PRIVACY
POLICY
Fourth Floor Privacy Policy
This privacy policy covers the processing of personal data by the Fourth Floor Group (“Fourth Floor”), including Fourth Floor Creative Limited (“Fourth Floor Creative”), Explosive Alan Productions Limited (“Explosive Alan”) and Fourth Floor Nordic AB (“Fourth Floor Nordic”).
For the purpose of the General Data Protection Regulation ((EU) 2016/679), the Data Protection Act 2018 (the Act) and the UK GDPR (as defined section 3(10) (as supplemented by section 205(4)) of the Act, the data controller is:
Fourth Floor Creative, of Fourth Floor King William House, 13 Queen Square, Bristol, United Kingdom, BS1 4NT, where you provide services to, or receive services from, Fourth Floor anywhere in the world except the Nordic region;
Fourth Floor Nordic, of Stockholm kommun, Stockholms län, Fleminggatan 23, 112 26 STOCKHOLM, where you provide services to, or receive services from, Fourth Floor in the Nordic region;
Explosive Alan Productions Limited, of 9 Bridge Street, Walton-On-Thames, England, KT12 1AE where you provide services to, or receive services from, Explosive Alan
Fourth Floor Creative’s European representative is Fourth Floor Nordic, Stockholm kommun, Stockholms län, Fleminggatan 23, 112 26 STOCKHOLM, email dataprotection@fourthfloorcreative.co
Fourth Floor is a next-generation global marketing services group specialising in:
Planning, managing and executing marketing campaigns for brands;
Producing branded content, connecting brands with audiences through authentic, creative content they want to engage with;
Event management, designing, managing and talent provision for live events, launch and activations, conventions etc;
Merchandise services under the Fresh brand (www.freshstore.co), providing high quality and bespoke mechandise and collectables, product design, store management and customer service;
Supporting and building audience communities where purpose and experience and understanding culture are key; and
Producing actionable insight from social content data and our expertise to build partnerships that bring the right creators and games together, and improve our understanding of influence
Developing technology products that simplify and improve our overall service delivery and enhance clients and creators experiences.
Our commitments
Our mission is to inspire and enable human creativity to thrive and for that creativity to make a positive impact on the world. We deliver services that aim to provide value for clients and their brands, creators and the audience, ensuring that everything we do is legal, decent, honest, truthful and within regulatory requirements. As part of delivering our services we may, from time to time, use certain data which relates to individuals. In doing so we commit to:
Only ever processing or retaining personal data if we have a lawful basis for doing so;
Being transparent about the data we hold and what we do with it;
Only collect the minimum data we need for an agreed purpose;
Ensure the data we have is accurate and up-to-date; and
Keep data safe and secure.
What personal information do we collect about you and how do we use it?
We have summarised below the type of information we collect and how we use it, depending on how the information is obtained and what it is used for:
Information you provide to us as a new client
What is collected
If you are a new client who want us to provide you with any branded content and/or other marketing services, you will need to fill out a new client form. Through that form, we will collect certain details including the name, job title, email address and telephone number of your representative(s), along with the full legal name and business address of the client and VAT number.
What we use it for
We use this information for account management and to enable us to provide marketing services to you in accordance with the client contract agreed between you and Fourth Floor.
Information you provide to us as a new creator
What is collected
If you are a new creator who may create and/or promote branded content on behalf of Fourth Floor and its clients in return for payment, you will need to fill out a new creator information form. Through that form, we will collect the name, job title, email address and telephone number of your representative, along with your full legal name, business address and bank details.
What we use it for
We use this information to enable us to exercise our rights and perform our obligations in the creator contract agreed between you and Fourth Floor, including to pay you the agreed price for branded content or services that you create.
Information you provide to us as a new supplier
What is collected
If you are a new supplier who may provide services to or on behalf of Fourth Floor and its clients and creators in return for payment, you will need to fill out a new supplier information form. Through that form, we will collect the name, job title, email address and telephone number, along with the full legal name and business address, VAT number and bank details.
What we use it for
We use this information to enable us to exercise our rights and perform our obligations in the supplier contract agreed between you and Fourth Floor, including to pay you the agreed price for services provided.
