Privacy
Privacy Policy
Effective Date/Last Updated: 1/1/2023
FourthWall offers its Reveal Portfolio and related services that allow our business customers to understand and analyze television, cable, satellite, broadcast, and device viewership data and extract meaningful insights (the “Reveal Portfolio”). Our Reveal Portfolio and related services include the provision of demographic data about individual viewers, data about specific TV programming and advertisements viewed by households and related reporting and tracking to understand the effectiveness of these programs and advertisements. This Privacy Notice describes how FourthWall (“our,” “we”) collects, uses, and shares personal information via its Reveal Portfolio and related services (our” Services”) and the rights you may have regarding the same.
We collect information you choose to give our third-party partners and other information that may be automatically collected from your use of our Services, including from your device. We use that information to operate our business, and for a variety of other purposes set forth below.
INFORMATION WE COLLECT
To provide our Services, we collect data by which you may be personally identified. We may also collect information about the devices and equipment you use to access our Services, including usage data.
We collect your personal information from a variety of sources, including:
- Automatically as you utilize the Services.
- From third parties, including analytics providers, data brokers, and online and broadcast distributors and providers of video and television content.
- From our business customers.
Information we collect from third party sources.
We may collect additional information from third-parties. These third parties may provide us information both in connection with our Services and through tools they use to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information about your online activities over time. With respect to our Services our business customers may use this information to provide you with interest-based advertising or other targeted content, and for other purposes (such as to better understand our Services’ audience).
Services Related Data Collection.
In connection with our offer and provision of our Services to our business customers, we may collect information from third parties including:
Television, cable, satellite, and broadcast companies. This information includes:
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What television programs are being watched in your home.
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What time, and for how long, those programs are watched.
Demographic information services / data brokers. This information includes:
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Information about the ages of the members of your household.
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Information about household income.
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Information about racial, ethnic, or religious background.
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Information about gender, and the genders of other individuals in your household.
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Information about your interests and preferences.
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Other information that be available from such data broker services.
Online Activity/Data Brokers
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Information regarding your use of online services through cookies, web beacons, and other automatically collected information. This data may include your IP address, date and time you access online services and the pages and content you access during your visit, websites that you link to or from, emails from us that you open, and the links you click on within those emails.
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Information from your mobile device or your computer about how you interact with online services, including IP address, operating system, and browser type.
Information provided by our business customers.
In some cases, our business customers may directly provide information about individuals to our platform. We may process this data according to such customer’s instructions in that case.
HOW WE USE INFORMATION WE COLLECT
We may use data we collect for a variety of purposes, including the following (which includes activity on behalf of our business clients):
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To provide our Reveal Portfolio to our business customers. We may provide our business customers with the ability to receive, combine, analyze and report on the collected data. This provides insights regarding their advertising, campaigns and other promotions including the viewership of their ads and helps identify target audiences for additional advertising.
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To maintain, analyze, customize, measure, and improve our Services, which includes generating internal reports about the use of our Services.
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To send transactional communications, including requests for information, responses to requests for information, and other Service updates.
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To provide customer support.
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To communicate with our customers, including about products updates and offerings that we think they may be interested in.
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For account management, finance, dispute resolution, and reporting purposes.
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To monitor and enforce our legal terms or similar terms.
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For internal business reasons, including internal audits or investigations, company research, insurance purposes.
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To comply with law and satisfy our regulatory compliance obligations.
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To detect and prevent fraud and other prohibited, illicit or illegal activity, and to protect you, others, and ourselves.
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For other purposes permitted by law or to which you consent.
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Please note that we may combine the information we gather about you in identifiable form, including information from third parties. We may use this information, for example, to improve and personalize our Services, content, and our own marketing efforts.
HOW WE SECURE INFORMATION
We are committed to maintaining measures to protect the security of your information. Of course, despite these measures, no network or system is ever entirely secure and we cannot guarantee the security of networks and systems that we operate or that are operated on our behalf.
