Last Updated/Effective Date: February 26, 2019

4f Sales, Inc., a Delaware, USA corporation (hereinafter, “4f Sales” “we” or “us”), operates this website (“Site”).

We at 4f Sales respect your privacy and are committed to the protection of your Personal Information. Our Privacy Policy explains how we collect, use, share, process and safeguard the Personal Information collected through our Site, in connection with services we provide to our customers and in connection with services provided to us by our affiliates.

BY ACCESSING OR USING THE SITE OR USING OUR SERVICES, YOU UNDERSTAND ON BEHALF OF YOURSELF AND ANY ORGANIZATION OR COMPANY YOU REPRESENT (TOGETHER, “YOU”) THAT THIS PRIVACY POLICY APPLIES TO OUR DATA COLLECTION PROCESSES.

YOU EXPRESSLY AGREE TO OUR COLLECTION, USE, PROCESSING AND SHARING OF PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, YOU SHOULD NOT ACCESS THE SITE OR USE OUR SERVICES.

THIS PRIVACY POLICY MAY BE UPDATED FROM TIME TO TIME. PLEASE REVIEW THIS PRIVACY POLICY OFTEN SO YOU REMAIN FULLY INFORMED OF OUR PRIVACY PRACTICES. IF WE MAKE ANY MATERIAL CHANGES TO OUR PRIVACY POLICY WE WILL NOTIFY YOU BY MEANS OF A NOTICE ON OUR SITE PRIOR TO THE CHANGE BECOMING EFFECTIVE. YOUR CONTINUED USE OF THE SITE AFTER WE POST AN UPDATED PRIVACY POLICY IS CONSIDERED AGREEMENT TO THE UPDATES TO THE PRIVACY POLICY.

1.
Information We Collect. When you visit our Site, when we provide services for our customers or when our affiliates perform services for us, we may collect the following data:

1.1. Personal Information. We may collect Personal Information. Personal Information is information that can be used to identify, locate or contact a person (“Personal Information”). The types of Personal Information that we may collect via the Site or when performing services for our affiliates include: name, surname, family name, mother’s maiden name, date of birth, place of birth, gender, mailing address, business address, e-mail address, land, work and mobile phone numbers, personal identification number, series and number of identity card, bank account number, citizenship, number of loans and data on loans.

 

We also may collect certain “special categories of personal data”, as such phrase is defined under applicable law. We may collect such data when our affiliates provide services to us or when we perform services for our customers, such as health information, addictions, convictions, and decisions issued in court or administrative proceedings. You should not send us “special categories of Personal Information” through our Site.

 

1.2. Non-Personal Information. We may collect and store Non-Personal Information. “Non-Personal Information” is information or data that does not personally identify you and is not readily available for that purpose. The types of Non-Personal Information that we may collect via the Site are as follows: your type of browser, operating system, search requests, website traffic information, the date and time you visited our Site, the amount of time you used the Site, the pages you visited on our Site, any device you are using to access the Site, the website you visited after leaving our Site, and any hyperlinks you click on when using the Site. Such information is collected and processed directly through the Site. Such information is collected and processed
directly through the Site.

Any Personal Information that has been de-identified and/or aggregated so that it no longer contains Personal Information will be treated as Non-Personal Information.

Internet Protocol (“IP”) address and geolocation will be treated as Non-Personal Information except where otherwise expressly required by applicable law.

2.
2. How We Collect Personal Information and Non-Personal Information.. We may collect Personal Information or Non-Personal Information in the following ways:

2.1. When you voluntarily provide information to us.

2.2. If you communicate with us via phone, email, SMS or through our social media platforms. platforms.

2.3. When we communicate with and perform services for our affiliates or when we perform services for our customers.

2.4. Using third-party analytics companies, including Google Analytics, to analyze the usage of our Site for internal purposes.

