequent visit, or to another website that
recognizes that cookie. Cookies are useful because they allow a website to
recognize a user's device. You can find more information about cookies at:
http://www.allaboutcookies.org
Cookies do lots of different jobs, like letting you navigate between pages
efficiently, remembering your preferences, and generally improve the user
experience. They can also help to ensure that advertisements you see online are
more relevant to you and your interests.
The cookies used on our Sites and/or Services have been categorized based on the
categories found in the ICC UK Cookie guide. A list of all the cookies used on
our Sites and/or Services by category is set out below.
PERFORMANCE COOKIES
FWI collects cookies on our Sites and/or Services to capture information about
page visits (e.g. “performance cookies.”) This information is anonymous and FWI
uses this information to deliver the most effective content to our visitors.
Information from the cookie is used to gauge page popularity, analyze traffic
patterns on our Sites and/or Services and guide development of other
improvements to our Sites and/or Services.
TARGETING, PERFORMANCE, AND FUNCTIONALITY COOKIES
In our email programs, FWI may employ some tracking methods (e.g. “targeting,
performance, and functionality cookies”). We may track “opens” via a tracking
pixel in the email-meaning we may track who opens our e-mail messages and when
you open our e-mail messages; and we may track “clicks” via encoded URLs-meaning
we track whether you click on the links contained in our e-mail messages. This
information is used internally only to help us deliver relevant messaging, and
is not shared with any third parties.
FUNCTIONALITY AND NECESSARY COOKIES
FWI does not require that you accept cookies and/or you may withdraw your
consent to our use of cookies at any time by adjusting your browser's privacy
settings, however, some functionality on our Sites (e.g. “functionality
cookies”), our product or service check-out process, and Services may be
disabled if you decline to accept cookies ( e.g. “necessary cookies”).
OPTING OUT OF COOKIES
By using the Sites and Services, you consent to the placement of the cookies
referenced above. You can, however, set your browser to notify you when you
receive a cookie, giving you the chance to decide whether or not to accept it.
You may also change your cookie settings through preference options in our Sites
and/or Services, where applicable. We will indicate that upon selecting your
preferences, that we will use a cookie to remember your preferences.
FWI never gives away information about our users. If you choose to provide
Personal Information about yourself, FWI will use this information only to
communicate directly with you. FWI will not sell, rent or otherwise disclose
that information to third parties unless such disclosure is necessary for the
purposes set forth in this Policy, by law or a policy or notice contained or
associated with a specific Site(s) and/or Service(s).
LOCATION-BASED SERVICES
We may collect, use, and share (with FWI partners and/or service providers)
precise location data, including the real-time location of your mobile or fixed
location device. Should this happen, such information will not be used to
further identify you.
LOCALIZATION OF DATA PROHIBITION
If you currently are under the protection of any regulations requiring your data
to remain in a specific locale, then do not consent to this Privacy Policy and
you are prohibited from providing any Privacy Data protected under such
regulations.
ANALYTICS TOOLS
We may use analytics tools and other third party technologies, such as Google
Analytics, Pardot, ZoomInfo, Salesloft, and 6Sense to collect information in the
form of various usage and user metrics when you use our online Sites and/or
Services. These tools and technologies collect and analyze certain types of
information, including cookies, email, name, IP addresses, device and software
identifiers, referring and exit URLs, onsite behavior and usage information,
feature use metrics and statistics, usage and purchase history, MAC Address,
mobile unique device ID, and other similar information.
For additional information on how these companies use data collected from our
websites or applications, please visit their website privacy policy:
• www.google.com/policies/privacy/partners/
• www.salesforce.com/company/privacy/
• www.zoominfo.com/about-zoominfo/privacy-policy
• www.salesloft.com/privacy-notice/
• www.6sense.com/privacy-policy/


