Privacy Policy

Effective Date: 19 July 2026

 

This Privacy Policy explains how the Global 4-Domain Communication Skills Rating Tool™ (the 'Tool') collects, uses, stores, and protects your personal data. We are committed to safeguarding your privacy and handling your information in a fair, transparent, and responsible manner.


1. Data Controller

Global 4-Domain Communications Limited, trading as Global 4D Comms Ltd, Company No. 17130328, of 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom, is the Data Controller for personal data processed in connection with the Global 4-Domain Communication Skills Rating Tool™. Privacy enquiries may be directed to [email protected].

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2. Information We Collect

We may collect the following types of information when you use the Tool:

• Personal information such as your name, email address, job role, or organisation (if applicable).

• Assessment responses and feedback provided during the completion of the Tool.

• Optional 360-degree feedback provided by peers, colleagues, or managers.

• Technical data such as device type, browser, IP address, and usage statistics for system performance and security.


3. How We Use Your Information

Your information is used for the following purposes. The specific legal basis under UK GDPR relied upon for each purpose is identified alongside it:

• To generate your personalised assessment report, including results and development insights 

Legal basis: Performance of a contract (where you are using the Tool under an institutional or individual licence), or legitimate interests where no direct contractual relationship exists with the individual participant

• To provide organisations with aggregated insights where applicable

Legal basis: Legitimate interests of the Controller in supporting organisational development, balanced against data subjects’ interests. Note: aggregated data is not attributable to individual participants

• To improve the accuracy, reliability, and effectiveness of the Tool. 

Legal basis: Legitimate interests of the Controller in maintaining and developing the platform

• To support benchmarking and research, using anonymised and aggregated data only

Legal basis: Legitimate interests. This processing uses only anonymised data and does not identify individual data subjects

• To communicate with you regarding updates, improvements, or support related to the Tool

Legal basis: Legitimate interests (for service-related communications), or consent where required for any marketing communications


4. Legal Basis for Processing (UK GDPR)

The specific legal basis applicable to each processing activity is identified in Section 3 above. The legal bases that may apply, depending on the nature of the processing and your relationship with the Tool, are:

• Consent, where required

• Performance of a contract

• Compliance with legal obligations

• Legitimate interests of the Controller, where those interests are not overridden by your rights and interests


5. Data Confidentiality

• Your assessment responses are confidential and are not shared with unauthorised third parties, except where legally required.

• For corporate clients, reports may be shared with the organisation’s authorised representatives in line with agreed processes.

• Feedback data (e.g., 360-degree responses) is always anonymised in reporting to protect the identity of respondents.


6. Data Storage and Retention

• Data is stored securely using industry-standard safeguards to prevent unauthorised access or misuse.

• Data is retained for as long as necessary for the Tool’s operation or as required by law. For corporate clients, data may be retained in accordance with contractual obligations.

• Users may request deletion of their personal data at any time, subject to applicable legal and contractual obligations.


7. Data Sharing

We do not sell, rent, or trade your personal data for marketing or commercial purposes.

Data may be shared only in the following circumstances:

• With service providers who support the secure operation and delivery of the Tool (e.g., hosting providers), under strict confidentiality agreements.

• With your organisation (if applicable) to provide aggregated results or reports in line with agreed terms.

• Where disclosure is required by law, regulation, or legal process.


8. International Data Transfers

Personal data processed through the Tool is hosted on servers located in Germany, within the UK/European Economic Area adequacy zone. No restricted transfer of personal data is made in connection with the primary delivery of the Tool.

Where sub-processors operate outside the UK/EEA, data is transferred only under appropriate safeguards. Google LLC (Google Workspace), which processes transactional email notifications on our behalf, is based in the United States. Transfers to Google LLC are made under Standard Contractual Clauses approved by the European Commission and the UK International Data Transfer Addendum issued by the Information Commissioner's Office. A list of our sub-processors, including their countries of operation and applicable transfer mechanisms, is published on our Sub-Processors page.


9. Your Rights

Depending on your jurisdiction, you may have rights under data protection law, including the right to:

• Access the personal data we hold about you.

• Request correction of inaccurate or incomplete data.

• Request deletion of your personal data.

• Restrict or object to certain processing activities.

• Request transfer of your data to another provider (data portability).

• Withdraw consent, where processing is based on consent.

If you believe your data protection rights have been infringed, you have the right to complain to your local supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO). In Nigeria, the relevant authority is the Nigeria Data Protection Commission (NDPC). For users outside these jurisdictions, please contact your local supervisory authority.

You may exercise any of these rights by submitting a Data Rights Request via [email protected] or by using the Data Rights Request link in the footer of our website and assessment portal.


10. Children’s Data

The Tool is not intended for individuals under 18. We do not knowingly collect personal data from children.


11. Security

We use reasonable administrative, technical, and physical safeguards to protect your information from unauthorised access, alteration, or disclosure. However, no system can be guaranteed 100% secure. Users are responsible for maintaining the confidentiality of their login credentials (if applicable).

We regularly review and update our security measures to maintain industry best practices.


12. CCPA Statement (California Residents)

This section applies to California residents whose use of the Tool is subject to the California Consumer Privacy Act (CCPA). In compliance with the CCPA, we confirm that:

• We do not sell, rent, or share personal information for commercial gain.

• California residents may exercise their rights to access, delete, or restrict processing of their personal information by contacting us at [email protected].

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13. Global Compliance

We comply with applicable data protection laws in the jurisdictions where we operate, including the UK GDPR, the Data Protection Act 2018, Nigeria’s NDPA, the California Consumer Privacy Act (CCPA), and, where applicable, similar privacy frameworks in other jurisdictions.

Global 4-Domain Communications Limited is registered with the Information Commissioner’s Office (ICO) under registration reference ZC189239.     


14. Changes to This Policy

This Privacy Policy may be updated from time to time. Any changes will be published on this page, with the effective date revised accordingly. Continued use of the Tool after updates constitutes acceptance of the revised Policy.


15. Governing Law

This Policy shall be governed by and construed in accordance with the laws of England and Wales, and, where applicable, the laws of the Federal Republic of Nigeria.


16. Contact Information

If you have questions about this Privacy Policy or how your data is handled, please contact us at [email protected].

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