3.
Use of Your Personal Information. We may use the Personal Information we collect from you or otherwise receive about you in the following ways:

3.1. to receive services from our affiliates or to provide services to our customers;

3.2. to operate or improve the Site;

3.3. to monitor relevant Site visitor traffic patterns and Site usage;

3.4. to address any copyright infringement claim, copyright infringement notices and/or counter notices in accordance with our Digital Millennium Copyright Act Policy (“DMCA”) found at http://4fsales.com/privacypolicy/ (“DMCA Policy”);

3.5. as requested or consented to by you;

3.6. to respond to your questions, comments, or complaints;

3.7. to notify you of new services, new features of the Site, changes to the Privacy Policy or other similar communications;

3.8. as was stated (or obvious) at the point of collection;

3.9. to comply with our obligations to our customers for which we perform services;

3.10. to protect our legal rights or interests, to protect the legal rights of our customers or our affiliates and to protect the rights or interests of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, our customers, or affiliates or to other users of the Site; and

3.11. to comply with applicable laws, regulations and rules, and requests of relevant law enforcement and/or other governmental agencies; including to respond to DMCA notices and counter-notices.

4.
Our Use and Disclosure of Your
Personal Information
.

4.1. Categories of Parties. We disclose your Personal Information to the following categories of third-parties for the reasons described in this Privacy Policy.

  • Our employees, customers and affiliates;
  • Our service providers and professional advisors;
  • Government officials / law enforcement;
  • Individuals making or responding to DMCA claims (for the sole purpose of resolving such claims);
  • Our successors or assigns; and
  • Any third-party to which you have requested or consented to such disclosure

4.2. Customers.
We may disclose your Personal Information to our customers in order to provide them services.

4.3. Affiliates.
We may disclose your Personal Information to our affiliates in order for them to provide services to us.

4.4. Services Providers and Professional
Advisors
.

We may disclose your Personal Information to those third party service providers we utilize to operate our business and to our attorneys, accountants, financial and business advisors in their capacity as advisors to us as required to operate our business. When sharing any such Personal Information, we take reasonable actions to require that the data receiver follows the same level of privacy protection and security measures for storage and processing of Personal Information as we do. These companies are authorized to use your Personal Information only as necessary to provide services to us or on our behalf.

4.5. Other Reasons We May Disclose Personal Information. We may also disclose your Personal Information to third parties in the following cases:

4.5.1. selling any or all of our business to a third party may result in sharing your Personal Information with any potential or actual purchasers of our business or assets and/or your Personal Information may be among those assets transferred. You will be notified via email and/or a prominent notice on our Site, of any change in ownership, and uses of your Personal Information;

4.5.2. at any time when we are legally required to, or when it is legally advised by our attorneys, we may disclose information about you and your visits to the Site, including Personal Information, to comply with a subpoena or other legal process, or to meet national security or law enforcement requirements, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

4.5.3. iif you submit a copyright infringement notice, counter-notice or other similar notification through the Site or to us, you consent to having that communication forwarded to any person or entity to whom the notice or counter-notice is relating in order to facilitate a prompt resolution of the copyright infringement claim. Copyright infringement notices and/or counter-notices from you will be treated in accordance with our DMCA Policy found at: http://4fsales.com/privacypolicy/; and

4.5.4. we may share your Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure from the context of collection).

5.
Non-Personal Information. We may use, and share with third-parties, Non-Personal Information for various business purpose in compliance with applicable laws.

6.
Information from Children. The Site is not directed toward children under 18 years of age and we request that children under 18 years of age do not provide Personal Information through the Site. If you believe your child under 18 years of age has provided Personal Information to us, you may contact us at privacy@4fSales.com, provide us any relevant information needed to delete such Personal Information, and we will make reasonable attempts to delete such Personal Information.

7.
Personal Information: Storage and Protection.

7.1. We use physical, technical and organizational measures to protect Personal Information we collect from the Site or in connection with our provision or receipt of services.

7.2. We make commercially reasonable efforts to ensure the security of our systems. You should understand, however, that data transfer via online transmission is not completely secure. WE DO NOT GUARANTEE FULL PROTECTION AND SECURITY OF PERSONAL INFORMATION, ONLY THAT WE TAKE REASONABLE ACTIONS TO PROTECT INFORMATION SENT TO US ELECTRONICALLY. TRANSMISSION OF ANY DATA BY YOU IS AT YOUR OWN RISK.

