4C Strategies Privacy Statement

Issued in August 2018, version 2.0

4C STRATEGIES PRIVACY STATEMENT

 

  1. INTRODUCTION

 

4C Strategies are committed to protecting your personal data. This privacy statement describes why and how we collect and use personal data (other than personal data concerning members of our staff) and provides information about the rights of data subjects..

 

The joint data controllers are 4C Group AB with registered offices at Vattugatan 17, 111 52 Stockholm, +46 (0) 8 522 279 00 and, depending on the category of data subjects as further set out below or in the relevant privacy notice, one or several of its subsidiaries:

 

  • 4C Strategies AB, Vattugatan 17, 111 52 Stockholm, +46 (0) 8 522 279 00
  • 4C International AB, Vattugatan 17, 111 52 Stockholm, +46 (0) 8 522 279 00
  • 4C Europe UK Ltd, 13-14 Buckingham street WC2N 6DF, +44(0)203 318 2706

 

To find out more about our specific processing activities and about your rights in relation to the processing, please go to the relevant sections of this statement.

 

  1. CATEGORIES OF PERSONAL DATA

 

2.1 CUSTOMER AND PARTNER CONTACTS

 

We collect and process personal data about employees/individuals otherwise associated with 4C customers and 4C partner businesses (“customer and partner contacts”) for the purpose of managing the relationship and administering and developing our services and business, as further set out in this section.

 

 

Data Controller: 4C Group AB and the 4C company with whom the customer or partner has or has had a contractual relationship – or that would be the appropriate contracting party.

 

 

What information do we collect about you?

 

Information you give us:

 

  • Your name and contact information (such as your email and telephone number) so that we can identify you and contact you in relation to the purpose for which you gave us your contact details, and for other purposes relating to our products and services that we think may be of interest to you;
  • Your job title and employer so that we can identify you for the above purposes;
  • Your former job title and employer if your status changes during the course of our contractual relationship or during the retention period.

 

Information we may collect about you:

 

  • Your name, job title, employer and contact information if we have not received this information directly from you, so that we can identify you and contact you regarding the products and services we offer;
  • Photographs of you if you attend one of our events or an event in which we participate;
  • Footage from video surveillance of you entering and leaving our offices in Stockholm (where applicable).

What do we do with your information?

If you are employed by or otherwise represent a current or former customer or partner:

 

Type of personal data

 

Purpose of the processing

 

Legal basis for the processing (“why is the data processing necessary?”)

 

How long do we keep the data?

 

Your name and contact information, current job title and employerTo provide information about us and our products and services.

To administer, manage and develop our business, products and services, including fulfilling any contractual obligations towards the customer/partner.

To make your contact information available to our staff for the above purposes and to describe the nature of the relationship.

To perform analytics on sales intelligence, customer satisfaction and progress against business objectives.

To comply with any applicable laws.

To perform our contractual obligations towards the customer/partner.

To pursue our legitimate interest of promoting our products and services and to better understand the needs of customers and partners.

Where applicable, to comply with a legal obligation.

For as long as we have a contractual relationship with the customer/partner and, thereafter, for as long as we need to keep a record of a customer/partner contact. We may store your contact details in our CRM system for as long as we think that you may have a professional interest in our products and services.
Your former job title and employer

 

To provide information about us and our products and services.

To administer, manage and develop our business, products and services, including fulfilling any contractual obligations towards the customer/partner.

To make your contact information available to our staff for the above purposes and to describe the nature of the relationship.

To perform analytics on sales intelligence, customer satisfaction and progress against business objectives.

To comply with any applicable laws.

 

To perform our contractual obligations towards the customer/partner.

To pursue our legitimate interest of promoting our products and services and to better understand the needs of customers and partners.

Where applicable, to comply with a legal obligation.

For as long as we have a contractual relationship with the customer/partner and, thereafter, for as long as we need to keep a record of a customer/partner contact. We may store your contact details in our CRM system for as long as we think that you may have a professional interest in our products and services.
Photographs/

recordings of events in which you may appear

To inform about events that we have organised, or participated in, in marketing communications or on social media.

 

To pursue our legitimate interest of documenting events for marketing purposes. We will only share such pictures/recordings on social media or for other public marketing purposes with your consent.For as long as we have an interest in using the material for marketing purposes. We will remove any pictures/recordings posted on social media if you withdraw your consent or we no longer have a need to show the material on social media.