3. HOW WE USE INFORMATION AND LEGAL BASES ON WHICH WE RELY
Generally, we use Personal Information to establish and enhance our relationship
with our users through four main categories: (1) Communication; (2)
Optimization; (3) Advertising; and (4) Sharing Features. Below, we provide some
specific examples of how we use the Personal Information and other information
we collect.
1) Communication and Responding to Request
We use your information, including Personal Information to provide you with
customer support, process transactions, respond to users' requests, send
newsletters and updates, send special offers and advertisements, seek your
opinions and feedback, and connect users to FWI Sites and/or Services, and to
products and services of our partners and licensees.
2) Optimization
We use your information, including Personal Information, behavioral metrics, and
other non-personally identifiable information to operate, provide, improve, and
maintain our Sites and Services, to develop new products and services, to
prevent abuse and fraud, to personalize and display advertisements and other
content for you, and for other administrative and internal business purposes.
3) Advertising
We may use your information, including Personal Information, behavioral metrics,
geo-location data, demographic data and marketing preferences to personalize and
display advertisements and other content for you.
4) Sharing Features
We use your information, including Personal Information and any other
information you submit directly or through passive means to provide you with
various ways to connect and share content (e.g., web content, user generated
videos, text, drawings, and screen and lecture captures, and quizzing features,
media, tools, services and other products) with third parties. For example, we
may provide you with the opportunity to email a link to certain content to
another person. To use this feature, we may require you to provide certain
Personal Information including your email address and the email address of each
person to whom you send the link.
We also may allow you to share links to content with users of various third
party services (e.g., social networking, search and sharing services). When
sharing links using one of these third party services, if you are not already
logged in to the third party service, you will need to supply login credentials
for it. If you are not a registered user of the third party service, you will
need to sign up for it. You are supplying the registration information or login
credentials for the third party service directly to that third party, and not to
us. By using any of these third party services to share links to content, you
permit us to access, use and disclose any information relating to your account
on each such third party service (such as your user name and profile
information) that is available to us through the third party service, including
through its application programming interface (API) pursuant to this Policy.
More specifically, FWI Sites and/or Services may use interfaces with social
media sites such as Facebook, LinkedIn, Twitter and others. If you choose to
"like" or share information from the FWI Sites and/or Services through these
services, you should review the privacy policy of that service. If you are a
member of a social media site, the interfaces may allow the social media site to
connect your site visit to your personally identifiable information resulting in
the public display of the same.
5) Legal Bases
We collect and process your Personal Information for the above purposes. Where
required by law, we obtain your consent to use and process your Personal
Information for these purposes. Otherwise, we rely on another authorized legal
basis (including but not limited to the (a) performance of a contract or (b)
legitimate interest) to collect and process your Personal Information, as
further detailed below.
•    Providing and promoting our Sites and Services (including necessary
functionality): We process your Personal Information to perform our contract
with you for the use of our Sites and Services and to fulfill our obligations
under the applicable terms of use; if we have not entered into a contract with
you, we base the processing of your Personal Information on our legitimate
interest to operate and administer our Sites and Services and to provide you
with content you access and request (e.g., to download content from our Sites);
•    Promoting the security of our Sites and Services: We process your Personal
Information by tracking use of our Sites and Services, creating aggregated
non-personal data, verifying accounts and activity, investigating suspicious
activity, and enforcing our terms and policies to the extent necessary for our
legitimate interest in promoting the safety and security of the Services, Sites,
systems and applications and the security of FWI generally, and in protecting
our rights and the rights of others;
•    Managing user registrations: If you have registered for an account with us,
we process your Personal Information by managing your user account for the
purpose of performing our contract with you according to applicable terms of
service;
•    Handling contact and user support requests: If you fill out a “Contact Us”
web form or request user support, or if you contact us by other means including
but not limited to via phone, we process your Personal Information to perform
our contract with you and to the extent necessary for our legitimate interest in
fulfilling your requests and communicating with you;
•    Managing event registrations and attendance: We process your Personal
