Privacy Policy

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This privacy policy explains how 4CM Ltd. uses any personal information we collect about you. We follow the guidelines provided by the Information Commissioner’s Office (ICO) in order to comply with General Data Protection Regulation (GDPR). We are listed on the public register for data controllers maintained by the ICO. 

For the purpose of the GDPR (General Data Protection Regulation) and PECR (Privacy and Electronic Communication Regulation) the data processor is 4CM Ltd, Challenge House, Sherwood Drive, Bletchley, Milton Keynes, MK3 6DP. 

As Your Data Processor

As a marketing agency, 4CM will use customer data that is supplied for campaigns and projects as specifically instructed by clients (the controller). If you are another marketing company, sub-contracting a data processing task to 4CM you become our data controller. 

If you have questions or would like to speak to us about how we collect, process, manage or store data that we hold, please contact Gemma Brooks at gemma.brooks@4cm.co.uk

privacy policy

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WHY we collect personal data

We collect and process data:

  • To ensure that content from our website is presented in the most effective manner for you and for your internet browsers
  • To provide you with information, products or services that you may be interested in or have requested
  • To carry out our obligations arising from any contracts or transactions entered into between us
  • To allow you to participate in interactive features of our service, when you choose to do so
  • To notify you about changes to our services
  • To ensure we are providing a service that meets your requirements.

WHAT personal data is collected and processed

The data we hold for different purposes may include:

  • Personal contact information including name and contact details such as email, telephone number, social media handles and postal address
  • Demographic information, including job title and function, date of birth, location, personal preferences and interests
  • Financial details for invoicing and payment purposes
  • Customer feedback, including information that you share with 4CM Ltd about your experience in using 4CM Ltd’s services or those of our clients
  • Customer-generated content, including any content that you create and then share with 4CM Ltd by uploading it to a 4CM Ltd website
  • Data such as dietary requirements for events and images for use in 4CM or our client’s marketing – the required notices will be provided at point of data collection.

HOW personal data is collected

We may collect personal data about you from the following sources:

  • Online and electronic interactions, including via 4CM Ltd websites
  • Offline interactions with us, including via hard copy registration cards, competition entries, event registrations or
    phone contact
  • Your interaction with online targeted content (such as advertisements) that 4CM Ltd, provide to you via third party
    websites or applications
  • Cookies and other tracking technology which collect certain kinds of information when you interact with 4CM Ltd
    sites. Please see our cookie notice for information on these technologies and your rights in relation to them
  • External links – Although we look to include quality, safe and relevant external links across our websites, users are
    advised to adopt a policy of caution before clicking any external web links. (External links include clickable text /
    banner / image links to other websites)
  • From clients who have requested our marketing services and have provided us with your data for us to contact you
    on their behalf.

Please note: We cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users
should therefore note that they click on external links at their own risk and that this website and its owners cannot be
held liable for any damages or implications caused by visiting any external links mentioned.

IP addresses and cookies

We may collect information about your computer, including where available your IP address, operating system and
browser type, for system administration and optimisation. This is statistical data about our users’ browsing actions
and patterns and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is
stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard
drive.

They help us to improve our site and to deliver a better and more personalised service.

They enable us:

  • To estimate our audience size and usage pattern
  • To store information about your preferences, and so allow us to customise our site according to your
    individual interests
  • To speed up your searches
  • To recognise you when you return to our site
  • You may refuse to accept cookies by activating the setting on your browser. However, if you select this setting you
    may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will
    refuse cookies, our system will issue cookies when you log on to our site
  • In addition, cookies from third parties such as Twitter and Google are included on our websites.
  • Please see information on Twitter cookies here: https://help.twitter.com/en/rules-and-policies/twitter-cookies#
    Please see information on Google Analytics cookies here: https://developers.google.com/analytics/devguides/
    collection/analyticsjs/cookie-usage
  • Our website contains links to other websites. This privacy policy only applies to 4CM websites. We recommend
    that you check the policy of each site you visit and contact its owner or operator if you have any concerns
    or questions.

Generally, the cookies that are used on our sites can be broken down into the following categories:

Session Cookies
These cookies are used ‘in-session’ each time you visit and then expire when you leave a site or shortly thereafter:
they are not stored on your device permanently, do not contain any personal data and help by minimising the need to
transfer personal data across the internet. These cookies can be deleted, or you can refuse to allow their use, but this
will hamper the performance and your experience in using the sites. These cookies also take time stamps that record
when you access a site and when you leave a site.

Tracking Cookies
These cookies enable us to recognise repeat visitors to our sites. By matching an anonymous, randomly generated
identifier, a tracking cookie keeps track of where a user of our sites came from, which search engine they may have
used, which link they clicked on, which keyword they used and where they were in the world when they accessed a
site. By monitoring this data, we can make improvements to our sites.

Persistent Cookies
This type of cookie is saved on your device for a fixed period (sometimes for a few hours, sometimes for a year or
longer) and is not deleted when the browser is closed. Persistent cookies are used where we need to remember who
you are for more than one browsing session. For example, this type of cookie can be used to store your preferences,
so that they are remembered for the next visit to a site.

Performance or Analytical Cookies
Performance cookies are used to analyse how the sites are used and to monitor their performance, which allows us to
improve your experience in using the sites. These cookies help us to tailor the content of the sites to reflect what the
site users find most interesting and to identify when technical issues with the sites arise. We may also use this data to
compile reports to help us analyse how sites are used, what the most common issues are and how we can improve
the sites.