 

Video surveillance footage if you visit the reception of our Stockholm office.To prevent and look into breaches.To pursue or legitimate interest of preventing and dealing with breaches.For three months after the footage was recorded.

 

If you are employed by or otherwise represent a potential customer or partner:

 

Type of personal data

 

Purpose of the processing

 

Legal basis for the processing (“why is the data processing necessary?”)

 

How long do we keep the data?

 

Your name and contact information, current job title and employerTo provide information about us and our products and services.

To administer, manage and develop our business, products and services.

To make your contact information available to our staff for the above purposes and to describe the nature of the relationship.

To perform analytics on sales intelligence, customer satisfaction and progress against business objectives.

 

To pursue our legitimate interest of promoting our products and services and to better understand the needs of customers and partners.

 

For as long as we think that you may have a professional interest in our products and services.
Your former job title and employer

 

To administer, manage and develop our business, products and services.

To make your contact information available to our staff for the above purposes and to describe the nature of the relationship.

To perform analytics on sales intelligence, customer satisfaction and progress against business objectives.

 

To pursue our legitimate interest of promoting our products and services and to better understand the needs of customers and partners.

Where applicable, to comply with a legal obligation.

For as long as we think that you may have a professional interest in our products and services.
Photographs/

recordings of events in which you may appear

To inform about events that we have organised, or participated in, in marketing communications or on social media.

 

To pursue our legitimate interest of documenting events for marketing purposes. We will only share such pictures/recordings on social media or for other public marketing purposes with your consent.For as long as we have an interest in using the material for marketing purposes. We will remove any pictures/recordings posted on social media if you withdraw your consent or we no longer have a need to show the material on social media.

 

Video surveillance footage if you visit the reception of our Stockholm office.To look into breaches.To pursue or legitimate interest of preventing and dealing with breaches.For three months after the footage was recorded.

 

With whom may we share your information?

 

Social Media platforms (such as Facebook, Twitter, Linkedin, my Newsdesk): If you attend one of our seminars as a speaker, we may state your name on social media. With your permission, we may also post pictures in which you appear on our social media sites.

Sales and marketing service partners: We may engage external sales and marketing consultants to help us identify customers who may have an interest in our services.

With other companies within the 4C Group (who are not joint controllers): The controller(s) of your data may share this information with other companies within the 4C Group if they are engaged as subcontractor or if it is otherwise necessary for the above-stated purposes.

Divestiture: We may need to disclose your personal data to third parties in the event that we sell or liquidate any part of our business or assets.

Legal compliance: We will disclose or share your personal data to comply with any legal obligation or to protect the rights, property, or safety of the 4C Strategies companies or our clients.

 

2.2 SUPPLIERS

 

We collect and process personal data about employees and individuals otherwise associated with suppliers for the purpose of enquiring about, and receiving, products and services; managing the relationship; and administering and developing our business, as further set out in this section.

 

 

Data Controller: 4C Group AB and the 4C company with whom the supplier has or has had a contractual relationship – or that would be the appropriate contracting party.

 

 

What information do we collect about you?

 

Information you give us

 

  • Your name and contact information (such as your email and telephone number) so that we can identify you and contact you in relation to the purpose for which you gave us your contact details (such as to receive information about the supplier’s products and services and to manage our relationship);
  • Your job title and employer so that we can identify you and assess the supplier’s products and services in relation to our needs;
  • Your former job title and employer if your status changes during the course of our contractual relationship or during the retention period.

 

Information we may collect about you

 

  • Your name, job title, employer and contact information if we have not received this information directly from you or your colleague, so that we can identify you and contact you regarding the products and/or services offered by the supplier;
  • Footage from video surveillance of you entering and leaving our offices in Stockholm (where applicable).

What do we do with your information?

If you are employed by or represent a current or former supplier:

 

Type of personal data

 

Purpose of the processing

 

Legal basis for the processing (“why is the data processing necessary?”)

 

How long do we keep the data?

 

Your contact information (including name), job title and employer.To receive information about the supplier and its products and services.

To administer, manage and develop our business, products and services, including fulfilling any contractual obligations towards the supplier.

To manage security, quality and risk in our operations.

To comply with any applicable laws.

To pursue our legitimate interest of managing our business.

To perform our contractual obligations towards the supplier.

Where applicable, to comply with a legal obligation.

For as long as we have a contractual relationship with the supplier and, thereafter, for as long as we need to keep a record of a supplier contact for legal reasons or have an interest in the supplier’s products and services.
Your former job title and employer

 

To administer, manage and develop our business, products and services, including fulfilling any contractual obligations towards the supplier.