Information to plan and host events or webinars for which you have registered or
that you attend, including sending related communications to you or to perform
our contract with you or where we receive your consent;
•    Managing, and participating in, contests, programs or promotions: If you
register for a contest, promotion, or a program, we process your Personal
Information to perform our contract with you or where we seek your consent. Some
contests, programs, and promotions have additional rules containing information
about how we will process your Personal Information;
•    Managing payments: if you have provided financial information to us, we
process your Personal Information to verify that information and to collect
payments to the extent that doing so is necessary to complete a transaction and
perform our contract with you;
•    Contract fulfilment: We may process your Personal information for the
purposes of fulfilling our contract with you or your employer (e.g. if you are
an authorized user of our products and Services or work for a service provider
or supplier to FWI). We do this where it is necessary for the performance of the
relevant contract;
•    Developing and improving or websites and services: We process your Personal
Information to analyze trends and to track your usage of and interactions with
our websites and services to the extent it is necessary for our legitimate
interest in developing and improving or websites and services and providing our
users with more relevant content and service offerings;
•    Assessing and improving user experience: We process device and usage data
as discussed above, which in some cases may be associated with your Personal
Information, to analyze trends and assess and improve the overall user
experience to the extent it is necessary for our legitimate interest in
developing and improving the Services;
•    Reviewing compliance with applicable usage terms: We process your Personal
Information to validate that you are a licensed user and to review compliance
with the applicable usage terms in our customer’s or user’s contract to the
extent that it is in our legitimate interest to ensure adherence to the relevant
terms;
•    Identifying customer opportunities: We process your Personal Information to
assess new potential customer opportunities to the extent that it is in our
legitimate interest to ensure that we are meeting the demands of our customers
and their users’ experiences;
•    Registering an hosting visitors to the office or at events: We process your
Personal Information for security, health, and safety reasons, to register
visitors and to manage non-disclosure agreements that visitors may be required
to sign, to the extent such processing is necessary for our legitimate interest
in protecting our offices, staff and visitors and our confidential information
against unauthorized access. In addition, certain health data (which may include
special categories of Personal Information) may be processed for office visits
and at events during the Covid-19 pandemic to ensure the safety and security of
our visitors and employees (where legally permitted) with your consent or where
necessary for reasons of public interest in the area of public health;
•    Recording phone calls: We may record phone calls for training, quality
assurance, and administration purposes. If required under applicable law, we
will obtain your prior consent or give you the option to object to a call being
recorded;
•    Displaying personalized advertisements and content: We process your
Personal Information to conduct market research, advertise to you, provide
personalized information about us on and off our Sites and to provide other
personalized content based upon your activities and interests to the extent it
is necessary for our legitimate interest in advertising our Sites ro, where
necessary, to the extent you have provided your prior consent
•    Administering surveys and conducting research, We process your Personal
Information in order to meet the goals set out in surveys or research as well as
to analyze our compliance with internal policies. If required under applicable
law, we will obtain your consent to process your response;
•    Sending communications: we will process your Personal information or device
and usage data, which in some cases may be associated with your personal
Information, to send you marketing information, product recommendations and
other non-transactional communications (e.g. marketing newsletters,
telemarketing calls, SMS, or push notifications) about us and our affiliates and
partners, including information about our products, promotions, news or events
as necessary for our legitimate interest in conducting direct marketing or to
the extent you have provided your prior consent;
•    Compliance with legal obligations: We process your Personal Information
when cooperating with public and government authorities, courts or regulators in
accordance with our legal obligations under applicable laws to the extent this
requires the processing or disclosure of Personal Information to protect our
rights or as necessary for our legitimate interest in protecting against misuse
or abuse of our Sites or Services, protecting personal property or safety,
pursuing remedies available to us and limiting our damages, complying with
judicial proceedings, court orders or legal processes, respond to lawful
requests, or for auditing purposes.
If we need to collect and process Personal Information by law, or under a
contract we have entered into with you, and you fail to provide the required
Personal Information when requested, we may not be able to perform our contract
with you.


