Privacy Policy

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

• Data controller: 4Aces Digital Limited
• How we collect or obtain information about you: When you provide it to us (e.g. by contacting us, placing an order on our website and by signing up to our e-newsletter), from your use of our website, using cookies and similar technologies, and, from third parties.
• Information we collect: name, contact details, job title, job role, payment information e.g. your credit or debit card details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), VAT number (if applicable), business social identifiers, business size (both number of employees and annual revenue), business financials, business description and business location.
• How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.
• Disclosure of your information to third parties: to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you and where required by law or to enforce our legal rights.
• Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
• How long we retain your information: We retain user information for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled how long we retain your information.
• How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology where necessary and only granting access to your information where necessary.
• Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional, analytical and targeting cookies. For more information, please visit our cookies policy here: 4acesdigital.co.uk/cookies
• Transfers of your information outside the European Economic Area: in certain circumstances we transfer your information outside of the European Economic Area to the United States. Where we do so, we will ensure appropriate safeguards are in place, including the EU-U.S. Privacy Shield
• Use of automated decision making and profiling: we do not create a profile on you, we do however create a profile on the company you are associated with. For example, whilst we do process profile information such as financial information, we do not collect your personal income, we only collect your company revenue. We also use web analytics, cookies, web beacons or server logs analysis tools (profiling) and also use targeting cookies to display advertisements to people who visit our website and other websites around the internet (e.g. using the Google Adwords, LinkedIn Campaigns).
• Your rights in relation to your information
  • to access your information and to receive information about its use
  • to have your information corrected and/or completed
  • to have your information deleted
  • to restrict the use of your information
  • to receive your information in a portable format
  • to object to the use of your information
  • to withdraw your consent to the use of your information
  • not to have significant decisions made about you based solely on automated processing of your information, including profiling
  • to complain to a supervisory authority
• Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.
  

The data controller in respect of our website is 4Aces Digital Limited (company registration number: 08230089) of 27 Old Gloucester St, Bloomsbury, London WC1N 3AX.

The data controller’s representative is Rana K Hussain. You can contact the data controller’s representative by writing to 4Aces Digital Limited of 27 Old Gloucester St, Bloomsbury, London WC1N 3AX or sending an email to compliance@4acesdigital.co.uk.

If you have any questions about this Privacy Policy, please contact the data controller.

When you sign up for our e-newsletter on our website or opt to receive news and offers from us by entering your name and email address and clicking subscribe or ticking a box at checkout indicating that you would like to receive our e-newsletter, we collect your name and email address.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use our own service to send out our e-newsletter and administer our mailing list Gold Lasso, Inc. 25B Chestnut Street Gaithersburg, MD U.S.A. Their privacy policy is available here https://www.goldlasso.com/legal-policies/3-gold-lasso-eloop-terms-conditions On you submit to subscribe for our e-newsletter may be stored outside the European Economic Area on servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve.

For more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available here: 4acesdigital.co.uk/cookies

For more information about our third party mailing list provider and how they use web beacons, please see their privacy policy which is available here: Their privacy policy is available here https://www.goldlasso.com/legal-policies/3-gold-lasso-eloop-terms-conditions

When you register and create an account on our website, we collect the following information: First name, email address, IP address and how you heard about us –) and role and any other information you provide to us when you complete the registration form, including any optional information you provide about yourself in the more about yourself section.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing: necessary to perform a contract [or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: creating an account on our website is necessary to allow you to access the goods and services you have purchased from us.

AND

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our website to facilitate the running and operation of our business.

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored outside the European Economic Area on our server Gold Lasso, Inc. 25B Chestnut Street Gaithersburg, MD U.S.A. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Mandatory information

When you place an order for goods or services on our website, we collect your first name, last name, card number, expiry date, CVC, Zip Code/post Code and if applicable Coupon Code. If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions

At checkout you will have the option of receiving marketing communications from us.

Our goods and services

You can opt in to receiving marketing communications from us in relation to our goods and services by email, text message, phone, and/or post by ticking a box indicating that you would like to receive such communications.

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use a third party service to administer our mailing list, Gold Lasso, Inc. 25B Chestnut Street Gaithersburg, MD U.S.A. Their privacy policy is available here https://www.goldlasso.com/legal-policies/3-gold-lasso-eloop-terms-conditions

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails.

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through which our emails achieve. For more information on how we use web beacons in our emails, see our cookies policy which is available here: 4Aces digital.co.uk/cookies

For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here https://www.goldlasso.com/legal-policies/3-gold-lasso-eloop-terms-conditions

Third party goods and services

In addition to receiving information about our products and services you can opt in to receiving marketing communications from us in relation to third party goods and services by email by ticking a box indicating that you would like to receive such communications.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about third party goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use third party Gold Lasso, Inc. 25B Chestnut Street Gaithersburg, MD U.S.A. to administer our mailing list,.

Information you submit to subscribe for our e-newsletter will be stored within and outside the European Economic Area on our use third party Gold Lasso, Inc. 25B Chestnut Street Gaithersburg, MD U.S.A. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through which our emails achieve. For more information on how we use web beacons in our emails, see our cookies policy which is available here: 4Aces digital.co.uk/cookies

For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here https://www.goldlasso.com/legal-policies/3-gold-lasso-eloop-terms-conditions.

