4M respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how 4M collects and processes your personal data through your use of this website and through your participation in XCC and Muskathlon events.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
4M UK CIO is the controller and responsible for your personal data and this website.
This privacy notice is issued on behalf of the 4M and its affiliates, being 4MUK Limited, so when we mention, “we”, “us” or “our” in this privacy notice, we are referring to the relevant 4M affiliate responsible for processing your data.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are: Steven Case
Full name of legal entity: 4M UK CIO
Name or title of data privacy manager: Finance Director
Email address: firstname.lastname@example.org
Postal address: 16 Barwick Close, Rustington, West Sussex, BN16 3TT, UK
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website includes links to third-party websites of our affiliates and partners such as Impact Marathons and Muskathlon.com. Clicking on those links or enabling those connections may allow those third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Dataincludes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Dataincludes billing address, delivery address, email address and telephone numbers.
• Financial Dataincludes bank account and payment card details.
• Transaction Dataincludes details about payments to and from you and other details of your XCC booking.
• Technical Dataincludes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website as well as satellite tracking data provided by GPS trackers from which it will be possible to determine your location.
• Profile Data includesyour username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Dataincludes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Stills Photographs, video and/or audio of your participation in an XCC or Muskathlon event.
We also ask you to provide us on a voluntary basis data concerning your healthbut only insofar as it relates to, and for the purpose of determining, your fitness to undertake an XCC or Muskathlon event. This is the only special category of data we ask you to provide.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of your XCC or Muskathlon booking or 4M Shop contract you and you fail to provide that data when requested, we may not be able to accept your booking. In this case, we may have to cancel your booking, but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We obtain data from and about you primarily through Direct interactions.You may give us your Identity and Contact Data by registering for an XCC or Muskathlon event or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
• Order a product from the 4M Shop;
• Book yourself on to an XCC or Muskathlon; or
• Enter into any direct interactions in relation to your XCC event or product purchased from the 4M shop.
We may also obtain data about your location through the use of a location ‘tracker’ which you may carry while on an XCC or Muskathlon event which tracks your position using GPS co-ordinates.
[SPECIFY HERE IF THERE ARE ANY OTHER WAYS 4M COLLECTS PERSONAL DATA].
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party).
• Where we need to comply with a legal or regulatory obligation.
In order to operate the XCC or Muskathlon and to meet Our obligations with respect to Your health and safety, you accept that We may distribute Your personal details, including but not limited to Your name, contact address, phone number, email address, and emergency contact and/or next of kin details to those involved in running the XCC. You further agree that for reasons including health and safety we shall be entitled at our discretion to track your and your group’s progress during an XCC or Muskathlon via a satellite tracking device. In entering into this contract, You accept that You are consenting
You have the right to withdraw consent to marketing at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest |
|To register you on an XCC or Muskathlon event||(a) Identity(b) Contact||Performance of a contract with you|
|To process and deliver your 4M Shop order or your XCC booking, including:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:|
(b) Asking you to give feedback on an XCC or Muskathlon event or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how people use our products the impact of XCC events)
|To deliver relevant website content and promotional material to you and measure or understand the effectiveness of XCC and Muskathlon events||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how you use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To promote health and safety during the course of an XCC outdoors event||(a) Identity, through GPS co-ordinates provided by a tracker|
(d) Health data provided by you on a voluntary basis and only to the extent relevant to your ability to undertake an XCC
|Necessary for our legitimate interests (to be aware of your position in remote locations and for your health and safety considerations )|
|To promote and generate publicity for the activities of 4M and its affiliates and for educational and marketing purposes.||(a) Identity, through photographs, video footage and/or using audio clips of the Participant during the XCC programme||You will be asked for your explicit consent where your personal image or voice features prominently in any photographs or photographs|
For our legitimate interests (to obtain your feedback on your XCC or Muskathlon experience, to develop XCC and Muskathlon programmes, to generate publicity for and grow the 4M brand and business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity|
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around promotion of 4M products and events.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased something from the 4M Shop or booked an XCC event from us if, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any organization outside the 4M group of companies for marketing purposes.
You can ask us or third parties to stop sending you promotional messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase or an XCC booking.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details above.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• 4M staff and members of the 4M leadership team.
• The relevant third-party operator of any Muskathlon you participate in.
• Muskathlon.com for promotional purposes.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the applicable data protection legislation.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasurebelow for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please do so at any time by Contacting us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.