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C4S Global Privacy Notice

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Data processing covered from: 20 August 2025

The latest version will be published on the C4S website and the date at the top of the notice will be updated.

Last updated: 20 August 2026

We may update this notice when our services, systems or legal responsibilities change.

1. Who we are

20. Changes to this notice

C4S GLOBAL, UNIPESSOAL LDA is an executive development, communication and coaching business registered in Portugal.

Website: www.cnpd.pt

Company number: 517613492

Portugal

Registered address: Rua Estamparia de Lavadores, No. 1481, 1 F, 4400 455 Vila Nova de Gaia, Portugal

1200 651 Lisboa

Website: www.c4sglobal.com

Av. D. Carlos I, 134, 1º

Email: admin@c4sglobal.com

Comissão Nacional de Proteção de Dados

For the purposes of the General Data Protection Regulation, C4S GLOBAL, UNIPESSOAL LDA is the data controller when we decide why and how personal data is processed.

You also have the right to submit a complaint to:

In some client engagements, C4S processes participant information on behalf of a client organisation. In those situations, the client may be the data controller and C4S acts as a data processor under the client’s instructions.

If you are concerned about how C4S has handled your personal information, please contact us first at admin@c4sglobal.com.

2. Who this notice applies to

19. Complaints

This notice applies to:

If we become aware of a personal data incident, we will investigate it, take steps to limit the impact and notify affected clients, individuals or regulators where required by law.

1. Visitors to the C4S website
2. People who contact us or submit an enquiry
3. Prospective and current clients
4. Participants in C4S programmes, workshops, coaching and events
5. Members of the C4S Circle community
6. People completing C4S assessments, scorecards or application forms
7. Associates, coaches, facilitators, suppliers and business partners

18. Data incidents

3. What personal information we collect

We do not knowingly collect personal information from children under 18 through our website or normal programme activity.

Depending on how you interact with C4S, we may collect:

C4S services are designed for professionals and business clients.

1. Your name, email address, telephone number and location
2. Your job title, employer, professional responsibilities and business contact details
3. Information you provide through website forms, enquiries, applications, assessments or event registrations
4. Information connected to programme enrolment, attendance, participation and completion
5. Your programme goals, development priorities and feedback
6. Presentation recordings created during a C4S programme
7. Brief coaching or development notes where these are required to support an engagement
8. Information you choose to share within the C4S Circle community
9. Email correspondence and records of our communication with you
10. Commercial information connected to proposals, contracts, invoices and payments
11. Website information such as your IP address, browser type, device information, pages visited and form activity
12. Marketing preferences, including whether you have agreed to receive communication from us

17. Children

We do not intentionally collect sensitive personal information as part of our normal services. If you voluntarily share health information or another type of sensitive information during coaching or programme delivery, we will only use it where necessary, appropriate and legally permitted.

Assessments or scorecards may calculate results or provide recommendations. These are development tools and are not used to make automated employment decisions.

4. How we collect your information

C4S does not use personal information to make decisions based solely on automated processing that produce legal or similarly significant effects.

We may collect personal information:

16. Automated decision making

1. Directly from you
2. From your employer, programme sponsor or client organisation
3. Through the C4S website
4. Through assessments, application forms and registration forms
5. Through email, meetings, coaching sessions and programme delivery
6. Through Circle or another approved programme platform
7. Through professional sources such as a company website or LinkedIn
8. Automatically through website technology, cookies and security logs

To exercise your rights, contact admin@c4sglobal.com.

Where a client provides participant information, the client is responsible for ensuring that it has a lawful basis for providing that information to C4S.

We aim to respond within one month. In complex cases, the law may allow additional time. If this happens, we will explain why.

5. Why we use your information

We may need to verify your identity before responding to a request.

We use personal information to:

1. Ask what personal information we hold about you
2. Request a copy of your personal information
3. Correct inaccurate or incomplete information
4. Ask us to delete your information
5. Ask us to restrict how your information is used
6. Object to processing based on legitimate interests
7. Object to direct marketing
8. Receive certain information in a portable format
9. Withdraw consent where processing is based on consent
10. Raise a concern with a data protection authority

1. Respond to enquiries and prepare proposals
2. Manage our relationship with clients and prospective clients
3. Register participants and deliver programmes, workshops, coaching and events
4. Provide access to programme materials and the C4S Circle community
5. Support learning, feedback, practice and development
6. Schedule meetings, coaching sessions and programme activity
7. Measure attendance, engagement, completion and agreed programme outcomes
8. Improve our programmes, services and participant experience
9. Send relevant information about C4S programmes, events and services
10. Manage contracts, invoices, payments and financial records
11. Protect our systems, website, participants and business
12. Meet our legal, regulatory and contractual responsibilities

Subject to the circumstances and applicable law, you may have the right to:

6. Our legal basis for using your information

15. Your data protection rights

We only process personal information where we have a lawful basis.

