CT4 Global Data Privacy Policy

CT4 Europe (UK)
CT4 Pty Ltd (AU)
CT4 Pte Ltd (SG)
CT4 Philippines Inc. (PI)


CT4 Global Data Privacy Policy (GD-PP-2018)

Legal Basis That We Rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:



In specific situations, we can collect and process your data with your consent. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.


Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.  For example, if you order a service from us, we’ll collect your address details to provide an invoice and will require the details of nominated points of contact for us to liaise with.


Legal compliance

If the law requires us to, we may need to collect and process your data.  For example, we can pass on details of people involved in fraud or other criminal activity affecting the Partnership to law enforcement.


Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your customer history to make available personalised offers. We also combine the resource consumption levels to identify trends and ensure we can keep up with demand, or develop new products/services.



We know how much data security matters to all of our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. We secure access to all transactional areas of our apps using ‘https’ technology. Access to your personal data is password-protected and secured by SSL encryption. We do not collect sensitive data (such as payment card information).  We regularly monitor our system for possible vulnerabilities and attacks, and we carry out cyber security testing to identify ways to further strengthen security.  Further details can be found in the CT4 Privacy Policy (CT4-PP-2018).



Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected as stipulated through the Service Level Agreement. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.


Customer Data Retention Periods:


Customer Service Orders
When you place an order, we will keep the personal data you give us for seven years so we can comply with our legal and contractual obligations.


Inactive accounts

We will maintain all customer accounts as per the legal requirements detailed in the Service Level Agreement. Should a user account no longer be required then we rely on the customer to inform us so that we can remove the account and adjust the billing requirement accordingly.  If accounts lay dormant then they will be flagged as part of our routine consumption monitoring processes. We will inform the customer who can then advise us as to the required action.



We will only do this in very specific circumstances, for example:

– With your consent, given at the time you supply your personal data, we may pass that data to a third party for an extension or modification of existing services. For fraud management, we may share information about fraudulent or potentially fraudulent activity in our systems. This may include sharing data about individuals with law enforcement bodies.

– We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

– We may, from time to time, expand, reduce or sell the company and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.



Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).


Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA such as Australia, Singapore, Philippines and the US.

For example, this might be required in order to fulfil your order, process your payment details or provide support services.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. If you wish for more information about these contracts please contact our Data Protection Officer. Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.



An overview of your different rights

You have the right to request:

– Access to the personal data we hold about you, free of charge in most cases.

– The correction of your personal data when incorrect, out of date or incomplete.

– That we stop any consent-based processing of your personal data after you withdraw that consent.

– Review of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You can contact us to request to exercise these rights at any time. If we choose not to action your request we will explain to you the reasons for our refusal.


Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. Consent and withdrawal of consent should be in writing or (in the case of providing consent when using a service) by agreeing to access terms.


Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.


Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.  If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.


If your business operates outside the UK−

For all non-UK customers

By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. You still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes. Sometimes we’ll need to transfer your personal data between countries to enable us to supply the services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves in the UK. By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes. This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.



For the purposes of this Privacy Notice, ‘personal data’ means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, and whether or not the information or opinion is recorded in a material form. If you are in Australia you may submit any questions, comments or complaints to our UK-based Data Protection Officer who will come back to you within 30 days.


If you are contacting us to complain about an alleged breach of this Privacy Notice or our legal privacy obligations, please provide us with as much detail as possible in relation to your complaint.

We will take every privacy complaint seriously and assess it with the aim of resolving all issues quickly and efficiently.  We’d be grateful for your cooperation with us during this process by providing us with any relevant information that we made need.


If we have not come back to you within 30 days, or you are not happy with the response that you’ve received, you may submit a complaint to the Office of the Australian Information Commissioner.

We are committed to keeping your personal information secure and will take all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.


New Zealand

Customers and potential customers expect us to maintain their information accurately, protected against manipulation and errors, secure from theft and free from unwarranted disclosure. We protect the data security of our customers and potential customers by complying with the New Zealand Personal Data (Privacy) Ordinance determined in the Privacy Act 1993  and all relevant local laws, and ensure compliance by our staff with strict standards of security and confidentiality.



CT4 adheres to state and federal laws as required by both location and industry sector. For more information on our Data Privacy Policy (USA) please contact globalcompliance@CT4.com.



All personal data utilised by CT4  is protected under the Singapore Personal Data Protection Act. In accordance with  the act, CT4 may only collect personal data only with the consent of the individual, and the individual must be informed of the purpose for the data collection. Consent to this requirement is secured through agreement to access terms as part of the customer contract.



CT4 adheres to the Philippines data protection law by ensuring that specific and informed consent from the user is first obtained prior to collecting personal data. The purpose of the data processing is declared before collection begins (or as soon as reasonably possible after). Under the Republic Act No. 10173, individuals have the right to know our identity, what personal data we are  collecting and for what purpose, how it’s being processed, who it’s being disclosed to, and all their rights regarding their own data.



The Malaysian Personal Data Protection Act 2010 protects any personal data collected within its jurisdiction from being misused. Consent of users must be obtained before collecting their personal data or sharing it with any third parties. In order for their consent to be valid, CT4 is required to given them written notice of the purpose for the data collection , their rights to request or correct their data, what class of third parties will have access to their data and whether or not they are required to share their data and the consequences if the decide not to.


Any questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it. If you have any questions relating to this issue please contact our DPO through the Global Compliance Team using our email address: globalcompliance@CT4.com