4. WHEN WE DISCLOSE PERSONAL INFORMATION
We do not share Personal Information with third parties except in the limited
circumstances described in this Policy.
SERVICE PROVIDERS
We may provide Personal Information to third parties for their use in performing
internal business functions (e.g., payment processing, customer service,
maintenance, security, data analysis, email transmission, beta testing, or data
hosting) on our behalf. Additionally, some third party service providers may
collect information, including Personal Information, on our behalf. For example,
we may use a third party provider to assist us in utilizing data monitoring and
scouring technologies to obtain and transmit data on users of illegal copies of
some of our products. This data collection is not performed on users of legally
licensed products from FWI and its authorized distributors. If you are using an
illegal copy of our software and do not consent to the collection and
transmission of such data (including in the United States), cease using the
illegal version and contact us or one of our authorized distributors to obtain a
legally licensed copy of the product.
Whenever possible, we require such third-parties to only collect and use
Personal Information in accordance with this Policy, to maintain the
confidentiality, security, and integrity of such Personal Information, and for
no purpose other than providing us with our requested services.
LEGAL REQUIREMENTS
We may disclose Personal Information if we have a good-faith belief that doing
so is required by a subpoena, warrant, or other judicial or administrative order
or otherwise required by national security, law enforcement requirements,
statute, government regulation, or law. Additionally, we may disclose Personal
Information where we, in good faith, deem it appropriate or necessary to prevent
violation of our Terms of Use or End User License Agreements, or our other
agreements; take precautions against liability; protect our rights, property, or
safety, or those of a partner, any individual or the general public; maintain
and protect the security and integrity of our Sites and/or Services or
infrastructure; protect ourselves and our Sites and/or Services from fraudulent,
abusive, or unlawful uses; investigate and defend ourselves against third party
claims or allegations; or assist government regulatory agencies.
CHANGE OF OWNERSHIP
Information about our users, including Personal Information, may be disclosed as
part of any bankruptcy, merger, sale, transfer of company assets, acquisition,
or similar transaction. In the event of such a transaction in which your
Personal Information would be transferred to a third party, we will make
reasonable efforts to notify you. For example, we will post a notice of the
transfer of Personal Information on our Sites and/or Services and, if we have
your email address, we will send notice of the transfer of Personal Information
to that email address.
INTERACTIVE FEATURES
If you use a forum, blog, channel, bulletin board, chat room, user commenting
features, or other interactive sharing or social features that may be offered
through any of our Sites and/or Services, you should be aware that any Personal
Information you submit, display, or publish there is considered publicly
available and can be read, collected, used, and disclosed by other users of
those features, by us, and other third parties without restriction, except to
the extent limited access features are available, if any. To request removal of
your personal information from our blog, sharing service or community forum, for
example, contact us at the information provided in this Policy. In some cases,
we may not be able to remove your Personal Information, in which case we will
let you know if we are unable to do so and why.
THIRD PARTY SERVICES
This does not address, and FWI is not responsible for, the policies and
practices of third parties or other organizations that are not FWI service
providers, including policies and practices related to privacy and security,
data collection, processing, use, storage, and disclosure. This includes: (a)
any third party operating any site or service to which the Services link –the
inclusion of a link on the Services does not imply endorsement of the linked
site or service by us or by our affiliates; or (b) any app developer, app
provider, social media platform provider, operating system provider, wireless
service provider or device manufacturer (such as Facebook, Apple, Google,
Microsoft, LinkedIn, etc.).