Information relating to creators and content which we obtain from social platforms
What is collected
We access publicly available data from social platforms comprising:
data regarding the success of a particular campaign which has been executed by us on behalf of a client, including data pertaining to content views, impressions and engagements;
information relating to creators and their content, including the chosen social name of creators.
This may be combined with other information from publicly available sources and analytics data that our clients and creators provide to add information or narrative to the performance analysis.
What we use it for
We use this information to compile reports for our clients on the success of campaigns which we run on their behalf in accordance with our client contracts, to find creators who have the experience necessary to create branded content or provide services on behalf of our clients and to enable us to gather information on market trends and other information to support our service delivery.
Data analytics that you provide to us as a client
What is collected
If you have appointed us to provide marketing services to you, we may ask you to provide or you may choose to provide data analytics in relation to any of your previous campaigns and any data analytics you are able to obtain in relation to campaigns which we run on your behalf.
What we use it for
We will use this information to enable us to enhance the marketing services we provide to you in accordance with the client contract agreed between you and Fourth Floor.
Data analytics that you provide to us as a creator
What is collected
If we have appointed you to create and/or promote branded content on our behalf, we may ask you to provide or you may choose to provide data analytics in relation to any of your previous campaigns and any data analytics you are able to obtain in relation to campaigns which you create and/or promote on behalf of us and our clients.
What we use it for
We will use this information to compile reports for our clients on the success of campaigns which we run on their behalf, in accordance with our client contracts, and to help you and Fourth Floor build upon the success of previous campaigns.
Information you provide to us when you order merchandise from us
What is collected
If you order any of our bespoke merchandise through any of our merchandise sites, you will be required to provide us with your [name, email address or contact telephone number, postal address and billing address if different to postal address] and payment information.
What we use it for
We will use the information that you provide to enable us to fulfil your order, to collect payment from you and for fraud management purposes. [We may use third parties to help us fulfil your order, in which case we will share your information with those third parties.]
We may also contact you about similar merchandise which we think you may be interested in, unless you have told us that you do not want to receive this information. We will also keep details of orders for tax and accounting purposes.
In some cases, we may advertise the merchandise of third parties. If that is the case, we will direct you to their website so that you can order the merchandise through them.
Information you provide to us when you sign up to receive emails or newsletters about our branded merchandise or marketing services
What is collected
If you ask us to send you emails and/or newsletters about our branded merchandise or marketing services, you will need to provide us with your name, and email address.
What we use it for
We use this information to provide you with the emails or newsletters that you have asked us to send.
Information you provide to us when you attend one of our events or events we run on behalf of our clients
What is collected
If you register to attend one of our events, awards or conferences or any events, awards or conferences we run on behalf of our clients, you will need to provide us with your [name, date of birth, job title, email address and telephone number, as well as the full legal name of your employer].
What we use it for
We will use this information to help us manage attendee numbers and run the event, award or conference. [If we are running the event, award or conference on behalf of one of our clients, we will share this information with our client to enable them to manage attendee numbers and host the event].
Information you provide to us when you enter one of our competitions or competitions we run on behalf of clients
What is collected
If you enter one of our competitions or competitions we run on behalf of clients, you will need to provide us with your [name, email address, postal address, date of birth and contact telephone number].
What we use it for
We will use this information to manage the competition. If we are running the competition on behalf of a client, we will provide this information to the client. If third parties sponsor the competition, we may provide your information to them to enable them to send you a prize, if you are a winner.
Information you provide to us when you apply for a job with us
What is collected
If you apply for a job with us, you will need to provide us with your [name, email address, postal address and contact telephone number], along with an up to date CV and covering letter.
What we use it for
We will use the information you provide, along with any notes we make during any interviews, to assess whether the job we have available is suited to you and to contact you in relation to the job.
Information you provide when you access our Fourth Floor Platform or other secure systems or databases
What is collected
If you are a creator or client who wishes to access our Fourth Floor Platform or any of our other secure systems or databases, you will be required to provide your personal log on details.
What we use it for
We will use this information to assess whether you are authorised to access the relevant system/database and if so, grant access.