HOW WE SHARE INFORMATION
We may share your information with third parties as permitted or required by law.. For example, we may share information about you:
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With our professional advisors who provide legal, compliance, accounting, banking, or consulting services.
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To comply with our legal obligations or to protect the interests, property, or legal rights of you, ourselves, or third parties.
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With law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar law enforcement request, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of this Privacy Notice or other applicable terms.
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With companies or other entities in connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business.
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For other legal purposes, such as to enforce our legal terms, or to exercise or defend legal claims.
Additionally, our Reveal Portfolio inherently involves sharing information with our business customers, including the information noted above in Services-Related Data Collection. In using our Services, our business customers may direct further information sharing with their own ad agencies, service providers, or others. You should contact our business customers directly to understand their privacy practices with respect to your information.
WHAT CHOICES DO I HAVE?
Update personal information. If you are business customer of ours, you may log in to your account and update certain information that you have provided to us.
Cookies. You have a number of choices regarding certain cookies. Most web browsers automatically accept cookies, but you may modify your browser’s setting to notify you of cookie placement or decline cookies. If you choose to decline cookies, certain features of our website may not function properly as a result.
UPDATES TO OUR PRIVACY NOTICE
We may update this Privacy Notice from time to time in order to provide clarification or notice of changes to our practices. If we make changes, we will revise the Effective Date at the top of this Privacy Notice. Changes to this Privacy Notice will be effective once they are posted.
CONTACT INFORMATION
If you have questions or comments regarding the FourthWall Media Statement of Privacy, please contact us by e-mail or postal mail.
FourthWall Media, Inc.
Legal Department
45925 Horseshoe Drive, Suite 100
Dulles, VA 20166
privacypolicy@FourthWallMedia.tv
Last Updated: 1/1/2023
ADDITIONAL NOTICE FOR CALIFORNIA RESIDENTS
This Addendum to the Privacy Notice applies to residents of California only and describes our current practices and for the last 12 months.
COLLECTION, DISCLOSURE AND SALE OF PERSONAL INFORMATION
We collect personal information as necessary to operate our business, to provide our Reveal Portfolio , comply with our legal and regulatory obligations, and to provide our Services.
Our Services may collect and disclose the following information about you:
As disclosed above, with our Reveal Portfolio and Services, we have disclosed some of your personal information, such as inferences and usage data, to third parties who provide analytics or advertising services. Under the broad definition of what constitutes a “sale” or “sharing” under CCPA, such disclosure may constitute a “sale” or “sharing” of your personal information. You may opt out of the sale or sharing of your personal information here: Do Not Sell or Share My Personal Information. We do not sell or share the personal information of individuals who we know to be under 16 years of age.
As an individual or household whose data may be provided to our Reveal Portfolio, we may collect and disclose the following information about you:
Data indicated as “sold” may be provided by us to our business customers as part of their use of our Services. In all cases, we may also disclose information to comply with law, to protect the interests of ourselves or others, to professional advisors, and in connection with a merger, sale, or acquisition of all or part of our business. To learn more about how we share data, please see the How We Share Personal Information section. Please visit our Do Not Sell or Share My Personal Information page to exercise this right.
To learn more about the information we collect, see the Information We Collect section in our Privacy Notice.
COLLECTION OF SENSITIVE PERSONAL INFORMATION
We do not collect or process sensitive personal information. We do not collect or process any of the following about you or your household
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Social security, driver's license, state identification card, or passport number.
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Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
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Precise geolocation.
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Racial or ethnic origin, religious or philosophical beliefs, or union membership.
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Contents of your mail, email, and text messages unless the business is the intended recipient of the communication.
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Genetic data.
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Unique identifying biometric information.
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Health, sex life, or sexual orientation information.
SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED
We do not collect personal information directly from you. However, we may also collect personal information from the following:
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Indirectly from you. For example, from observing your actions on third party websites.
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From third parties, including data brokers, our business customers, analytics providers and others who provide data to operate our Services.
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Television, cable, satellite, and broadcast providers.