5. THIRD PARTY ADVERTISING TECHNOLOGIES
In addition to using cookies and related technologies as described above, we
also may permit certain third party companies to help us tailor advertising that
we think may be of interest to users and to collect and use other data about
user activities on our Sites and/or Services (e.g., to allow them to tailor ads
on third party services). These companies may deliver ads that might also place
cookies and otherwise track user behavior. These companies may use information
about user behavior in order to provide customized advertisements across various
services and products. In the course of providing these services, products or
placing advertisements, these third party companies may place or recognize a
unique cookie on your computer, and may record information to these cookies
based upon your activities on any of our Sites and/or Services and on third
party websites. Each of these companies uses this cookie information according
to their own privacy and security policies. If you wish to not have this
information used for the purpose of serving you targeted ads, you may opt-out as
indicated in this Policy. Please note this does not opt you out of being
delivered advertising. You will continue to receive generic ads.


6. CHILDREN UNDER 13 OR MINORS
The Services are not directed to individuals under the age of thirteen (13), or
to minors as otherwise defined in local law or regulation, and do not knowingly
collect personal information from these individuals. We request that these
individuals do not provide personal information through the Services. However,
if you believe that we may have collected personal information from someone
under the age of thirteen (13) or to minors as otherwise defined in applicable
law or regulation, please let us know using the methods described in the Contact
Us section and we will take appropriate measures to investigate and, if
appropriate, delete that information.


7. YOUR RIGHTS
SUBMITTING PERSONAL INFORMATION
If you do not want to submit Personal Information that is necessary to provide
or use our Sites and/or Services or to fulfill your request, you will not be
able to access and/or participate in certain FWI Sites and/or Services. For
example, you will not be able to register for an account with us or participate
in certain contests or promotions, or access and/or use certain FWI product
features or online services. In addition, your refusal to submit Personal
Information may limit our ability to respond to your customer support inquiry in
a timely fashion.
EDITING PERSONAL INFORMATION
You may, at any time, update, correct, or delete certain Personal Information
that you have provided to us by updating your preferences within the site or
application or by contacting us at the mailing or email address set forth in
this Policy.
MARKETING CHOICES
If you want to remove yourself from individual communications, including
marketing promotions, advertisements, updates and email newsletters, simply
click the unsubscribe link in the communication or access your Account Settings
page when logged in. You also acknowledge and agree that there may be instances
where we may elect to notify you about administrative notices regarding your
account with us, such as to inform you about changes to our terms, conditions,
and policies, that your account may be expiring, or to provide you with other
relevant administrative information about your account. Because this information
is important to your interaction with us, you may not opt out of receiving these
communications.
ACCOUNT DELETION
If you submit Personal Information, you may delete your account with us at any
time. If you delete your account, your Personal Information and any and all
other account related information including, but not limited to, user profile
data, sharing data and any other data, credits specifically associated with your
account may be permanently deleted. If you choose to have an account with us in
the future, you will have to sign up for a new account as none of the
information you previously provided or saved within your account will have been
saved.
ADDITIONAL RIGHTS
You may have certain additional rights relating to your Personal Information,
subject to local data protection laws. Depending on the Applicable laws, these
rights may include the right to:
•    Access your Personal Information held by us;
•    Know more about how we process your Personal Information;
•    Rectify inaccurate Personal Information and, taking into account the
purpose of processing the Personal Information, ensure it is complete;
•    Erase or delete your Personal Information;
•    Transfer your Personal Information to another controller, to the extent
possible;
•    Object to any processing of your Personal Information;
•    Opt out of certain disclosures of your Personal Information to third
parties;
•    If you’re under the age of 16, or such other applicable age of consent for
privacy purposes in relevant individual jurisdictions, opt in to certain
disclosures of your Peronal Information to third parties;
•    Not to be discriminated against for exercising your rights described above;
•    Not be subject to a decision based solely on automated processing,
including profiling, which products legal effects (“Automated Decision-Making”);
and
•    Withdraw your consent at any time (to the extent we base processing on
consent), without affecting the lawfulness of the processing based on such
consent before its withdrawal.
Please note that Automated Decision-Making currently does not take place on our
Sites or in our Services.
Depending on the circumstances and the nature of your request it may not be
possible for us to do what you have asked, for example, where there is a
statutory or contractual requirement for us to process your data and it would
not be possible to fulfill our legal obligations if we were to stop. However,
where you have consented to the processing, you can withdraw your consent at
10any time by emailing us. In this event, we will stop the processing as soon as
we can. If you choose to withdraw consent it will not invalidate past
processing. If you want to exercise any of the rights described above or are
dissatisfied with the way we have used your information, please contact the
FWI's Privacy Team at Privacy@fwi.com. The same email address may be used to
contact the FWI's Data Protection Officer. We will seek to deal with your
request without undue delay, and in any event in accordance with the
requirements of the GDPR. Please note that we may keep a record of your
communications to help us resolve any issues which you raise. Please see the
contacting us section at the start of this policy to get the contact
information.