Information we collect through cookies and similar technologies
What is collected
We may collect information about you through the use of cookies and similar technologies. For more information about what we collect and to manage the cookies and similar technologies used, please see our cookies policy.
What we use it for
For more information about how we use the information collected through cookies and similar technologies, please see our cookies policy.
Information relating to you and your content on social platforms
What is collected
If you have signed up to a social platform we will use your content/activity you upload which includes messages, posts, comments, emoji.
We will also use your profile information and the information you provide when you join a social platform channel, server, group that we are managing on behalf of a client.
This may be combined with other information from publicly available sources and analytics data that our clients and creators provide to add information or narrative to the performance analysis.
What we use it for
We will use this information as part of our service delivery to clients compiling content analytics and sentiment reports.
We will also use your platform activity to make content moderation decisions to ensure we meet our commitments to communities we are supporting and channels we are managing.
In addition, we may use any of the information described above to respond to requests from law enforcement authorities or to comply with any legal or regulatory requirement.
We do not collect any personal data that can be classified as ‘Special Categories’ under EU GDPR regulation or data relating to criminal convictions or offences.
What lawful basis do we rely on for processing?
In order to process your personal data, we must have a lawful reason for doing so. The lawful bases that we rely on to process your personal data are described below:
Necessary for the performance of a contract
If you are a client or creator or you order a product or service from us such as merchandise, or subscription to our newsletter or emails, we will use your information to provide that product or service to you.
Consent
In some cases, we rely on your specific consent to process your personal data. This applies where you will have actively agreed and ‘opted in’ for example to receive our newsletters or emails. You have the right to withdraw your consent at any time.
Compliance with laws
We may have to process and share your personal data in order to comply with our legal obligations, or to protect our rights or the rights of others. For example, we have to collect certain information from you when we collect a payment from you for tax and accounting purposes.
Legitimate interests
In some situations we rely on our legitimate business interests in order to collect and use your personal data. Before we do, we will have carefully assessed the impact of the processing on your interests, rights and freedoms. We will only undertake the processing if we are satisfied that your fundamental rights and interests do not override our legitimate interests.
We rely on Legitimate Interests for the following activities:
sending direct marketing communications about our products and services to you if we think you may be interested in them. If you do not want us to use your personal data in this way, you can tell us by checking or unchecking relevant boxes on our websites or on any form you complete to adjust your marketing preferences or by following the instructions in any marketing communication we send. Otherwise, you can contact us at dataprotection@fourthfloorcreative.co;
managing suppression and unsubscribe requests;
obtaining publicly available data regarding campaigns and creators;
analysing the use of our products and services;
using aggregated, non–personally identifiable statistical and analysis data to identify usage trends, such as your visits and activity on our sites, and to determine the effectiveness of campaigns;
personalising your experience on our sites;
identifying fraudulent behaviour and ensuring our websites and systems are secure;
make platform/channel content moderation decisions;
building and enriching profiles of users based upon, for example, product selection and online behaviour.
If you object to our reliance on Legitimate Interests for any purpose please contact us using any of the contact methods described in the “How can you contact us?” section, below.
Do we collect data on behalf of other organisations?
In specific cases, we will collect and store personal information on behalf of a client, as part of our service delivery and contractual agreement. In these instances you will have registered with our client and accepted their terms of how they use your data and for what purpose. We will only ever process your data in accordance with these terms and to the extent necessary to enable us to provide our services to the client. If you would like further information on this, please contact the relevant organisation. Alternatively, we would be happy to assist.
How is your information stored?
All of your personal data that we collect is stored securely in the EU. Your personal data may be transferred to, and stored by, our group companies and our service providers who are based outside the UK and European Economic Area (EEA), if necessary to enable us to provide our products and services to you including, for example, where necessary to fulfil your order or process your payment details.
Whenever we store or transfer your personal data to third parties outside the UK or EEA, we will comply with our legal obligations and take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this privacy policy.
