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Effective/Last Updated:
May 25, 2018
BNI® UNIVERSITY
PRIVACY POLICY
BNI Worldwide Development Ltd, for and on behalf of
BNI Global, LLC, together with its related affiliates BNI
Singapore Enterprises Pvt Ltd, BNI India Enterprises Pvt Ltd,
BNI Franchising, LLC, BNI Connect Global, LLC, BNI Hong Kong
Enterprises Pvt Ltd, BNI Lanka Enterprises Pvt Ltd, and BNI
Enterprise Business Network (Guangzhou) Co Ltd (“BNI”, “our” or “we”)
prioritizes the privacy of our
users, and has developed this privacy policy to show our
commitment to that and to explain how we use certain information
("Privacy Policy").
This Privacy Policy is intended to explain to you, as a user of
BNI or our services, what information we collect, how we use
that information, with whom it may be shared, and your options
about such uses and disclosures. If you have any questions or
suggestions regarding this Privacy Policy, please email our Data
Protection Officer (“DPO”) at
dpo@bni.com.
We encourage you to read this Privacy
Policy carefully when using our Sites or services or transacting
business with us. By using our Sites and associated products
and/or services, you are accepting the practices described in
this Privacy Policy and the data collection and use practice
described in this policy.
As with
BNI’s
ToS, the
mere act of visiting our Sites or web-accessed or mobile
applications (our “Sites”), even without reading the subject
legal document, will be viewed as acceptance of the terms
contained in the Privacy Policy.
In the event of inconsistency between any terms of this contract and any
translation into another language, the English version will
control and prevail on any question of interpretation or
otherwise.
Privacy
Philosophies
Information We Collect
About You
A.
General.
In order to better provide you with the products and
services offered on the Site, we collect two types of
information about our users: personally identifiable information
and aggregate information.
Personally identifiable information refers to
information that lets us know the specifics of who you are. When
you engage in certain activities on our Sites, such as
registering for an account, purchasing a product, submitting
content and/or posting content on any of our blogs, or sending
us feedback, we may ask you to provide certain information about
yourself. Examples of personally identifiable information may
include your first and last name, email address, mailing
address, telephone numbers, age group, gender and other
identifying information. When setting up your profile on our
Sites, you may be asked to provide an e-mail address, phone
number, and address.
Aggregate information refers to information that
does not by itself identify a specific individual. We gather
certain information about you based upon where you visit on our
Sites, and what other sites may have directed you to us. This
information, which is collected in a variety of different ways,
is compiled and analyzed on both a personal and an aggregated
basis. This technology
enables us to determine (i) your IP Address of your
computer and its geographic location from installing the
Applications onto your computer, mobile device or through your
GPS of your mobile device; (ii) your search terms or interactive
behavior via BNI’s websites; (iii) your purchasing behavior;
(iv) source of the information sought by you during your search;
and (v) the age of your results data (collectively, “Shared
Information”).
We may use the information you provide in aggregate form for
internal business purposes, such as generating statistics and
developing marketing plans.
B.
Other
Information You Provide. We may also
collect and store any personal information you enter on our
Sites or provide to us in some other manner, including personal
information that may be contained in any comment you post to our
Sites. This includes identifying information, such as your name,
address, e-mail address, and telephone number (if provided and
applicable); your likeness (both still and moving); and, if you
transact business with us or our partner, limited financial
information such as your payment method (valid credit card
number, type, expiration date or other financial information).
C.
Information
About Others. We may also collect and store personal
information about other people provided to us by members,
including their businesses, contact details including email
addresses and/or IP addresses. This data is used in the
legitimate interests of members, for the purposes of generating
their invitations to non-members to Chapter meetings and other
BNI events, and for business-to-business referrals between
members for the potential purchase of goods or services from
non‑members.
D.
Sweepstakes and Contests. When
BNI offers
sweepstakes or contests, personal information is collected with
the sole purpose of notifying you if you win the sweepstakes or
contest.
E.
Automatic Collection of Data.
Information concerning your computer hardware and
software are automatically collected and may be shared with
other
BNI or
affiliated websites. This information may include: your IP
address, browser type and language, domain names, access times,
referring website addresses and
the content of
any undeleted cookies that your browser previously accepted from
us (see "Cookies"
below).
