Introduction

This Privacy Policy explains how Era4 Limited (trading as Era4) ("we", "us", "our"), a company incorporated in England and Wales (company number 16536112) whose registered office is at The Black And White Building, 74 Rivington Street, London, England, EC2A 3AY, processes personal data when we act as a data controller. It applies to our public website, marketing activities and related business development activities (together, the “Services” for the purposes of this Policy).

Where we process personal data on behalf of customers as a data processor, such processing is governed by the relevant contractual arrangements and data processing terms.

Separate privacy notices apply to Candidates, Employees, and Workers.

This Policy applies to personal data relating to:

• Visitors to our website at https://era4.com and any related digital platforms that link to this Policy and any related digital platforms that link to this Policy

• Prospective and existing customers

• Suppliers, partners, and professional advisers

• Representatives, employees, and contractors of organisations with whom we engage

Carbon3.ai is a UK AI infrastructure provider supporting organisations in deploying secure, enterprise grade artificial intelligence solutions. In the course of operating our business and delivering our services, we process personal data in a professional and commercial context.

We are committed to handling personal data responsibly, transparently, and securely, and in compliance with applicable data protection laws. This includes the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and, where relevant, the EU General Data Protection Regulation (EU GDPR), together with other applicable data protection legislation in jurisdictions in which we operate.

If you have questions about this Policy or our data practices, you may contact us at legal@era4.com.

Personal Data We Collect

Personal information you disclose to us
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we may collect:

• Name

• Business email address

• Business telephone number

• Job title and employer

• Communication preferences

• Account credentials or authentication data

• Information contained in correspondence, enquiries, meeting notes, contracts, or support requests

We do not intentionally collect special category personal data under this Notice. Please do not provide such information unless specifically requested.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Meeting Recordings and Transcripts

We may record or transcribe meetings conducted via Microsoft Teams where there is a legitimate business purpose for doing so. If a meeting is being recorded, all participants will be notified automatically at the start of the session and must actively consent before participating. Recordings and transcripts are stored securely within our company-managed Microsoft 365 environment and are not shared with third-party platforms. We retain recordings for up to 120 days, after which they are deleted automatically unless a longer retention period is required for legal, regulatory, or contractual reasons. Access to recordings is restricted to authorised personnel and download is disabled by default.

Information automatically collected
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookies Policy.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected from third party sources
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

How We Process Personal Data

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.

• To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more. For more information see our Cookies Policy.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

Legal Basis For Processing

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. 

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

  • Send users information about special offers and discounts on our products and services

  • Develop and display personalised and relevant advertising content for our users

  • Analyse how our Services are used so we can improve them to engage and retain users

  • Support our marketing activities

  • Understand how our users use our products and services so we can improve user experience

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

Disclosure of Personal Data

We may disclose personal data to carefully selected third parties where this is necessary to operate our business, deliver our services, or comply with legal obligations.

Service Providers and Professional Advisers
We engage third party vendors, contractors, consultants, and service providers to perform services on our behalf. Where these providers require access to personal data in order to deliver their services, such access is limited to what is necessary and subject to appropriate contractual safeguards.

All such third parties are required to:

• Process personal data only on our documented instructions

• Implement appropriate technical and organisational security measures

• Maintain confidentiality

• Not disclose personal data to other organisations without authorisation

• Retain personal data only for the period specified by us

• We maintain written agreements with these providers to ensure compliance with applicable data protection laws.

Categories of Third Parties
Depending on the nature of our relationship and services provided, we may share personal data with the following categories of third parties:

• Data analytics providers

• Cloud hosting and data storage providers

• Infrastructure and performance monitoring providers

• Customer relationship management and sales platforms

• Marketing automation and retargeting platforms

• Professional networking and social media platforms

• Professional advisers, including legal, audit, and compliance advisers

We do not sell personal data to third parties.

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

Cookies And Similar Tracking Technologies

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookies Policy.

Google Analytics
We may share your information with Google Analytics to track and analyse the use of the Services. The Google Analytics Advertising Features that we may use include:

Remarketing with Google Analytics and Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page. 

Artificial Intelligence Services

As part of our business operations, we use artificial intelligence (AI), machine learning, and similar technologies to support and improve how we work. This section explains how AI is used in the context of personal data we hold about our business contacts and customers.

How We Use AI

We may use AI-powered tools for the following purposes:

• Marketing: to support and enhance our marketing activities, including personalising communications, automating responses, and assisting in the creation of proposals and other materials

• Sales support: to analyse engagement, score leads, and assist our sales team in identifying opportunities and tailoring communications

• Customer service:  to assist our customer service team with routing enquiries, suggesting responses, and managing support interactions more efficiently

• Website and communications analytics: to analyse how business contacts interact with our website and communications in order to improve their relevance and effectiveness

• Security and fraud prevention: to monitor and protect our systems and infrastructure from threats, unauthorised access, and suspicious activity

• Operational efficiency: to support internal processes such as reporting, data analysis, and service monitoring

Third-Party Tools

We use trusted third-party platforms and tools to deliver some of these AI-powered functions. Any third parties processing personal data on our behalf are required to do so only on our instructions and in accordance with applicable data protection law.

Questions

If you have any questions about how AI is used in relation to your personal data, please contact us at legal@era4.com 

Retention of Personal Data

We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, including to meet our contractual, legal, regulatory, tax, accounting, and reporting obligations.

Retention periods are determined by reference to the nature of the data, the purpose for which it is processed, applicable legal requirements, and our legitimate business needs.

Where there is no longer a lawful basis or legitimate business purpose for processing personal data, we will securely delete or irreversibly anonymise it. If deletion is not immediately feasible, for example where data is contained within secure backup systems, the data will be securely stored and isolated from further processing until permanent deletion can be carried out in accordance with our retention procedures.

Security of Personal Data

We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure. These measures are proportionate to the nature, scope, context, and purposes of the processing, and the risks posed to individuals.

While we maintain safeguards intended to secure personal data, no method of transmission over the internet or electronic storage system can be guaranteed to be completely secure. Accordingly, we cannot warrant or guarantee absolute security.

Where personal data is transmitted electronically, this is undertaken at the sender’s own risk. Individuals should ensure that they access our Services using secure systems and networks.

Children

Our Services are intended for business use and are not directed at individuals under the age of 18.

We do not knowingly collect or process personal data relating to children under 18 years of age. We do not knowingly market to children or sell personal data.

If we become aware that personal data relating to a person under 18 has been collected inadvertently, we will take reasonable steps to delete that information promptly.

If you believe that we may have collected personal data from or about a child under 18, please contact us at legal@era4.com so that we can investigate and take appropriate action.so that we can investigate and take appropriate action.

Overseas disclosure

We store personal data primarily in the United Kingdom. However, where we disclose personal data to third parties, that data may be transferred to, stored in, or accessed from countries outside the United Kingdom, including the EU and United States.

Where personal data is transferred outside the UK, we ensure that appropriate safeguards are in place in accordance with UK data protection laws. This includes reliance on the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or other lawful transfer mechanisms, as well as contractual protections requiring recipients to protect personal data to UK standards.

Your Data Protection Rights

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the Contact Section below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the Contact Section below. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookies Policy.

Do Not Track Signals

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

Changes to This Policy

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

Contact Section

If you have questions or comments about this notice, or if you would like to exercise your rights, you may contact us at legal@era4.com