Opt-out for cookies used for online advertising – Just in case
You can also manage many companies’ cookies used for online advertising via the consumer choice tools created
under self-regulation programs in many countries, such as the EU-based http://www.youronlinechoices.com/uk/yourad-
choices.
You can withdraw your consent to the use of consent based cookies individually at any time with effect for the future
by adjusting your cookie settings accordingly.

4CM marketing

Email Newsletter

We operate an email newsletter program, used to inform subscribers about our work, and services. Users can
subscribe through an online automated process should they wish to do so. Some subscriptions may be manually
processed following agreement via email or telephone.

Subscriptions are taken in compliance with GDPR and PECR. All personal details relating to subscriptions are held
securely and in accordance with GDPR/PECR. No personal details are passed on to third parties nor shared with
companies / people outside 4CM Ltd. You may request a copy of personal information held about you by 4CM Ltd’s
email newsletter program.

Our email marketing campaigns may contain tracking facilities within the actual email. Subscriber activity is tracked
and stored in a database for future analysis and evaluation. Such tracked activity may include: the opening of emails,
forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity (this is not a
comprehensive list).

This information is used to refine future email campaigns and supply users with more relevant content based around
their activity.

In compliance with GDPR and PECR subscribers are given the opportunity to un-subscribe at any time through an
automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription
system is unavailable clear instructions on how to un-subscribe will be detailed instead.

Social Media Platforms
Communication, engagement and actions taken through external social media platforms that we participate
on are customised to the terms and conditions as well as the privacy policies held with each social media
platform respectively.

Users are advised to use social media platforms wisely and communicate / engage upon them with due care and
caution in regard to their own privacy and personal details. We will never ask for personal or sensitive information
through social media platforms and encourage users wishing to discuss sensitive details to contact us through primary
communication channels such as by telephone or email.

We use social sharing buttons which help share web content directly from web pages to the social media platform in
question. Users are advised before using such social sharing buttons that they do so at their own discretion and note
that the social media platform may track and save your request to share a web page respectively through your social
media platform account.

MARKETING on behalf of clients

We run marketing campaigns on behalf of our clients. This involves processing and storing data using third party
technologies such as HubSpot, Survey Monkey etc. In order to do this we comply with GDPR requirements specified by
the third party. We process data provided by our clients and any additional data is generated from individuals engaging
with our marketing campaigns such as filling in forms via our client’s websites, engagement on social media etc. under
the relevant lawful bases of consent or legitimate interest.

Email marketing
You may opt out of receiving this information at any time by unsubscribing from our client’s different email
communications, this will, however, mean that you won’t hear from them about any similar future initiatives, services or
offers that may be of interest to your organisation.

Websites
If you fill in forms to receive further information via the websites we manage on behalf of our clients, your data will be
shared with the relevant client and, if stated at data entry point, included in their marketing communications database
going forward. As detailed above, you can unsubscribe from email communication at any point.

HOW long will we keep your personal information

4CM Ltd will only retain information for as long as necessary for the relevant activity. This may be determined by
legislation or a decision as to what we consider necessary for the business based on a number of factors.

WHERE we store your personal data

4CM Ltd has put in place appropriate technical and organisational measures to prevent accidental loss, damage or
destruction of your personal data, and to protect your personal data against unauthorised, or unlawful use or theft. We
put in place strict confidentiality agreements, including data protection obligations, with our third-party service providers
and data processors. In addition, internal filing systems are held online and are password protected. If sharing data by
email, spreadsheets are password protected. We also operate a clean desk policy at our offices. Entry to all mobile
devices, laptops and computers are password protected.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to
protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at
your own risk. Once we have received your information, we use strict procedures and security features to try to prevent
unauthorised access.

WHERE your information is shared

Under the legal bases of legitimate interest, consent or contract, we may share information about you with our
employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in
this privacy policy. This includes sharing personal information such as dietary requirements and accessibility needs etc
with third parties such as event venues.

In addition, we may disclose your personal information:

  • a. to the extent that we are required to do so by law
  • b. in connection with any legal proceedings or prospective legal proceedings
  • c. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes
    of fraud prevention and reducing credit risk)
  • d. to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling
  • e. we may disclose your personal information to third parties:
    • In the event that we sell or buy any business or assets, in which case we may disclose
      your personal data to the prospective seller or buyer of such business or assets
    • If 4CM Ltd or substantially all of its assets are acquired by a third party, in which case
      personal data held by it about its clients will be one of the transferred assets.

WHAT are your rights

You have a number of rights when it comes to having a say in how we use, store, process and manage your
personal data:

You have the right to be informed about how we will use data some information is provided in this privacy document
but there will also be notices at point of data collection.

You have the right to object to your data being used or to request that we correct any information that we hold that is
false or inaccurate.

You can also ask us to delete data and/or restrict processing of your data. You can exercise your right to prevent such
processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any
time by contacting us at info@4cm.co.uk or calling us on +44 (0)1908 533253.

Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you
follow a link to any of these websites, please note that these websites have their own privacy policies and that we do
not accept any responsibility or liability for these policies. Please check these policies before you submit any personal
data to these websites.

ACCESS to information

GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance
with the policy. Any access request may be subject to a fee of £25 to meet our costs in providing you with details of the
information we hold about you.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon
as possible, at the below address. We will promptly correct any information found to be incorrect.

WHAT if our policy changes

Any changes we may make to our privacy policy in the future will be updated on our website and this document,
where appropriate, notified to you by e-mail.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to
gemma.brooks@4cm.co.uk or by calling us on +44 (0)1908 533253.
Address:
4CM Ltd
Challenge House
Sherwood Drive
Bletchley
Milton Keynes
MK3 6DP

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