BNI uses this
information to maintain the quality of its service and to
provide general statistics about website visitors.
Cookies. When you visit our
Sites, we may use one or more "Cookies" to make our Sites easier
for you to use and to personalize your online experience.
Through the use of a cookie, we also may automatically collect
information about your online activity on our Sites, such as the
web pages you visit, the links you click, and the amount of time
you spend on the website. You can remove or block cookies using
your settings in most browsers, but if you choose to decline
cookies, you may not be able to sign in or use some of the
features offered on our Sites.
Other Technologies. We may use the
ever-evolving Internet technology, such as web beacons and other
similar technologies, to track your use of our Sites. We also
may include web beacons in company e-mail messages, newsletters,
or notifications to determine whether messages have been opened
and/or acted upon. This enables us to customize the services we
offer our Sites visitors to deliver targeted advertisements and
to measure the overall effectiveness of our online advertising,
content, programming or other activities.
Information Collected By
Third Parties.
We may allow third parties, including advertising companies, and
ad networks, to display advertisements on our Sites. These
companies may use tracking technologies, such as cookies, to
collect information about users who view or interact with their
advertisements. Unless expressly stated otherwise, our Sites do
not provide any personal information to these third parties.
This information may allow them to deliver targeted
advertisements and gauge their effectiveness. If you have
questions or concerns about this, please email our DPO at
dpo@bni.com.
Information From Other
Sources.
We sometimes supplement the information that we receive
that has been outlined in this Privacy Policy with information
from other sources and companies. Such outside information
includes updated delivery and address information from carriers
or third parties, which enables us to correct our records and
deliver, for example, future communications more easily; account
information, purchase or redemption information, and page-view
information from some merchants with which we operate co-branded
businesses or for which we provide technical, fulfilment,
advertising, or other services; search term and search result
information from some searches conducted through the Web search
features; search results and links, including paid listings
(such as Sponsored Links from Google); and credit history
information from credit bureaus, which we use to help prevent
and detect fraud and to offer certain credit or financial
services to some customers.
F.
Storage and Transfer of Personally Identifiable
Information.
BNI
may store
and process in the United States or any other country in which
BNI or its
affiliates, subsidiaries, or agents maintain data facilities.
How We Use the Information We Collect
A.
General. We will primarily use your personally
identifiable information to fulfil our contract to provide
support or service offerings to you. Specifically, BNI collects and uses your personal information in order to:
1.
operate the Sites and to
deliver the services that you have requested;
2.
manage your account and
provide you with customer support;
3.
perform research and
analysis about your use of (personal and aggregate), or interest
in, our products, services, or content, or products, services or
content offered by others; this information may be used, by way
of example only, to help us understand the demographics of our
members, identify chapters with openings for certain
professions, inform future marketing campaigns, and judge the
success of members and identify coaching strategies.
4.
cross market your
services/products with our services and our affiliates’ services
5.
verify your eligibility
and deliver online and/or offline in connection with contests
and sweepstakes;
6.
enforce our terms and
conditions;
7.
manage our business;
8.
enable and leverage
applications such as BNI University to provide user
functionality; and
9.
perform functions as
otherwise described to you at the time of collection.
When you join BNI or visit a BNI-related website, we
will not collect any personally identifiable information about
you unless you choose to provide such information to us. You
agree that when you provide your personal identifiable
information to us, BNI and its affiliated BNI franchisees may
use your information to promote you and BNI.
We want your information and
preferences to be accurate and complete. You may
request access to any personal information and preferences that
you have provided to us and correct, modify or update such
information and/or preferences by sending an email with your
request to
dpo@bni.com.
The collection of your e-mail address
and name if and when requested during account registration
enables
BNI and its
affiliates
to send you
any requested newsletter(s) or to send you any requested
mailings or offers. If applicable, you will be allowed to
indicate upon registration that you are or are not interested in
receiving offers or information from our partners and/or us and
we may occasionally send you e-mails regarding product and event
information or promotions. Only BNI and its affiliates will send
you these solicitations, and only if you have previously not
indicated that you do not wish to receive them. If applicable
and you prefer not to receive such e-mails, please opt out or
otherwise do not opt-in to receive these e-mails. You may
opt-out of receiving e-mails from BNI when you register within
your account settings at our Sites within or otherwise provide
contact information to BNI.