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To further understand the categories of sources from which consumer information is collected, see the Information We Collect section of our notice.
PURPOSES FOR WHICH PERSONAL INFORMATION IS COLLECTED
The purposes for which we will collect or use your personal information are described in the How We Use Information We Collect section in our notice and include:
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To provide our Reveal Portfolio and Services to our business customers.
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To operate, improve or maintain our Services.
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To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
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To comply with our legal and regulatory requirements.
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As indicated in the charts set forth above.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you have the following rights to your personal information.
1) Right to Know. You have the right to request that we disclose the following about the personal information we have collected about you in the preceding 12 months:
a. What personal information we have collected;
b. The categories of personal information we collected;
c. The categories of sources from which we collected your personal information;
d. The business purposes for collecting or sharing your personal information;
e. The categories of personal information we may disclose for business purposes; and
f. The categories of third parties to whom we share your personal information.
2) Right to Delete. You have the right to request that we delete your personal information. Upon verifying your identity and the validity of your request, we will delete your personal information from our records and instruct our service providers, affiliates, or third parties to delete your information as required by law. We may deny your deletion request if retaining the information is permitted under law.
3) Right to Correct. You have the right to correct inaccurate personal information. Upon verifying your identity and the validity of your request, we will use reasonable efforts to correct your personal information as directed. In certain circumstances, we may not be able to satisfy this request depending on the nature of the personal information and purposes for maintaining it.
4) Right to Opt-out of Selling. If you are age 16 or older, you have the right to direct us to not sell your personal information at any time. To exercise the right to opt out, you (or your authorized representative) may submit a request to use by visiting our Do Not Sell or Share My Personal Information [MMM8] page. Once you make an opt-out request, we will wait at least twelve months before asking you to reauthorize personal information sales. You do not need to create an account with us to exercise your opt out rights.
5) Right to Limit Use of Sensitive Personal Information. You have the right to limit how your sensitive personal information is used and/or disclosed to third parties. As indicated above, we do not collect, process, or provide Sensitive Personal Information
6) Right to Opt-Out of Sharing Personal Information for Behavioral Advertising. You have the right to opt of the sharing of your data for the purpose of targeting cross-context behavioral advertising to you. Please visit our Do Not Sell or Share My Personal Information page to exercise this right.
HOW TO EXERCISE THESE RIGHTS
You can exercise any of the rights described in this Addendum by using the following contact information:
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Toll free at 866.372.6774
Please note that, as permitted by law, we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. In connection with such verification, we may ask you to provide: Name, Address, Phone Number, and email We may limit our response to your exercise of the above rights as permitted by law.
If we have processed your data through our Service as submitted by or for a business customer of ours, we may act only as a data processor on behalf of such business customers. In that case, should you wish to exercise any rights you may have under applicable laws, please contact these entities directly.
We may not discriminate against you for exercising any of your rights under California law. This means that we may not deny you services, or charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under California law. However, we may charge different prices or rates, or provide a different level or quality of services, where that difference is reasonably related to the value provided to us by your personal information.
You may designate an authorized agent to make a California rights request on your behalf. An agent may be an individual or a business entity registered with the California Secretary of State. To designate an authorized agent, you must provide the agent with written permission to submit the request. We may still require you to confirm that you have authorized an agent to act on your behalf and to verify your identity directly (subject to certain exceptions) as permitted by law. We may refuse a request if the agent does not provide adequate proof of their authorization as permitted by law.
DATA STORAGE AND SECURITY
We will store your personal information until the initial purpose for which we collected such data has been satisfied, including the purpose described in our How We Use Information We Collect section. If you consent to a new or additional purpose for retaining your data, your personal information may be stored for longer. We have implemented measures designed to secure your personal information against unauthorized use, loss, destruction or alteration. We cannot guarantee the security of your personal information.
We retain your data according to a set retention schedule, which can be generally described as follows: Our data retention period is up to 5 years. At the end of that retention schedule, all data is deleted unless subject an independent legal obligation which requires us to retain it.