8. HOW TO EXERCISE YOUR RIGHTS
To exercise your rights, please contact us by using the information in Section
16 below. Your Personal Information may be processed in responding to these
rights. We try to respond to all legitimate requests within one month unless
otherwise required by law, and will contact you if we need additional
information from you in order to honor your request or verify your identity.
Occasionally, it may take us longer than a month, taking into account the
complexity and number of requests we receive.
Some registered users may update their user settings, profiles, organization
settings by logging into their accounts within the Services and editing their
settings or profiles.


9. SECURITY AND DATA RETENTION
If we become aware of security systems breach that may impact you, we may
attempt to notify you electronically so that you can take appropriate protective
steps. By using the FWI Sites and/or Services covered by this Policy and
providing Personal Information to us, you agree that we can communicate with you
electronically regarding security, privacy and administrative issues relating to
your account information and usage.
We take appropriate precautions including organizational, technical, and
physical measures to help safeguard against accidental or unlawful destruction,
loss, alteration, and unauthorized disclosure of, or access to, the Personal
Information we process or use.
The security of your data is important to us but remember that no method of
transmission over the Internet, or method of electronic storage is 100% secure.
While we at FWI strive to use commercially acceptable means to protect your
Personal Data, we cannot guarantee its absolute security.
We may retain your Personal Information for a period of time consistent with the
original purpose of collection (see above sections) or as long as required to
fulfill our legal obligations. We determine the appropriate retention period for
Personal Information on the basis of the amount, nature, and sensitivity of the
Personal Information being processed, the potential risk of harm from
unauthorized use or disclosure of the Personal Information, whether we can
achieve the purposes of the processing through other means, and on the basis of
applicable legal requirements (such as applicable statutes of limitation). After
expiry of the applicable retention periods, your Personal Information will be
deleted. If there is any data that we are unable, for technical reasons, to
delete entirely from our systems, we will implement appropriate measures to
prevent any further use of such data.


10. DATA INTEGRITY AND PURPOSE LIMITATION
We collect and use Personal Information in accordance with this Policy and only
for the limited relevant purposes stated in this Policy and/or at the time we
request such Personal Information from our users, or for such purposes to which
a user may otherwise consent. We do not use or share our users' Personal
Information in a way that is incompatible with the purposes for which such
Personal Information was requested and authorized for use by us. We retain
Personal Information for no longer than is commercially useful to carry out our
business purposes, or as we believe may be legally required. FWI takes
reasonable steps to ensure that the Personal Information is reliable for its
intended use, accurate, complete and current. When Personal Information is
deleted or updated by you, it may take up to 30 days from accessible systems,
and up to 90 days from backup systems, for us to delete such Personal
Information, unless such Personal Information has been re-published outside of
our control.


11. ACCESS TO PERSONAL INFORMATION
You may view, correct, amend, or delete the Personal Information FWI stores
about you where it is inaccurate or if you believe the Personal Information has
been processed contrary to the terms of this Policy except to the extent where
the burden or expense of providing access would be disproportionate to the risks
to your privacy in the case in question or where the rights of persons other
than yours would be violated.


12. THIRD PARTY LOGIN FUNCTIONALITY
We may permit users with accounts on certain third party services, including but
not limited to, social networking, search, sharing, and other services delivered
by third-parties, to bypass the standard applicable registration process. If you
connect through an authorized third party service, you will be able to use your
third party login information to log in to your FWI account or access FWI
content, Sites and/or Services. We are not responsible, nor liable, for the
sharing, posting, commenting, or other content and information gathering
practices of any third party services that may be triggered by using these third
party login services. Please review their terms of service and privacy policies
carefully before using third party login functionality to access any FWI Sites
and/or Services.
By using any third party services to log in to your FWI account or access FWI
Sites and/or Services, you permit us to access, store and use all information
related to your third party account that may be accessible to us through the
third party service, including through its application programming interface
(API), pursuant to this Policy.