Information concerning your geographical
location is used to determine if
BNI
should
provide regionalized information to its site users. When you
voluntarily enter a sweepstakes or contest, we request your
e-mail address and other contact information in order to be able
to contact you in the event you are a winner of the sweepstakes
or contest. Except as otherwise stated in this Privacy Policy,
the personal information you provide on our Sites will not be
shared with any third-parties, although
BNI reserves
the right to share such information with its affiliates and
subsidiaries without your permission.
BNI provides
links to send e-mail messages to our Sites for your convenience
and your e-mail address is used so that our Sites may reply to
your inquiry.
BNI tracks the
pages on our Sites that our users visit in order to determine
which areas of the website are the most popular. This data is
used to deliver customized content and advertising within our
Sites to customers whose behavior indicates that they are
interested in a particular subject area.
The vast majority of data collection
from our visitors is used to assess the type of people visiting
that website and to determine what content is most frequently
accessed by those visitors. This information helps
BNI improve its websites by offering
content that more specifically meets the interests of our Site
visitors.
B.
Financial
Information. If BNI collects your financial information, it
may use your financial information or payment method to process
payment for any purchases, subscriptions or sales made on our
Sites, to protect against or identify possible fraudulent
transactions, and otherwise as needed to manage our business.
Data Retention
Your data will only be retained for as long as
necessary to fulfil the purposes for which it was obtained. For
members, at a minimum this will be for the duration of your
membership and likely longer depending upon applicable laws,
rules and regulations.
For non-members, this
will be for the duration needed to align with your engagement
with us, such as, by way of example only, to enable us to send
invitations to Chapter meetings, for maintaining subscriptions
to email newsletters, or for the duration of your participation
in one of our core groups prior to Chapter launch. Please see
our Data Retention Policy, accessible at
http://bnitos.com/retention.html for more
information.
With Whom We Share Your
Information
A.
General.
We want you to understand when and with whom we may share
personal or other information we have collected about you or
your activities on our Sites or while using our services.
B.
Personally
Identifiable Information. We do not share your personal
information with others except as indicated below or when we
inform you and give you an opportunity to opt out of having your
personal information shared.
1.
We may share your personal
information with:
a.
Authorized Service Providers: We may share your
personal information with our authorized service providers that
perform certain services on our behalf. These services may
include processing credit card payments, delivering products and
services, providing customer service and marketing assistance,
performing business and sales analysis, supporting our Sites’
functionality, and supporting other features and promotions
offered through our Sites. We will only provide these service
providers with the limited information that they need to provide
us with such services, including limited access to personal
information needed to perform their functions.
However, they are not permitted to share or use such
information for any other purposes. When you enter into
transactions with others or make payments on our Sites, we will
either (a) link you to a third party who handles the transaction
outside of our Sites, or (b) share transaction information with
only those third parties necessary to complete the transaction.
We will require those third parties to agree to respect the
privacy of your information.
b.
Business partners: From time to time, we
may offer promotions, sweepstakes or third-party offerings on
our Sites. If and when you make purchases, engage in these
services and/or products, offered through our Sites or our
services, we may share personal information with the businesses
with which we partner to offer you those products, services,
promotions, contests and/or sweepstakes. When you elect to
engage in a particular merchant's offer or program, you consent
to us to providing your email address and other information to
that merchant. You have the right to withdraw your consent at
any time by emailing us at
legal@bni.com.
2.
Based on the contractual necessity given the nature of
our networking business, you acknowledge that in connection with
your membership we may share your personal information with:
a.
Franchisees: If
you are a BNI member or a non-member, we may share your personal
information with BNI Master Franchisees or (Sub)franchisees of
BNI, who are joint controllers of data (“Data Controller”) with
our affiliate BNI Worldwide Development Limited.
As joint Data Controllers, Master Franchisees and
(Sub)franchisees have separate obligations for implementing
appropriate technical and organizational measures to ensure and
to demonstrate that their processing activities are compliant
with the requirements of the European Union’s General Data
Protection Regulation (“GDPR” or the “Regulation”).
b.
Members: We and
our authorized third-party agents may share your personal
information and member performance data with other members,
chapters, and the entire BNI System.