DATA RIGHTS UTILIZATION METRICS FOR DATA SUBJECT RIGHTS REQUESTS
In the last calendar year of 2022, the following requests were received from California residents and handled as follows:
CONTACT US
If you have any questions or concerns about privacy at FourthWal, please contact us:
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Toll free at 866.372.6774
Last Updated: 1/1/2023
ADDITIONAL NOTICE FOR VIRGINIA RESIDENTS
This Addendum to the Privacy Notice applies to residents of Virginia only.
COLLECTION OF PERSONAL INFORMATION
We collect personal information as necessary to operate our business, to comply with our legal and regulatory obligations, and to provide services to our business customers.. We may collect the following categories of personal information from third party partners:
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Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, device identifier, or other similar identifiers.
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Internet or other similar network activity including browsing history, search history, information on a consumer’s interaction with a websites, application, or advertisement.
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Geolocation data, including physical location or movements.
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Inferences drawn from other personal information such as a profile reflecting a person's preferences, and characteristics’.
To learn more about the information we collect, see the Information We Collect section in our Privacy Notice.
PURPOSES FOR WHICH PERSONAL INFORMATION IS COLLECTED
The purposes for which we will collect or use your personal information are described in the How We Use Information We Collect section in our notice and include:
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To provide our Reveal Portfolio and Services to our business customers.
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To operate, improve or maintain our Services.
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To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
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To comply with our legal and regulatory requirements.
DISCLOSURE OF YOUR PERSONAL INFORMATION
We may share your information with third parties for a specified, legitimate business purpose. We share your information with the following third parties:
We may also share information to comply with law, to protect the interests of ourselves or others, and in connection with a merger, sale, or acquisition of all or part of our business. To learn more about how we share data, please see the How We Share Personal Information section.
As described above, we may disclose personal information to third parties in connection with providing you with services and for other business purposes. In some cases, these third parties operate advertising networks and may collect and use information about you to identify interests and preferences. This information may then be used for targeted advertisements to you.
YOUR VIRGINIA PRIVACY RIGHTS
If you are a Virginia resident, you have the following rights to your personal information.
1) Right to Confirmation and Access. You have the right to request that we confirm whether we are processing your personal information and you have the right to access the personal information we have processed about you.
2) Right to Correct. You have the right to correct inaccurate personal information. In certain circumstances, we may not be able to satisfy this request depending on the nature of the personal information and purposes for maintaining it.
3) Right to Delete. You have the right to request that we delete your personal information that you have provided to us or that we have obtained about you. We may deny your deletion request if retaining the information is permitted under law.
4) Right to Data. You have the right to obtain a copy of the personal information that you previously provided in a portable and, as technically feasible, readily usable format that allows transmission to another data controller without hindrance. The right to obtain in such a portable, usable form may only apply to data that is processed via automatic, standardized means.
5) Right to Opt-Out of Certain Targeted Advertising. You have the right to opt out of the sharing of your data to target advertising based on personal data obtained from your activities overtime and across websites or applications used to predict interests or preferences.
6) Right to Opt-out of Selling. You have the right to direct us to not sell your personal information at any time. To exercise the right to opt out, you (or your authorized representative) may submit a request to use by visiting our Do Not Sell or Share My Personal Information page.
7) Right to Opt-Out of Profiling. You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
We may limit our response to your request to exercise the above rights as permitted by law.
HOW TO EXERCISE THESE RIGHTS
You can exercise any of the rights described in this Addendum by using the following contact information:
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Toll free at 866.372.6774
Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. In connection with such verification, we may ask you to provide: Name, Address, Phone Number, and email We may limit our response to your exercise of the above rights as permitted by law.
CONTACT INFORMATION
If you have questions or comments regarding the FourthWall Media Statement of Privacy, please contact us by e-mail or postal mail.
FourthWall Media, Inc.
Legal Department
45925 Horseshoe Drive, Suite 100
Dulles, VA 20166