8.
Third-Party Links. Third-party links may be displayed on the Site. These third-party links will direct you to websites controlled by third parties that have their own privacy policies, which you agree to when you click on the link. We are not responsible nor do we accept responsibility for the privacy practices of third parties when you use any third-party links, and you should review the privacy policies posted on such sites. To the extent that you disclose Personal Information to any such third parties, the privacy policies and terms of those third parties, and not this Privacy Policy, apply.

9.
“DO NOT TRACK”
SIGNALS
. We do not currently process or comply with any web browser’s “do not track” signal or other mechanisms that provide consumers with the ability to exercise choice regarding the collection of certain information about their online activities over time and across third-party websites. Further, we have not knowingly authorized third parties to collect Personal Information about your online activities over time and across different websites when you use the Site.

10.
California
Residents
. Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information, by emailing privacy@4fSales.com.

11.
Consent to
Processing in the United States
. By providing Personal Information to us, you understand and consent to the collection and processing of your Personal Information in the United States, regardless that certain governmental authorities may not consider the United States as having an adequate level of protection for Personal Information, or a level of protection equivalent to that required by the European Union or other jurisdictions.

12.
Governing Law
. Unless otherwise expressly required by the applicable law of your country of residence, this Privacy Policy is governed by the laws of the State of Delaware, United States, without regard to conflict of laws principle.

13.
Contacting Us
. Please feel free to contact us with queries, requests, or comments you may have about our Privacy Policy. We welcome any communication via the email address.
Privacy Counsel
We welcome any communication via the email
address.

Privacy Counsel
4f Sales, Inc.
18851 NE 29th Avenue
Suite 410
Miami, FL 33180
USA

E-mail: privacy@4fsales.com

************************************************************************************************

THIS SECTION ONLY APPLIES TO YOU IF YOU ARE A DATA SUBJECT LOCATED IN THE EUROPEAN UNION, UNITED KINGDOM OR EUROPEAN ECONOMIC AREA.

These additional terms apply regarding our processing of Personal Data of persons located in the European Union (“EU”), the United Kingdom (“UK”), and the European Economic Area (“EEA”) in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”).

For purposes of this section:

a. “Personal Data”
means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b. “Process or Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

In the event of a conflict between the EU / UK / EEA Sections of this Privacy Policy and the remainder of this Privacy Policy, the EU / UK / EEA Sections of the Privacy Policy shall control for those persons located in the EU / UK / EEA.

1.
Compliance with Privacy Shield Framework.
. 4f Sales complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Data transferred from the EU and the United Kingdom to the US. 4f Sales is committed to subjecting all Personal Data received from EU member countries and/or the United Kingdom (as applicable) to the United States, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. 4f Sales has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the policies in this Privacy Policy and Data Subject’s rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list .

4f Sales is responsible for the processing of Personal Data it receives under the Privacy Shield Framework, and subsequent transfers to a third party acting as an agent on our behalf. 4f Sales complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU and the United Kingdom, including the onward transfer liability provisions.

With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, 4f Sales is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, 4f Sales may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, 4f Sales commits to resolve complaints about our collection or use of your Personal Data. Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at privacy@4fSales.com.

If we are unable to resolve a complaint to your satisfaction directly with us, 4f Sales has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you have an unresolved privacy or data use concerns that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield.

Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.


4f Sales’ affiliate 4f Sales Overseas, Inc., a Florida, USA corporation, also adheres to the EU-US Privacy Shield Principles.

2.
Legal Basis for Processing. When we process your Personal Data, we have a legal basis for doing so as required under GDPR. We will only process your Personal Data under one or more of the following legal bases: (i) we have received your express opt-in consent for such processing, (ii) the processing is necessary for performance of a contract, (iii) the processing is necessary for a legal obligation to which we are subject, or (iv) if we or a third party has a legitimate interest that is not overridden by the interests or fundamental rights and freedoms of the Data Subject. We have set out in the table below the reasons why we process Personal Data, the associated legal basis for our processing of such Personal Data, and the type of Personal Data we process. If we are required to process any Personal Data for reasons (iii) or (iv), those reasons may not be known to us today and therefore may not be listed below.