This includes (a) displaying your personal information as
a way of marketing your business on BNI® University, and (b)
sharing your performance data via BNI Connect®, BNI University,
and any other web platforms or techniques we may, separately or
through authorized third-party agents, choose to utilize or
develop in the future related to the core business of networking
and passing referrals.
3.
Other Situations. We also may disclose your information:
a.
In response to a subpoena, court order, or other requests
for cooperation from a law enforcement or other government
agency (including civil and criminal matters); to establish or
exercise our legal rights; to defend against legal claims; or as
otherwise required by law. In such cases, we may raise or waive
any legal objection or right available to us, in our sole
discretion. This may include respecting requests from
jurisdictions outside of the United States if we have a good
faith belief that response is required by law under the local
laws in that jurisdiction, apply to users from that
jurisdiction, and are consistent with generally accepted
international standards. We may also share information when we
have a good faith belief it is necessary to prevent illegal
activity, to prevent imminent bodily harm, or to protect
ourselves and you from people violating our Terms of Service,
accessible at
http://bnitos.com/tos_google.html. This may include
sharing information with other companies, lawyers, courts or
other government entities where applicable.
b.
In connection with a substantial corporate transaction,
such as the sale of our business, a merger, divestiture,
consolidation, or asset sale; though in any event, any acquiring
entity or other third-party assignee will be bound by the terms
of this Privacy Policy.
c.
To protect and defend the rights or property of BNI or
one of BNI’s referral networks; and, act under exigent
circumstances to protect the personal safety of members and
users of BNI, its websites, or the public.
Any third parties to whom we may disclose personal
information may have their own privacy policies, which describe
how they use and disclose personal information. Those policies
will govern use, handling and disclosure of your personal
information once we have shared it with those third parties as
described in this Privacy Policy. If you want to learn more
about their privacy practices, we encourage you to visit the
websites of those third parties. These entities or their servers
may be located either inside or outside the United States.
C.
Aggregated and non-personal information. We
may share aggregated and non-personal information we collect. We
may also share it with third parties to develop and deliver
targeted advertising on our Sites and on websites of third
parties. We may combine non-personal information we collect with
additional non-personal information collected from other
sources. We also may share aggregated information with third
parties, including advisors, advertisers and investors, for the
purpose of conducting general business analysis. This
information does not contain any personal information and may be
used to develop services that we hope you and other users will
enjoy using.
About
User-Generated-Content
We do not screen, filter or monitor user submissions
to our Sites, nor do we scrape or glean personal information
from any such submissions to the extent that any comment or
other user submission contains personal information (including
name, likeness, email address, whether such information pertains
to the submitter or someone else), such personal information may
be viewed by authorized users of our Sites with whom you have
shared that information, subject to our Terms of Service. We do
not gain access to any of your personal content, and only use
"meta" information to enable the successful operation of our
service. (See "User Submissions" below).
Third-Party Websites
There are a number of places on our Sites or through
our services where you may click on a link to access other
websites that do not operate under this Privacy Policy. For
example, if you click on an advertisement or a search result on
our Sites, you may be taken to a website that we do not control.
These third-party websites may independently solicit and collect
information, including personal information, from you and, in
some instances, provide us with information about your
activities on those websites. We recommend that you consult the
privacy statements of all third-party websites you visit by
clicking on the "privacy" link typically located at the bottom
of the webpage you are visiting.
Your Data Protection
Rights and Accessing Your Information under GDPR
Because our affiliate BNI Worldwide Development
Limited is established in Ireland, we will be governed by the
GDPR. This means that we are going to be working continuously to
ensure that we are satisfying our obligations under the
Regulation.
If you have an online account with us, you have the
ability to review and update your personal information online by
logging into your account. You can also review and update your
personal information and exercise your other rights by
contacting us. More information about how to contact us is
provided below.
·
You have the right to be provided on request with a
copy of your personal data.
·
You have the right to rectification of inaccurate
data we may have recorded about you.
·
You have the right to the erasure of your data
(“Right to be Forgotten”) which we no longer have justification
for recording.
·
You have the right to object to processing of your
data which is being done on the basis of our legitimate
interests.
·
You have the right to refuse to be contacted for
direct marketing purposes.
