New UK Policy for Oversight of Critical Third Parties (CTPs) in the Financial Sector
4C Group AB (publ) and its subsidiaries (“4C”) are committed to protecting your privacy. This Privacy Notice set out how and why 4C processes your personal data. Processing of your personal data may occur when visiting our website or in communication with us when representing a customer, supplier, investor or partner. This Privacy Notice further describes your rights.
The General Data Protection Regulation (“GDPR”) is applicable to the 4C companies established in the EU/EEA and UK. Personal data may be processed by all 4C companies as joint controllers or by one 4C company as set out below. If the personal data is processed by joint controllers you will, as a data subject, have the right to exercise your rights by sending a request to one of the joint controllers of your choice.
Processing
Category | Categories of Data Subjects | Personal Data | Purpose | Legal Basis | Recipient of Personal Data | Source | Controller |
Sales processes and project coordination | Potential customers, customers and partners | 4C may process your name, title, email, phone number and role in projects in sales material, contracts, invoices and internal systems for tracking sales processes and for project coordination. | Manage and track sales processes and coordinate our projects. | 4C has a legitimate interest to manage and track sales processes and to coordinate our projects. | 4C may share certain material such as invoices with auditors if required. | From you, your employer or outbound sales agencies. | The 4C company that is the contracting party or potential contracting party. |
Marketing | Potential customers, customers, partners and visitors at events | 4C may use your personal data such as photos and videos from events and delivery, name, email, phone number and title in internal and external communication such as sales material and posts on 4C’s website, Twitter, Facebook, Instagram YouTube and LinkedIn.
| Internal and external communication and to promote 4C’s services. | 4C has a legitimate interest to promote our services and use the personal data in external and internal communication. | Potential customers and customers | From you, your employer or from events | Sales material, photos and videos: Joint controllers
Social media and website: 4C Group AB |
Facebook and LinkedIn | Visitors on Facebook and LinkedIn page | 4C may process statistics with Page Insights if you visit 4C’s Facebook or LinkedIn Page. | 4C uses Page Insights to analyse statistics of website visitors. | 4C has a legitimate interest to analyse statistic collected by platform provider. |
| Facebook | 4C Group AB (Facebook and LinkedIn are joint controllers). |
Forms on 4C’s website and in webinar service | Website visitors and webinar participants | 4C may process your name, email, phone number, title, place of work and information needed for events (for example potential allergies) when you fill in forms on our website/in webinar service to sign up for events, get in contact etc. | To be able to contact website visitors | Website visitor/webinar participant consents to the processing when submitting the data. |
| From you. | Joint controllers |
Cookies | Website visitors | 4C may place cookies on your browser that store IP address and information about your behaviour on the website. | To get statistic from our website and to protect against spam. | Website visitor consents to the processing in cookie banner. |
| From you. | 4C Group AB |
Project Delivery | Customer | 4C may process your personal data such as name, title, email, phone number, log in details and role in project in project material, in support portal (if 4C deliver support), Exonaut (if Exonaut is used in project) and in customer satisfaction survey (if customer choose to participate). | To deliver the agreed services to customer and to evaluate 4C’s services. | 4C has a legitimate interest to deliver the agreed services to customer and to evaluate 4C’s services. |
| From you or from your employer. | The 4C company that is the contracting party. |
Investor relations | Potential investors and investors | 4C may process your name, email, address, phone number, national identification number, info about your shares and your role/title if you have invested or showed your interest in investing in 4C. | To keep track of and contact investors and potential investors. | 4C has a legitimate interest to keep track of and contact investors and potential investors. |
| From you. | 4C Group AB |
Communication | Customers, partners, suppliers, investors and other external parties | 4C may process your personal data such as name, user name, title, phone number, email, place of work, photos, video, location, IP address etc. if this personal data is revealed in emails, Teams messages or in other channel of communication. | Internal and external communication and to organize webinars and meetings. | 4C has a legitimate interest to use certain channels for internal and external communication and to organize webinars and meetings. |
| From you. | Joint controllers |
Supplier | Suppliers | 4C may process your name, title, email and phone number in contracts and supplier invoices. | To track, book-keep and pay vendor invoices and archive signed contracts. | 4C has a legitimate interest to track, book-keep and pay vendor invoices and archive signed contracts. | 4C may share certain material such as invoices with auditors if required. | From you or from your employer. | The 4C company that is the contracting party. |
You have the right to withdraw your consent if the legal basis for the processing is consent. Your personal data will only be processed for as long as the processing is necessary for the purpose.
Third Country Transfer
4C may transfer personal data to other companies within 4C Group, including companies established in third countries. For certain processing, 4C may use third party suppliers that process personal data in a third country. 4C will ensure appropriate safeguards for any transfer to third countries. The transfer will either be based on an Adequacy Decision by the European Commission or Standard Contractual Clauses approved by the European Commission. Please reach out to our Data Protection Manager (contact details below) for more information about third country transfers.
Data Subjects Rights
Data Protection Manager
If you want to contact 4C regarding the processing of your personal data or if you want to exercise your rights as described above or withdraw your consent, please contact 4C’s Data Protection Manager, at: privacy@4cstrategies.com or by letter to 4C Group AB, Att: DPO, Vattugatan 17, 111 52 Stockholm, Sweden.
Right to lodge a complaint
You have the right to lodge a complaint with a Supervisory Authority or seek remedy in court if you believe that your data protection rights have been breached. See contact details for Supervisory Authorities below.
Sweden | Norway | UK |
Integritetsskyddsmyndigheten | Datatilsynet https://www.datatilsynet.no | The information Commissioner 0303 123 1113 |
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