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide the service or obtain additional information to help us understand your requirements in more detail or provide you with a quotation for a service or product) we will obtain information about you from certain private and publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, lead generation companies, business directories, media publications, social media, and websites (including your own website if you have one).

In certain circumstances will also obtain information about you from private sources, both EU and non-EU, such as Twitter and Facebook. Gold Lasso, Inc. 25B Chestnut Street Gaithersburg, MD U.S.A. Their privacy policy is available here https://www.goldlasso.com/legal-policies/3-gold-lasso-eloop-terms-conditions

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

OR

Legal basis for processing: contract (Article 6(1)(b) of the General Data Protection Regulation).
Legitimate interest relied on: processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.

Use of automated decision making for advertising

We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here: 4Aces digital.co.uk/cookies

Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.

Significance and envisaged consequences: cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.

How to object: you can block these cookies by using the cookies control management tool on your site (if you use one) blocking third party cookies using browser settings, or insert specific method e.g. for Google DoubleClick, by opting out of seeing personalised ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB]. For further information, please see our cookies policy: 4acedigital.co.uk.cookies

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Use of profiling for web analytics

Our web analytics service, Google Analytics collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy 4acesdigital.co.uk/cookies). [Information collected about you, once collected is anonymised and stored on an aggregate basis.

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by You may use our Cookie Control Tool to opt out) and your location will be analysed based on your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our website and content

Use of profiling in marketing emails

We use web beacons in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on). Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including open rates, click through rates.

How to object: You may unsubscribe from any of our marketing emails via the unsubscribe link however, if you still want to receive our email marketing messages but just want the web beacons turning off then you can email us at compliance@4acesdigital.co.uk and we will complete this.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content.

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

• Telephone provider(s), including BT Group. Their privacy policy is available here: https://ee.co.uk/help/help-new/general/privacy/ee-privacy-policy
• Email provider(s), including Google, inc. Their privacy policy is available here: https://policies.google.com/privacy

Web hosting company, HostGator.com, 5005 Mitchelldale Suite #100, Houston, TX 77092, United States of America, (866) 964-2867.The privacy policy of which is available here https://www.hostgator.com/privacy.

Our third party service providers are located in Europe apart from above, which are located in the United States.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

We disclose your information to other third parties, as set out below.

Providing information to users for data enhancement.

Gold Lasso, Inc. 25B Chestnut Street Gaithersburg, MD U.S.A. is used by many different companies to enhance their corporate emails with a corporate profile including the company name, address, telephone number, description, size, social identifiers (twitter ID for instance) and financial information (revenue, cash at bank, total assets, total liabilities for instance).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): we share your information with these third parties to perform a contract
Legitimate interest(s): to facilitate the running and operation of our business.

You can delete your information from Contact Enhance or object to us processing your information at any time by emailing us at compliance@4acesdigital.co.uk

Transfer and storage of your information

Information collected by Gold Lasso, Inc. 25B Chestnut Street Gaithersburg, MD U.S.A. is stored outside the European Economic Area in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Enhancing company names or domains with contact information.

Gold Lasso, Inc. is also able to enhance corporate domains and/or company name with a corporate contact by job title(s), including their first name, last name and email address, where this email address was found (online) and when it was last seen at that source.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): we share your information with these third parties to perform a contract
Legitimate interest(s): to facilitate the running and operation of our business.

You can delete your information from Contact Enhance or object to us processing your information at anytime by emailing us at compliance@4acesdigital.co.uk

Review Management.

When you place an order with us we send your information to Trigger in order to request and manage a review of our service from you in order to help us improve our range of products, goods and services..

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): we share your information with these third parties to perform a contract
Legitimate interest(s): to facilitate the running and operation of our business.

You can delete your information from 4Aces Digital or object to us processing your information at anytime by emailing us at compliance@4acesdigital.co.uk

Transfer and storage of your information

Information collected by 4Aces Digital is stored outside the European Economic Area on Gold Lasso, Inc servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Providing information to third parties such as Google Inc.. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.]

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, business partners, independent contractors, and insurers, Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts. Our accountants are Shahidullah & Co are located in England.

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

Server log information: we retain information on our server logs for a period 56 months.

Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 56 further months after which point we will delete your information.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

• the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
• whether we have any legal basis to continue to process your information (such as your consent);
• how valuable your information is (both now and in the future);
• any relevant agreed industry practices on how long information should be retained;
• the levels of risk, cost and liability involved with us continuing to hold the information;
• how hard it is to ensure that the information can be kept up to date and accurate; and

any relevant surrounding circumstances (such as the nature and status of our relationship with you).

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. Our third party email provider is: Gold Lasso, Inc. 25B Chestnut Street Gaithersburg, MD U.S.A. Their privacy policy is available here https://www.goldlasso.com/legal-policies/3-gold-lasso-eloop-terms-conditions Country of storage: United States. This country is subject to an adequacy decision by the European Commission.

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to or sending an email to compliance@4acesdigital.co.uk

• to request access to your information and information related to our use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
• to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

• https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
• https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to or sending an email to compliance@4acesdigital.co.uk:

• to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
• to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

• clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
• sending an email to compliance@4acesdigital.co.uk, asking that we stop sending you marketing communications or by including the words “OPT OUT” or “unsubscribe” – please note that this method is not 100% guaranteed as it relies upon the 100% delivery to our inbox.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: 4acesdigital.co.uk/cookies

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to info@4acesdigital.co.uk

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: 4acesdigital.co.uk/cookies

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.