·
You have the right to restrict the processing of
your personal data when:
o
the basis for its
processing is in dispute;
o
its accuracy is in
dispute;
o
we cannot establish a
lawful basis for its processing, but you do not wish it to be
erased;
o
we no longer need your
data, but you need it for the establishment, exercise, or
defense of legal claims;
o
you object, where
applicable, to our processing your data on the basis of our
legitimate interests, pending verification of whether our
interests override.
·
You have the right to be provided with a copy of
your data in machine readable format, or to have it transferred
directly to another data controller (“Data Portability”).
If you have an online account with us, you also may
choose to close your account at any time by emailing us at
legal@bni.com. If you close your account, we may still retain
certain information associated with your account for analytical
purposes and record keeping requirements per our Data Retention
section above as well as to prevent fraud, collect any fees
owed, enforce our Terms of Service, or take other actions
otherwise permitted by law. In addition, if certain information
has already been provided to third parties as described in this
Privacy Policy, retention of that information will be subject to
those third parties' policies.
Your Choices
About Collection and Use of Your Information
1.
You can choose not to provide us with certain information, but
that may result in you being unable to use certain features of
our Sites because such information may be required in order for
you to register as a member; purchase products or services;
participate in a contest, promotion, survey, or sweepstakes; ask
a question; or initiate other transactions on our Sites.
2.
When you register on our Sites you may be given a choice or
otherwise allowed to indicate whether you want to receive email
notifications and/or newsletters. At any time you can choose to
stop receiving notification emails by accessing your account
settings or through the link at the bottom of the notification
emails; and commercial or promotional emails or newsletters from
us by clicking on the link at the bottom of any of our emails.
You will be given the opportunity, in any commercial e-mail that
we send to you, to opt out of receiving such messages in the
future. It may take up to 10 days for us to process an opt-out
request. We may send you other types of transactional and
relationship e-mail communications, such as service
announcements, administrative notices, and surveys, without
offering you the opportunity to opt out of receiving them as
long as your account is active. Please note that, changing
information in your account, or otherwise opting out of receipt
of promotional email communications will only affect future
activities or communications from us. If we have already
provided your information to a third party (such as a credit
card processing partner or an event provider) before you have
changed your preferences or updated your information, you may
have to change your preferences directly with that third party.
Protecting Your Personal
Information
We take appropriate security measures
(including physical, electronic and procedural measures) to help
safeguard your personal information from unauthorized access and
disclosure. For example, only authorized BNI employees,
contractors and certain third party service providers are
permitted to access personal information, and they may do so
only for permitted business functions. In addition, we use
encryption in the transmission of your sensitive personal
information between your system and ours.
If you choose to create a profile on our Sites or if you choose to
register for an account, you will be required to select a
password. This password can be changed at any time after you
first log into the service by using your current password. You
must keep your password confidential and you must not share this
information with anyone. If you share a computer with anyone,
you should always log out of our Sites before leaving it to
prevent access to your information from subsequent users of that
computer.
There are,
however, risks inherent in sharing information, and though we
provide privacy settings for whom you share your videos with,
please be aware that no security measures are perfect or
impenetrable. We cannot control the actions of any person with
whom you share your information, and cannot guarantee that only
authorized recipients will view your videos. We cannot control
the actions of other users with whom you share your information.
We cannot guarantee that only authorized persons will view your
information. Therefore, although we take steps to secure your
information, we do not promise, and you should not expect, that
your personal information, searches, or other communications
will always remain secure. Users should also take care with how
they handle and disclose their personal information and should
avoid sending personal information through insecure email. We
are not responsible for third party circumvention of any of our
privacy settings or security measures. Please be careful and
conscientious with whom you share your videos and choose a
strong password that you do not use for other services. For
information about how to protect yourself against identity
theft, please refer to the Federal Trade Commission's website at
www.ftc.gov/bcp/menus/consumer/data.shtml.
Communities and Forums Offered on our
Sites
Any personally identifiable information
or personally sensitive data that you disclose through our
Sites, or other online forums hosted on our Sites, may be
collected and used by others. We recommend caution when giving
out personal information to others in these online forums. We
encourage you to review the privacy statements of websites you
choose to visit via hyper-links posted on our Sites so that you
can understand how those websites collect, use and share your
information. BNI is not responsible for the privacy policies or
other content on third-party websites accessed through its
websites.
