Privacy Statements

When you use our services, you’re trusting us with your information. We understand our responsibilities in relation to privacy and we work hard to protect your data.

These Privacy Statements are meant to help you understand what information we collect, why we collect it, how we use it and how you can update, manage, export and delete your data.

Privacy Policy

This Privacy Policy applies between (1) you, as a User of this Website, our Services or a member of our Mailing Lists, and (2) 4N6, the owner of this Website and related Services. 4N6 takes the privacy of your information very seriously. This Privacy Policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website or our Services or your inclusion on any of our Mailing Lists.

You must be at least 18 years of age to use this Website or our Services. By using the Website or our Services and agreeing to the terms of the Privacy Policy, you represent and warrant that you are at least 18 years of age.

This Privacy Policy should be read alongside, and in addition to, our Terms and Conditions. Should you have any queries about this policy, you may contact 4N6 by email at [email protected]

Definitions and Interpretation

1. In this Privacy Policy, the following definitions are used:

• 4N6, we or us: 4N6 Ltd, a company registered in England and Wales under number 15477135 whose registered office is at 5th Floor, 167-169 Great Portland Street, London, W1W 5PF;
• Cookies: a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Information about the cookies used by this Website are set out in the clause below (Cookies);
• Data: collectively all information that is collected by us in relation to you via the Website, in relation to our Services, or for operating our Mailing Lists. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
• Data Protection Laws: any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;
• GDPR: the UK General Data Protection Regulation;
• Mailing Lists: Any lists of contacts that we maintain for providing information to you or gaining feedback from the wider market for the following purposes: to improve our offers specifically to you or more generally, to seek new or repeated business, and to advise you on improvements or changes to our business or our services;
• Services: any services provided to you by us under a contract governed by the Terms and Conditions of Service or otherwise, including the pre-contract negotiations and the provision of quotes;
• UK and EU Cookie Law: the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;
• User or you: any third party that accesses the Website or our Services or is included in our Mailing Lists, and is not either (i) employed by 4N6 and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to 4N6 and accessing the Website in connection with the provision of such services; and
• Website: the website that you are currently using, www.4n6.io, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. In this Privacy Policy, unless the context requires a different interpretation:

• the singular includes the plural and vice versa;
• references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Policy;
• a reference to a person includes firms, companies, government entities, trusts and partnerships;
• "including" is understood to mean "including without limitation";
• reference to any statutory provision includes any modification or amendment of it;
• the headings and sub-headings do not form part of this Privacy Policy.

Scope of this Privacy Policy

3. This Privacy Policy applies only to the actions of 4N6 and Users with respect to our Services, this Website and our Mailing Lists. It does not extend to any websites that can be accessed from this Website.

4. For purposes of the applicable Data Protection Laws, 4N6 is the "data controller". This means that 4N6 determines the purposes for which, and the manner in which, your Data is processed.

Data Collected

5. We may collect the following Data, which includes personal Data, about you:

• name;
• job title;
• employer;
• contact Information such as email addresses and telephone numbers;
• IP address (automatically collected);
• web browser type and version (automatically collected);
• operating system (automatically collected); and
• a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected).

6. We not intentionally or routinely collect sensitive personal data in relation to you. Where we identify our records include sensitive personal data about you, we will endeavour to delete this data.

How We Collect Data

7. We collect Data in the following ways: data is given to us by you; data is received from other sources; and data is collected automatically.

Data provided to Us by You

8. 4N6 will collect your Data in a number of ways, for example:

• when you contact us through the Website, by telephone, post, e-mail or through any other means;
• when you register with us and set up an account to receive our Services;
• when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
• when you enter a competition or promotion through a social media channel;
• when you make payments to us, through this Website or otherwise;
• when you request to be included on our Mailing Lists; or
• when you use our Services.

Data received from Third Parties

9. 4N6 may receive Data about you from third party sources, including commercially available mailing lists.

Data collected automatically

10. To the extent that you access the Website, we will collect your Data automatically, for example:

• we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and to the services we offer. This data includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
• we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

Our Use of Data

11. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

• internal record keeping;
• improvement of our products / services;
• transmission by email of marketing materials that may be of interest to you; and
• contact for market research purposes which may be done using email, telephone or post. Such information may be used to customise or update our Website or service offerings.

12. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

13. For your inclusion on Mailing Lists and any subsequent contacts via those mailing lists, we'll need your consent or to establish that we have a legitimate interest in processing your Data:

• soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular service, and we are marketing similar services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
• you are also able to provide explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
• where consent is not the basis for processing, we may rely on a legitimate interest assessment, where we balance the benefits to us and you, against the privacy impact on you and whether the processing is something you could reasonably expect.
• if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.

14. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

15. We may use your Data to show you 4N6 adverts and other content on other websites. If you do not want us to use your data to show you 4N6 adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed "Cookies" below).

Who We Share Data With

16. We may share your Data with the following groups of people for the following reasons:

• any of our group companies or affiliates - to ensure the proper administration of business affairs;
• our employees, agents and/or professional advisors - to provide services to you and to obtain advice;
• third party service providers who provide services to us which require the processing of personal data - to help third party service providers to perform functions on our behalf to help ensure our business operates smoothly; or
• relevant authorities - to facilitate the detection of crime or the collection of taxes or duties.

Keeping Data Secure

17. We will use technical and organisational measures to safeguard your Data, for example:

• access to your account requires a sign-in that is unique to you.
• we store your Data on secure servers.
• our employees and agents are appropriately trained in the handling and processing of data.
• we ensure that our third party service providers have similar appropriate mechanisms in place.

18. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: [email protected]

19. If you want detailed information on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit one of the following recommended resources:

• The National Cyber Security Centre's advice including the Cyber Aware advice portal: https://www.ncsc.gov.uk/section/information-for/

• Get Safe Online, backed by leading UK businesses: https://www.getsafeonline.org/business/

Data Retention

20. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Data be deleted.

21. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your Rights

22. You have the following rights in relation to your Data:

• Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
• Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
• Right to erase - the right to request that we delete or remove your Data from our systems.
• Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
• Right to data portability - the right to request that we move, copy or transfer your Data.
• Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

23. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: [email protected]

24. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/. We are registered as a Data Controller with the Information Commissioner’s Office (ICO) with registration number ZB671460.

25. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Transfers Outside the United Kingdom and European Economic Area

26. Data we collect from you will be stored and processed by us in UK, European Economic Area (EEA) and other countries with equivalent legal protections, or by our third party service providers in the locations they operate.

27. Your Data may be transferred to and held in countries outside of the UK and EEA, either temporarily or permanently by us or our third party service providers.

28. We will only allow the transfer of Data outside the UK or EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission.

29. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws. For further details, please see the Sub-processors addendum below.

Links to Other Websites

30. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the Privacy Policy or statement of other websites prior to using them.

Changes of Business Ownership and Control

31. 4N6 may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of 4N6. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally collected by us.

32. We may also disclose Data to a prospective purchaser of our business or any part of it.

33. In the above instances, we will take steps with the aim of ensuring your privacy is protected including via non-disclosure agreements.

Cookies

34. This Website may place and access certain Cookies on your computer. 4N6 uses Cookies to improve your experience of using the Website and to improve our range of services. 4N6 has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

35. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

36. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling 4N6 to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

37. This Website may place the following Cookies:

• Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the Website, you agree to our placement of functionality cookie.
• Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

38. We give you control over which Cookies we use. You can find how to adjust your cookies preferences at any time at: www.4n6.io/cookie-policy

39. You can also choose to enable or disable Cookies in your web browser. By default, many web browsers accept Cookies but this can be changed. For further details, please see the help menu in your web browser. You can switch off Cookies at any time, however, you may lose any information that enables you to access the Website more quickly and efficiently.

40. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

41. It is recommended that you ensure that your web browser is up-to-date and that you consult the help and guidance provided by the vendor of your web browser if you are unsure about adjusting your privacy settings.

42. For more information generally on cookies, including how to disable them, please refer to https://ico.org.uk/for-the-public/online/cookies/

General

43. You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected.

44. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.

45. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

46. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to our Privacy Policy

47. 4N6 reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Privacy Policy on your first use of our Services or the Website following the alterations, or from the next time we contact you via our Mailing Lists (whichever happens earlier).

Privacy Policy Last Updated: 1 Nov 2024

Sub-processors

In order to deliver services, 4N6 may engage third party data processors to process, store or transit personal Data. This section provides important information about the identity and role of each sub-processor, as well as the geographic location in which the data is stored, processed or transited via.

The information provided here is done so in the interest of transparency and does not provide any additional rights or remedies above those detailed in the Terms and Conditions of Service and the above Privacy Policy.

Due Diligence

4N6 undertake a robust due diligence process when appointing outsourcing partners and sub-processors. In relation to sub-processing activities, 4N6 only engage reputable vendors who are contractually bound to maintain data privacy to the extent applicable to current data protection legislation.

Infrastructure Sub-processors

4N6 use a number of third party IT and communications service providers to store and process data. Using third-party IT services allow us to scale in line with demand, protect against external threats and ensure business continuity.