To manage security, quality and risk in our operations.

To comply with any applicable laws.

 

To pursue our legitimate interest of managing our business.

 

For as long as we have a contractual relationship with the supplier and, thereafter, for as long as we need to keep a record of a former supplier contact.
Video surveillance footage if you visit the reception of our Stockholm office.To look into breaches.To pursue or legitimate interest of preventing and dealing with breaches.For three months after the footage was recorded.

 

If you are employed by or represent a potential supplier:

 

Type of personal data

 

Purpose of the processing

 

Legal basis for the processing (“why is the data processing necessary?”)

 

How long do we keep the data?

 

Your contact information (including name), job title and employer.To receive information about the supplier and its products and services.

To administer, manage and develop our business, products and services.

To manage security, quality and risk in our operations.

 

To pursue our legitimate interest of managing our business.

 

For as long as we have an interest in the supplier’s products and services.
Video surveillance footage if you visit the reception of our Stockholm office.To look into breaches.To pursue or legitimate interest of preventing and dealing with breaches.For three months after the footage was recorded.

 

With whom may we share your information?

 

With other companies within the 4C Group (who are not joint controllers): The controller(s) of your data may share this information with other companies within the 4C Group if they may have an interest in the supplier’s products or services or if it is otherwise necessary for the above-stated purposes.

Divestiture: We may need to disclose your personal data to third parties in the event that we sell or liquidate any part of our business or assets.

Legal compliance: We will disclose or share your personal data to comply with any legal obligation or to protect the rights, property, or safety of the 4C Strategies companies or our clients.

 

2.3 VISITORS TO OUR WEBSITE

 

We capture the IP addresses of website visitors to enable us to carry out forensics analyses in the event of security breaches. Please see our cookie statement for information on how we use cookies.

 

Visitors who ask us to get in touch by filling fill in a contact form on our website may provide us with personal data that we process as set out in this privacy statement or our privacy notice to job candidates.

 

2.4 VISITORS TO OUR OFFICES

 

We have security measures in place at our offices, including video surveillance at our headquarters in Stockholm.

Images captured through video surveillance are securely stored and only accessed on a need to know basis (e.g. to look into an incident). Recordings are typically automatically overwritten after three months, unless an issue is identified that requires investigation (such as unauthorized entry).

 

We require visitors to our Stockholm office to sign in at reception (providing their name, job title and employer as applicable). Visitor records are securely stored and only accessible on a need to know basis, for instance to look into an incident and to manage fire safety.

 

  1. WHERE DO WE STORE AND PROCESS YOUR PERSONAL DATA?

 

We strive to process all personal data within the EEA. If we have to transfer personal data to countries outside the EEA, we make sure that the transfer complies with applicable data protection laws. Any transfer made to a country not determined by the European Commission as providing an adequate level of protection for personal data, will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the standard contractual clauses approved by the European Commission.

 

  1. YOUR RIGHTS TO ACCESS, RECTIFICATION AND ERASURE

 

Your right to object to the processing: You have the right to object to any processing carried out based on legitimate interests pursued by us or third parties.

Your right to access your data: You may request a transcript of records if you would like to know and verify the information we process with respect to yourself.

Your right to rectify your data: You have the right to correct inaccurate or incomplete information we process about yourself.

Your right to request that we restrict or erase your data (“right to be forgotten”): You have the right to request that we restrict or delete your personal data, insofar as this personal data is no longer necessary for the purpose it was collected. However, certain legal obligations prevent us from immediately deleting parts of your data.

 

Please send us a message at dataprivacy@4cstrategies.com if you wish to exercise any of your rights as described above or if you have any questions regarding the way we process your data.

 

  1. COMPLAINTS

 

If you don’t agree with the way we process your data, please reach out to us at dataprivacy@4cstrategies.com

and we will try to resolve the problem. You also have the right to report concerns to the relevant supervisory authority:

 

Datainspektionen

Phone: 08-657 61 00

E-mail: datainspektionen@datainspektionen.se

Post: Datainspektionen, Box 8114, 104 20 Stockholm

 

Information Commissioner’s Office

Helpline: 0303 123 1113 (local rate – calls to this number cost the same as calls to 01 or 02 numbers)

Online reporting service: https://ico.org.uk/concerns/handling/

 

For the contact details to other national data protection authorities, please refer to: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

 

 

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