User Submissions
We may provide areas on our Sites where you can post
information about yourself, including your name and email
address, communicate with others; upload content; and post
comments. Such postings are governed by our Terms of Service.
Also, whenever you voluntarily disclose personal information on
our site, that information will be available and can be
collected and used by others who have authorized access to your
content. We encourage you to exercise discretion and caution
with respect to your personal information. Once you have posted
information, you may not be able to edit or delete such
information.
Children's Privacy
Our Site is a general audience site, and we do not
knowingly collect personal information from children under the
age of 13. Our Sites are not intended for use by children. You
may access our Sites only if you are of legal age to lawfully
form a binding contract. If you are under the age of 18 and do
not have a parent’s or legal guardian’s permission to use our
Sites, you may not access our Sites or use any services. If you
are 13 years of age or older, then you can only use our Sites
and services with the consent of your parent or legal guardian.
Transfers of Personal
Data Outside of Europe
The global extent of BNI’s business necessitates the
transfer of data to its franchisees and times members on a
worldwide basis. Some countries to which we transfer your data
have not been designated by the European Commission as having at
a national level an adequate level of data protection. In these
cases, we rely on (a) Privacy Shield, and (b)
Commission-approved standard contractual clauses (“SCC”) with
our franchisees to safeguard your data.
Privacy Shield
For transfers out of the
EU and Switzerland and to the United States of America, BNI
Global, LLC has self-certified that it complies with the EU-US
and Swiss-US Privacy Shield Framework as prescribed by the US
Department of Commerce regarding the retention, use, collection,
and notice principles. BNI additionally adheres to the Privacy
Shield Framework recommendations pertaining to the transfer of
information to third parties, access, security, data integrity
and purpose limitation and enforcement. Additional information
on the Privacy Shield Program can be viewed at
https://www.privacyshield.gov.
The Federal Trade Commission (FTC) has jurisdiction over BNI’s
compliance with the Privacy Shield. BNI will annually renew its
Privacy Shield certification to help ensure the treatment of all
personal data continues to be accurate and processed in
accordance with the Privacy Shield Framework and applicable
Principles. In cases of onward transfer to third parties of EU
and Swiss Personal Data received pursuant to the EU-US and
Swiss-US Privacy Shield Framework, BNI is potentially liable.
All questions or complaints regarding the processing and use of
personal data should be directed to
legal@bni.com.
BNI has elected JAMS as
its independent dispute resolution mechanism in accordance with
requirements set forth by Privacy Shield. If questions or
complaints are not resolved satisfactorily through contacting
BNI, users can file a complaint with JAMS at
https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.
You may have the option to select binding
arbitration for the resolution of your complaint under certain
circumstances, provided you have taken the following steps: (1)
raised your complaint directly with BNI and provided us the
opportunity to resolve the issue; (2) made use of the
independent dispute resolution mechanism identified above; and
(3) raised the issue through the relevant data protection
authority (DPA) and allowed the US Department of Commerce an
opportunity to resolve the complaint at no cost to you. For more
information on binding arbitration, see US Department of
Commerce’s Privacy Shield Framework: Annex I (Binding
Arbitration).
No Rights of Third
Parties
This Privacy Policy does not create rights
enforceable by third parties or require disclosure of any
personal information relating to users of our Sites.
Changes to This Privacy
Policy
We will occasionally update this Privacy Policy to
reflect changes in our practices and services. When we post
changes to this Privacy Policy, we will revise the "Last
Updated" date at the top of this Privacy Policy. If we make any
material changes in the way we collect, use, and/or share your
personal information, we will notify you by sending an email to
the email address you most recently provided us in your account,
profile or registration (unless we do not have such an email
address), and/or by prominently posting notice of the changes on
our Sites. We recommend that you check our Sites from time to
time to inform yourself of any changes in this Privacy Policy or
any of our other policies.
How to Contact Us
If you have any questions about this Privacy Policy
or our information-handling practices, or if you would like to
request information about our disclosure of personal information
to third parties for their direct marketing purposes, please
contact us by email, telephone, or postal mail as follows:
BNI Worldwide Development Ltd
IRELAND
BNI’s Data Protection Officer can be contacted at
the above address or phone number, or by email at
dpo@bni.com.
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