 

Our Purpose for Processing

Legal Basis For The Processing

Category of Personal Data

To provide services and to communicate with our customers and affiliates.

Legitimate interest of 4f Sales, our customers and affiliates, and to provide services to each other

Name, business address, work and mobile phone numbers, email address and tax ID number.

Personal Information as defined in Section 1.1 of this Privacy Policy.

 

2.1. Right to Withdraw Consent. In the event you provide your consent for us to process your Personal Data, you may withdraw your consent by contacting privacy@4fsales.com to request such change at no additional cost.

2.2. Marketing.
We process Personal Data for the purposes of marketing in accordance with GDPR requirements. You have the right to object to the processing of Personal Data for marketing purposes at any time by contacting us at privacy@4fsales.com.

3.
Your Rights & Choices. GDPR provides certain rights to individuals in relation to their Personal Data. Accordingly, you may have the following rights under GDPR, although some exceptions do apply. With respect to the following rights, we will either forward your request to the applicable data controller, or respond to your request, whichever is required by applicable law in our role as a data processor. We may require you to prove your identity before we modify, provide, delete or transfer your Personal Data.

3.1. Right of Access – You have the right to be informed of and request access to the Personal Data we process about you. This allows you to receive a copy of the Personal Data we hold about you.

3.2. Right of Rectification – You have the right to request that we amend or update inaccurate or incomplete Personal Data.

3.3. Right to Erase (Deletion) – Under certain circumstances, you have the right to request deletion of your Personal Data.

3.4. Right to Restrict – Under certain circumstances, you have the right to request that we temporarily or permanently stop processing all or some of your Personal Data.

3.5. Right to Object – Under certain circumstances, you have the right to object to our processing of Personal Data, such as for direct marketing purposes.

3.6. Right to Data Portability – You have the right to request a copy of your Personal Data in electronic format and further request that we send such Personal Data to another party.

3.7. Communication Preferences and Opt-Outs – You have the right to stop receiving communications from us at any time by contacting privacy@4fsales.com, at no additional cost.

If you have any questions about your privacy, your rights and choices, or how to exercise them, please contact us with your request at privacy@4fsales.com. We will respond to your request within a reasonable period of time, but no later than thirty (30) days.

4.
Retention. When our processing of your Personal Data is no longer necessary for the purposes for which it was collected, including our contractual and legal rights enforcement, we will delete your Personal Data from our databases and will request that such data be deleted from the databases of our service providers. Please note, however, that deleted information may persist in backup copies for a reasonable period of time but will not be generally available. We will retain your Personal Data for as long as needed to provide our services to our affiliates, to communicate with our affiliates, comply with our legal obligations, resolve disputes and enforce our agreements or other legal rights.

5.
Information Collected From Our
Customers and Affiliates
. In certain circumstances, 4f Sales receives Personal Data from its customers or affiliates and has no direct relationship with the Data Subjects. With regard to customers, in such circumstances, 4f Sales is a data processor and our customers are the data controllers, as such terms are defined under GDPR. Our affiliates are our sub-processors. We only process such Personal Data as agreed to between our affiliates and us or between our customers and us. Your Personal Data may be subject to the privacy policies of our customers or affiliates. If you have any questions regarding the use of Personal Data by our customers or affiliates you may reach us at privacy@4fsales.com and we will connect you to the correct parties.

6.
Transfer to Third Parties and
Countries
. Personal Data that we collect or receive may be transferred to and/or processed by third parties that are located outside of the EU / UK / EEA.
We have ensured appropriate safeguards for the transfer of such Personal Data, which is made pursuant to either the EU standard contractual clauses or the EU-US Privacy Shield between us and our customers and affiliates.
You may request a copy of any such appropriate safeguards or seek inquiries regarding such safeguards by contacting us at privacy@4fsales.com. We will respond to your request or inquiry within a reasonable period of time, but no later than thirty (30) days.

7.
Identity of the Data Protection Officer. .

Data Processor: Legal Counsel, 4f Sales, Inc., 18851 NE 29th Avenue, Suite 410, Miami, FL 33180, USA; privacy@4fsales.com