4D Life Limited
Privacy and Cookies Policy
1.1. We are committed to safeguarding the privacy of our website visitors and customers.
1.2. This notice describes our processing of personal data we obtain about:
visitors to our www.4DLife.org website
individual customers (members)
For the purposes of UK and EU data protection law, we are the ‘controller’ of this personal
data (meaning that we determine why and how it is processed).
1.4. In this policy, “we”, “us” and “our” refer to 4D Life Ltd. For more information about us, see Section 19.
2. The personal data that we collect
2.1. In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2. We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, telephone number and/or postal address. The source of the contact data is you.
2.3. We may process your website user account data (“account data”). The account data may include your account identifier, name, address, telephone number, email address, account creation and modification dates and website settings. The primary source of the account data is you, although some elements of the account data may be generated by our website.
2.4. We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
2.5. We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication such as the date and time of sending.
2.6. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
2.7. We may process information collected in connection with any marketing subscription or opt-out request (“marketing data”), such as email addresses and marketing preferences.
2.8. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Purposes of processing and legal bases
3.1. In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2. Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3. Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and customers, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
3.4. Direct marketing – We may process contact data, account data, marketing data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email and/or post. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users (Members).
3.5. Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.6. Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.7. Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.8. Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.9. Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.10. Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
3.11. Using personal data for marketing purposes. We send occasional emails containing information about our business and services to the following categories of people :
individual customers who have previously bought our services
- people who have subscribed to receive our newsletter or other marketing communications
- If you receive such communications from us and do not wish to, you can tell us by using the
- unsubscribe link in any email we send to you or emailing info@4DLife.org.
4. Sensitive personal data that we collect
4.1. The sensitive personal data, also referred to as “special category personal data” is personal data that is deemed to be more sensitive than the personal data as described above and includes data concerning health. By the very nature of the service we provide and the fact that you have registered for our 4D Life Programme, we can deduce that either you have a certain health condition, or you are acting on behalf of someone who is.
4.2. By submitting your membership registration form you self-allocate to which programme you want to sign up to. Also, before joining the programme you will be asked to complete a self-assessment questionnaire which contains questions about your health. The source of the special category personal data is you. The legal basis for this processing is your explicit consent.
5. Providing your personal data to others
5.1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
5.2. We may disclose your personal data to organisations or individuals engaged by us in the course of providing our services: such as individual consultants or their personal service companies who provide software/website programming/development services or assist with providing support and maintenance services to our customers.
5.3. We use a number of service providers in connection with our website, services, communications and IT infrastructure, which involves those service providers processing some of the personal data described in this notice to the extent necessary to provide the relevant services. We currently use the following providers:
Nature of services : Website development and maintenance
Type of data processed : Contact data, account data, transaction data, communication data and usage data.
Linode LLC https://www.linode.com/
Nature of services : Website hosting
Type of data processed : Contact data, order data, usage data
Nature of services : Email communication system service
Type of data processed : Outbound email data containing recipients email address
Nature of services : Identity and account management services
Type of data processed : Account data, contact data.
Nature of services : payment services
Type of data processed : Transaction data, contact data, usage data
Nature of services : Video streaming platform
Type of data processed : Usage data (IP address)
Nature of services : Web fonts
Type of data processed : Usage data (IP address)
Nature of services : Bank
Type of data processed : Transaction data
5.4. In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. International transfers of your personal data
6.1. In this Section 6, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).
6.2. We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
6.3. The hosting facilities for our website are situated in United Kingdom.
6.4. We transfer some personal data to the service providers described in the ‘Providing your personal data to others’ section above that are based in countries outside the UK. Below we describe these transfers and the safeguards in place to protect personal data once it has been transferred.
Third country (non-UK)/international organisation
Safeguards in place to protect your personal data
Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.
Retrieve a copy of the safeguards in place here:
For more information please contact us at: info@4DLife.org
7. Retaining and deleting personal data
7.1. This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3. We will retain your personal data as follows:
(a) contact data will be retained for a period of 1 year following the date of the most recent contact between you and us but if the contact relates to a customer contract or our customer (member) we store that contact data for 6 years after the relevant customer contract has terminated.
(b) account data will be retained for a period of 6 months following the date of closure of the relevant account;
(c) transaction data will be retained for a period of 18 months following the date of the transaction;
(d) communication data will be retained for a period of 1 year following the date of the communication in question, but if the communication relates to a customer contract we store the communication for 6 years after termination of the customer contract to which the communication relates;
(e) usage data will be retained for a period of 12 months period following the date of collection;
(f) special category data will be retained for a period of 6 years after the customer contract to which this data relates to has terminated; and
(g) marketing data: we will continue to use this data until we receive an opt-out request, after which time we will retain the email address and marketing preference information to ensure that we do not send marketing to the unsubscribed email address.
7.4. Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Security of personal data
8.1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
8.2. We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
8.3. Passwords will be stored by us in encrypted form.
8.4. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
8.5. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.6. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
9. Your rights
9.1. In this Section 9, we have listed the rights that you have under data protection law.
9.2. Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
9.3. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
9.4. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
10. Third party websites
10.1. Our website includes hyperlinks to, and details of, third party websites.
10.2. In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Personal data of children
11.1. Our website and services are targeted at persons over the age of 18.
11.2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12. Updating information
12.1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. About cookies
13.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3. Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
14. Cookies that we use
(a) suitability confirm to record whether you have viewed and accepted our suitability assessment checklist.
(b) suitability hash to record your acceptance choice against your order for future queries.
(c) woocommerce cart_hash, woocommerce_items_in_cart, wp_woocommerce_session_ to provide ecommerce functionality such as checkout.
(e) to deliver your content on my.4dlife.org.
15. Cookies used by our service providers
|Cookie name||Default expiration time||Description|
||2 years||Used to distinguish users.|
||24 hours||Used to distinguish users.|
||2 years||Used to persist session state.|
Contains campaign related information. If you have
linked your Google Analytics and Google Ads accounts, Google Ads
website conversion tags will read this cookie unless you opt-out.
16. Managing cookies
16.1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
16.2. Blocking all cookies will have a negative impact upon the usability of many websites.
16.3. If you block cookies, you will not be able to use all the features on our website.
17. Cookie preferences
18.1. We may update this policy from time to time by publishing a new version on our website.
18.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
19. Our details
19.1. This website is owned and operated by 4D Life Ltd.
19.2. We are registered in England and Wales under registration number 12313488, and our registered office is at 20 Mortlake Business Centre, Mortlake High Street, London, England, SW14 8JN.
19.3. Our principal place of business is at 20 Mortlake Business Centre, Mortlake High Street, London, England, SW14 8JN.
19.4. You can contact us:
(a) by post, to the postal address given above;
(b) by telephone, on the contact number published on our website; or
(c) by email, using the email address published on our website.
20. Data protection registration
20.1. We are registered as a data controller with the UK Information Commissioner’s Office.
20.2. Our data protection registration number is ZB076213.