External websites and platforms linked from the C4S website operate under their own privacy and cookie notices.

Depending on the situation, this may include:

You can control cookies through your browser settings and, where available, through the cookie preference tool displayed on the website.

1. Contract

Where consent is legally required for analytics, preference or marketing cookies, these cookies should only be activated after you have made your choice.

Processing is necessary to deliver a service you have requested or to take steps before entering into a contract.

Some cookies are necessary for the website to function.

2. Legitimate interests

The C4S website may use cookies and similar technology to operate the website, protect forms, understand website use and improve performance.

Processing is necessary to operate C4S, manage client relationships, deliver effective programmes, maintain accurate records, improve our services and protect our business.

14. Cookies and website technology

We consider the impact on your rights before relying on legitimate interests.

We will not sell your information or provide it to another organisation for its independent marketing.

3. Consent

1. Using the unsubscribe option in the communicationother sensitive information during coaching or programme delivery, we will use it only where necessary, appropriate,
2. Emailing admin@c4sglobal.com

We may rely on your consent for certain marketing activity, optional recordings, testimonials, photographs or other uses where consent is appropriate.

You can unsubscribe at any time by:

You can withdraw your consent at any time.

We may contact you about relevant C4S programmes, events, insights or services where you have provided consent or where we have another lawful basis.

4. Legal obligation

13. Marketing communication

Processing is necessary to meet accounting, tax, regulatory or other legal requirements.

We may retain anonymised information that can no longer identify an individual.

7. Programme recordings

1. Enquiry and prospective client information: up to 24 months after the last meaningful contact
2. Participant administration and programme records: normally 12 months after programme completion
3. Routine programme recordings: normally deleted within 30 days after the programme
4. Routine coaching notes: normally deleted within 90 days after the engagement
5. Circle membership information: retained while access is active and normally deleted or anonymised within 30 days after the agreed access period ends
6. Contracts, invoices and financial records: retained for the period required by Portuguese law
7. Information connected to a complaint, dispute or legal claim: retained for as long as reasonably necessary to resolve the matter

Some C4S programmes involve recording participants while they practise presentations or communication skills.

Our normal retention periods are:

Participants will be informed before recording takes place.

We only keep personal information for as long as necessary.

Recordings are used for playback, feedback and learning. They are not used for public marketing without separate permission.

12. How long we keep information

Routine programme recordings are normally deleted within 30 days after the programme unless a different period has been agreed with the participant or client.

No method of electronic storage or transmission is completely risk free. However, we take reasonable steps to prevent unauthorised access, loss, misuse, alteration or disclosure.

Recordings will not normally be shared with a participant’s employer, manager or programme sponsor unless this has been clearly agreed and participants have been informed.

We use proportionate security measures including access controls, individual accounts, secure passwords, multifactor authentication where supported, device security, current software updates, malware protection, secure deletion and incident response procedures.

8. Coaching and development information

Access is limited to people who need the information for their role.

Coaching notes are kept brief, factual and limited to what is necessary to support the engagement.

Personal information is stored within approved business systems and, where necessary, on two dedicated business computers controlled by the C4S founders.

Private coaching content will not normally be shared with an employer or programme sponsor. We may provide agreed information about attendance, programme participation or overall themes, but we will not disclose private coaching discussions unless:

C4S does not operate a private company server.

1. You have agreed to the disclosure
2. We are legally required to disclose the information
3. There is a serious and immediate concern involving safety or unlawful conduct

Our main business systems currently include:

11. Where information is stored and how it is protected

1. Webflow for website hosting and website forms
2. Google Workspace for email, calendars, documents and business administration
3. Zoho Bigin for client, prospect and programme relationship records
4. Circle for community access, programme support and learning activity
5. ScoreApp for assessments and scorecards where these are used

Routine coaching notes are normally deleted within 90 days after the engagement ends unless a longer period is required by contract or law.

1. The client organisation funding or organising a programme
2. C4S founders, approved associates, coaches and facilitators who need the information to perform their role
3. Website, email, customer relationship management, community and technology providers
4. Assessment, meeting, recording and event platforms
5. Payment, accounting and professional service providers
6. Regulators, courts, law enforcement bodies or public authorities where disclosure is legally required

Where personal information is transferred internationally, we use appropriate safeguards. These may include an adequacy decision, European Commission approved Standard Contractual Clauses or another legally recognised transfer mechanism.

We require service providers and associates to protect personal information and use it only for the agreed purpose.

9. Who we share information with

We may share limited personal information with:

Some of our technology providers or their subprocessors may process information outside Portugal or the European Economic Area.

10. International data transfers

We do not sell personal information.