13. WHERE WE STORE AND PROCESS PERSONAL DATA, INTERNATIONAL TRANSFER
Personal information collected on FWI sites, services, and products may be
stored and processed through FWI' servers located in the United States. If you
use any feature sets offered through FWI's cloud solution, Amazon Web Services
(AWS) may also store and process your content in the United States.
Your Personal Data may be processed outside your jurisdiction, including in
countries and jurisdictions that are not subject to an adequacy decision by the
European Commission or your local legislature or regulator, and that may not
provide for the same level of data protection as your jurisdiction. We ensure
that the recipient of your Personal Information offers an adequate level of
protection and security, for instance by entering into the appropriate
agreements and, if required, standard contractual clauses or an alternative
mechanism for the transfer of data as approved by the European Commission or
other applicable regulators or legislators. Where required by applicable law, we
will only share, transfer or store your Personal Information outside of your
jurisdiction with your prior consent.


14. CALIFORNIA PRIVACY RIGHTS
In addition to the rights set forth in this Privacy Policy, California Consumer
Privacy Act and its implementing regulations (“CCPA”) permits California
residents who are individual consumers or users of FWI Sites and/or Services to
request certain information regarding its disclosure of personal information to
third parties for their direct marketing purposes. To make such a request,
please contact us via mail or email at the address identified in the "Contacting
Us" section.
Please also not that we do not sell Personal Information. We may share personal
Information with third parties or allow them to collect personal Information
from our Sites or Services if those third parties are authorized service
providers or business partners who have agreed to our contractual limitations as
to their retention, use, and disclosure of such Personal Information, or if you
use Sites or Services to interact with third parties or direct us to disclose
your Personal Information to third parties. California law requires that we
detail the categories of Personal Information that we disclose for certain
“business purposes”, such as to service providers that assist us with securing
our services or marketing our Services. We disclose the following categories of
Personal Information for our business purposes:
•    Identifiers;
•    Commercial information;
•    Internet activity information;
•    Financial information;
•    Professional and employment-related information;
•    Education information; and
•    Inferences drawn from any of the above information categories


15. CHANGES AND UPDATES TO THIS POLICY
We may update this Policy from time to time. If we do, we will update the
"effective date" at the top of the Policy and require you to provide a fresh
consent. We will post the updated Policy on the affected Sites and/or Service.
We encourage you to review this Policy periodically to stay informed about our
collection, use and disclosure of Personal Information. Your continued use of
our Sites and/or Services or any other content, products or other services
covered by this Policy constitutes your agreement to this Policy and any
updates.


16. ENFORCEMENT
FWI regularly reviews its compliance with this Privacy Policy. Please feel free
to direct any questions or concerns regarding this Policy or FWI's treatment of
Personal Information by contacting us through this Site at Privacy@fwi.com or by
writing to us at:
Four Winds Interactive, LLC
Data Protection Officer
1221 Broadway, Denver,
CO80203, USA.
When FWI receives a formal written complaint at this address, it is FWI's policy
to contact the complaining party regarding his or her concerns within 30 days of
receiving the complaint. FWI will cooperate with the appropriate regulatory
authorities, including local data protection authorities, to resolve any
complaints regarding the transfer of personal data that cannot be resolved by
FWI and an individual.


17. NO ERROR FREE PERFORMANCE
FWI does not guarantee error-free performance under this Privacy Policy. FWI
will use reasonable efforts to comply with this Privacy Policy and will take
prompt corrective action when FWI learns of any failure to comply with our
Privacy Policy. FWI shall not be liable for any incidental, consequential or
punitive damages relating to this Privacy Policy. This Privacy Policy shall be
governed by the laws of the State of Colorado and the United States (USA), to
the extent applicable.

Version 1.3 12/17/2021, 10:57:48 PM

 



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