For residents of the UK and EU, please note that this Policy has been updated in accordance with the requirements of EU General Data Protection Regulation (GDPR) as of 25th May 2018. For residents of the US, by visiting this web site you agree to this Policy, you consent to and authorise our using your personal information as described in this Policy.
Please note that merely by visiting our website, www.sector4focus.co.uk, or clicking any internal link on that site, your are NOT transferring any data to us.
1.0 What is Sector 4 Focus?
S4F is a consultancy service operated by Tom Levitt. More details are available on relevant pages of this web site.
2.0 Who provides the Services and controls my information?
For the purposes of EU / UK data protection law, Sector 4 Focus Limited is your data controller.
Normally the contact data we hold will relate to your place of work and occasionally S4F may update such data from public sites such as Linked In. If you change your place of work, your information will be dealt with as from the date on which S4F becomes aware of such changes.
Sector 4 Focus maintains a contacts book and relies on a number of legal bases to collect, use, and otherwise process the information we have about you for the purposes described in this Policy. We do not share such data with others in a traceable form nor do we hold subjective data such as your opinions. Our treatment and use of data respects the following principles:
- We will only use data concerning you as necessary:
- to allow S4F to deliver the Services which it exists to provide;
- to comply with a legal obligation, a court order, or to exercise and defend legal claims;
- to protect your vital interests, and/or those of others;
- in the public interest;
- You may revoke your consent to be on our database at any time;
- We may use data from third parties where you have made your information manifestly public, such as through Linked In.
3.0 Our legitimate interests
We process your information in furtherance of the following legitimate interests:
- Keeping our Services safe and secure: we use your information as necessary to pursue our legitimate interests in ensuring S4F is secure, such as by implementing and enhancing security measures and protections, protecting against fraud, spam and abuse.
- Providing, improving and developing the Services: we use your information to provide the Services, including any personalised services. We do so as necessary to pursue our legitimate interests of providing an innovative and tailored offering to our clients and collaborators on a sustained basis.
4.0 Information we collect
When we provide Services, we collect or receive information in several different ways. In many cases you choose what information to provide, although some information is required in order for S4F to provide Services. We use this information for the purposes that are described further below.
4.1 From you, or with your permission. We collect a variety of information from you when you provide it to us directly, when we request it from you, or when you give us permission to get it from a third party source. For example:
- When you are first in contact with S4F you may volunteer your name, address, phone number, email address, and similar information through the use of business cards, emails, Linked In profiles, Twitter feeds, web sites or other personal contact.
- You may share the email address or other contact details of a third party with us for reasons of our mutual interest.
4.2 We do not collect information from your browser, computer, mobile device or cookies to provide us with technical or any other information.
4.3 We do not generally harvest bulk data from third parties and public sources. On rare occasions, for research purpose, we may do so, when we would use public sources of information, such as census data, street addresses or property maps to provide us with information for specific survey purposes.
5.0 How we use your information
We use the information we have to help us provide, operate, improve, understand, customise, support, and market our Services.
5.1 Advertising. We do not use information to provide or improve advertisements or other commercial offerings nor to facilitate others to do so.
5.2 Newsletters. On rare occasions we have been known to contact our database in bulk to inform them of significant events in the history of S4F.
6.0 Your Choices
You have legal rights over what and how your information is stored or used. These include access to, rectification of and deletion of your information. Access to any data we may hold about you will be granted on request (by email) and all such rights upheld.
7.0 Your Rights
You benefit from a number of rights in relation to your information that we process. While some of these rights apply generally, certain rights apply only in certain limited cases. You have rights relating to:
7.1 Revoking consent. Where you have previously provided your consent, you have the right to withdraw your consent to the use or holding of your information at any time. For example, you can withdraw your consent to receiving mass emails from us by sending us an email. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
7.2 Making a complaint. If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), and you are not satisfied with our response, you have the right to raise the matter with the UK Information Commissioner’s Office.
8.0 Sharing information with third parties
We only share information on a limited basis with service providers, affiliates, partners, and other third parties where it is necessary to provide our Services, or for other purposes described above.
8.1 Business re-organisation. In instances where S4F is subject to a re-organisation, such as a merger or acquisition of some or all of its assets, we may, in accordance with our legitimate interests, need to share information in the course of the transaction. In such circumstances, your information may be disclosed, where permitted by applicable law, in connection with a corporate restructuring, sale, or assignment of assets, merger, or other changes of control or financial status of S4F.
8.2 Legal and safety reasons. We may retain, preserve, or share your personal information if we have a good-faith belief that it is reasonably necessary to (a) respond, based on applicable law, to a legal request (e.g., a subpoena, search warrant, court order, or other request from government or law enforcement); (b) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; (c) protect our rights, property, or safety; (d) enforce any agreements we have with you; (e) prevent physical injury or other harm to any person or entity, including yourself and members of the general public.
8.3 Aggregated information. We do not currently share anonymised and aggregated information about our database with others but we reserve the right so to do.
9.0 Data transfers
We do not transfer personal data outside the UK or EU, but we reserve the right so to do in accordance with the relevant UK or EU data protection law, subject to legal safeguards, where it is necessary to provide our Services.
S4F will only ever transfer personal data as permitted by law, and will take steps intended to ensure appropriate protection of your personal information. If you have questions, please contact us.
10.0 Data retention
We may retain your information in our databases and records for as long as necessary in light of the purposes set out in this Policy, subject to any legal obligations to further retain such information.
11.0 Additional information
11.1 Account Security. S4F uses technical and organisational measures intended to keep your data secure and does not store data on or make accessible any such data through its website.
11.2 Other Services and Websites. In using the S4F website, you may come across links to websites and services operated by third parties. These third parties have their own privacy policies, which will apply to your activity if you click on the link and access their website or service. We do not accept any responsibility or liability for such external sites’ privacy and security practices.
11.3 Amendments to the Policy
From time to time we may make changes to this Policy, so please review it periodically. If we materially change our Policy, we will take steps to notify you in advance of the change, for example by emailing you or by posting a notice on the S4F website.
12.0 Contact Us (link)