We will only keep your personal data for a reasonable period of time, which is based on the purpose for which we are using it, as described above. When that purpose has been fulfilled, we will securely delete or destroy your personal data or anonymise it (so that no-one else can tell that the personal data relates to you) unless we are required to retain your personal data longer for legal, tax or accounting reasons or to defend or enforce our contractual rights. We may also retain your personal data beyond this period for our legitimate business purposes, for example, if you have opted out of marketing communications from us, we will retain limited details about you to ensure we can honour the opt-out request.
Security
Where we have given you (or where you have chosen) secure log on details which are required to access our Fourth Floor Platform or other secure platforms, you are responsible for keeping those log on details confidential. We ask you not to share them with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data when it is transmitted to us; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access to it. 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.
Do we share data with other third parties?
We do not, and will not, sell any of your personal information to any third party.
However, we do share your data with the following categories of organisation to enable us to provide our products and services:
We may disclose your personal data to any member of the Fourth Floor Group.
As noted above, we share data relating to campaign performance with our clients to enable us to fulfil our contractual obligations to them. If we are managing an event or competition on behalf of a client, we will also provide them with the contact details of all attendees or competition entrants.
Professional service providers, such as the ecommerce platform for online stores, Shopify, to power our online shop, who help us deliver our products and services. They will have access to your personal information if necessary to perform their function but they cannot use it or disclose it for any other purpose unless you have specifically given them consent to do so.
Companies approved by you such as social media sites, when you decide to link your accounts to us, and other marketplaces, such as payment services like PayPal. In these instances, you are accepting their terms of how they use the data and for what purpose. We will only ever process your data in accordance with these terms. If you would like further information on this, please contact the relevant organisation. Alternatively, we would be happy to assist.
When a competition is being managed by Fourth Floor but fulfilled by a third party, your information will be shared if you are a winner so that we can ensure, as a winner, receive your prize. In this circumstance, they will have access to your personal information but they cannot use it or disclose it for any other purpose unless you have specifically given them consent to do so.
Website analytics service providers, such as Google Analytics, collect information about you by cookies and similar technologies which are placed on our websites and online stores. For more information on what information is collected and how it is used, please see our cookies policy.
In the event that we sell our business or any part of our business or assets, we may disclose your personal data to the prospective buyer of such business or assets.
To law enforcement agencies if we are under a legal duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or to protect the rights, property or safety of ourselves, our customers and clients and others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
What rights and options do you have?
You have certain rights in relation to your personal data, as described below:
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. You will not have to pay a fee to access your personal data, though we reserve the right to charge a reasonable fee in line with data protection laws in certain circumstances;
The right to 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.
The right to request erasure of your personal data. This enables you to ask us to delete your personal data when we no longer need it. We may however not be able to comply with your request of erasure, for example, if we are required to retain your personal data for legal reasons. We will let you know if this is the case.
The right to restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data, for example if you want us to establish its accuracy or the reason for processing it.
The right to data portability. This enables you to request the transfer of your personal data to another party.
The right to object to processing of your personal data where we are processing your personal data for direct marketing purposes.
The right to withdraw consent at any time where we are relying on consent to process your personal data (for example, for marketing purposes). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
We will respond to all legitimate requests within a 30-day period. The response time may be extended for a further two months, if required.
How can you contact us?
If you would like to contact us in relation to what data we hold and for what purpose outlined in ‘What rights and options do you have?’ or to make a complaint, please email us at dataprotection@fourthfloorcreative.co or at the following address:
Data Protection Officer
Fourth Floor Creative
King William House
13 Queen Square
Bristol BS1 4NT
Changes to this privacy policy
We may update this privacy policy from time to time. Any updated versions will be posted on this page. We request that you check this privacy policy from time to time to keep up to date with any changes. We will notify you of any changes where required by law to do so.
Your right to complain
If you have any concerns about our use of your personal data, please contact us using any of the means set out in the “How can you contact us?” section above.
You may also complain to the UK Information Commissioner’s Officer (‘ICO’) if you are unhappy with how we have used your personal data. The ICO’s contact details can be found through their website here: https://www.ico.org.uk. If you are based outside the UK, you may complain to your local data protection regulator.
Privacy Policy v6.0 | Last reviewed: [July 2023]