Privacy Policy

While using our services (hereinafter referred to jointly as the “Services” or “4Element Services” and separately as the “Service”) i.e. the services of 4Element (hereinafter “4Element”) and all its affiliated and subsidiary entities, both through personal and equity links, directly or through any other entities (hereinafter “Subsidiaries ”), you provide us with your personal data. While using the specific Services, you can also provide your personal data to our trusted partners i.e. any third parties operating within the range of our Services, with which we cooperate directly or indirectly, primarily to provide you with the Services of the highest quality, as well as the third parties performing the marketing activities (hereinafter “Trusted Partners”), including the clients (hereinafter “Clients”) that is the entities that directly or indirectly commission the performance of marketing activities (including among others mailing campaign or online advertising on the 4Element website)

The privacy policy will help you to understand what types of data we collect, for what purpose and to what exactly we are using them. This information is of key importance to us and therefore we ask you to read this document carefully.

What data we process

We process data you provide us or leave behind when using the 4Element Services. These include primarily any data necessary to provide access to the accounts or profiles in the Services, e.g. email address, you provide us e.g. when filling the forms or windows available in our Services, as well as data you leave behind when surfing on our Services that is among other these you leave behind in so called cookies. We also process data you place in the Services made available by us under so called “hosting” – in such case our data processing is limited only to providing access to any virtual space in which you place these data. The scope of data processed by the specific 4Element Services vary – you can always find the applicable information in a panel linked to the specific 4Element Service – or send a query to our Data Protection Officer (contact details below).

Who is the controller?

Your data controllers are the entities belonging to MOLY LTD. In addition, in view of the underlying legislation, also the Trusted Partners, including the Clients, can act as the controllers of your data with regard to the specific Services.

The List of Trusted Partners is provided below. Please note that in some cases, e.g. when no direct relation with certain Trusted Partners exists – in particular in the case of the Partners being so called Clients – when such entities commission online advertising on our websites by the agency of the Trusted Partner being e.g. an advertising network, we are not able – due to objective reasons – provide their names on the list. If you need more information, please contact our Data Protection Officer (contact details below).

Trusted Partners:

Google Inc. with its registered seat in Mountain View, California, United States of America.
In order to learn more about the privacy policy of this controller, click here:
Facebook Inc. with its registered seat in Menlo Park, California, United States of America
In order to learn more about the privacy policy of this controller, click here:

Data Protection Officer and its contact details:

We have designated the Data Protection Officer for 4Element. You can contact this person in any and all issues related to personal data processing and exercising the rights linked to processing. If you want to contact the Data Protection Officer, please use contact details provided below:

Correspondence Address:

MOLY LTD, Flat 202, Sanctuary Court Reardon Path, London E1W 2PP


What are the purposes and legal bases for processing of your personal data and for what is the time period of their processing?

Legal bases for processing of your data for specific purposes are as follows:

Purposes of data processing:
Performance of the contract between 4Element – user (these contracts are usually the rules and regulations to be accepted by the User before making use of a given Service), including providing the Services for the Users and tailor the Services to the Users’ needs, their analysing and improving and ensuring their security (hereinafter “performance of Services”)
Statistical surveys (hereinafter “statistics”)
Marketing (including the controller’s data analysing and profiling for marketing purposes) of the controller’s products and services (hereinafter also “own marketing”).
Marketing (including the data analysing and profiling for marketing purposes) of products and services of third parties (hereinafter also the “third-party marketing”).

Legal bases:
Article 6(1)(b) of the GDPR – necessary for performance of a contract to which the User (data subject) is party
Article 6(1)(f) of the GDPR – legitimate interest of the controller.
Article 6(1)(a) – voluntary consent

Processing period:
Until the expiry of the given contract between you and 4Element, provided that in some cases these data can be also stored upon the expiry of the contract, however only when permitted or required in view of the underlying legislation e.g. processing for statistical or settlement purposes or when seeking damages
until the effective objection is raised
until the consent is withdrawn

Is there a requirement to provide data?

Personal data are provided on voluntary basis, however any failure to provide data marked as necessary to provide you with the services shall preventing the provision of such services.

What recipients will receive your personal data?

Your data can be transferred to the processors on request of the controller to, among others, the IT service providers, marketing agencies etc. – provided that such entities process data under the contract made with the controller and only and exclusively following the controller’s instructions. Your data can be also provided to the authorities entitled to acquire them under the legislation in force, e.g. to the law-enforcement authorities when the authority requests such data under the applicable legal basis (for example for the purposes of a pending criminal proceeding). In certain cases, your data can be transferred to third-country recipients i.e. to the states outside the European Economic Area, e.g. if necessary to provide you with the Service or if required by any other important legal basis. Relevant information is available within the individual Services.

What are your rights related to personal data processing?

With regard to processing of your personal data by us, you have the following rights:

If your data are processed on the basis of consent, you can additionally exercise the following rights:

If your data are processed on the basis of consent or within the provided service (data are necessary to provide the service), you can additionally exercise the following rights:

In order to exercise these rights, please contact the controller or Personal Data Officer (contact details above).

Cookies information

Cookies and other similar technologies

The entities submitting information in a form of cookie files and other similar technologies in the end device of the User (e.g. computer, laptop, smartphone or Smart TV) and obtaining access to it are the entities from the 4Element and Trusted Partners, that is e.g. the entities cooperating with 4Element, including among others the partners providing analytical services, advertisers, app developers, network advertising agencies (hereinafter referred to as the “Submitters”).

Cookies are the IT data, in particular text files, stored in end device of the User of VPM services and apps. Cookies usually contain the name of IT service domain, from which they derive, period of storage in the end device and unique number. Cookies are used neither for identification of the user, nor for determination of the user’s identity.

Publisher website can place cookies in the browser, if the browser enables to do so. Remember that the browser enables the website to access only the cookies sent by this website rather than to files placed by the other websites.

Why we use cookies

We use cookies and other technologies to:

Types of cookies we use

Due to life-span of cookies and other similar technologies, we use two essential types of these files:

With regard to the purpose of cookies and other similar technologies, we use their following types:

Other technologies

To ensure comfortable and easy use of our services, we apply the Local Storage (LS) technology which functions similarly to cookies, although has slightly different properties. LS is a separate browser memory space used for storage of data saved by the services. This space is available only to pages operating within the same website, from which data are saved, however in contrary to cookies these data are not transmitted by the browser each time the website is requested. Data in LS are stored by the browser on long-term basis and are not deleted when the browser is closed and have no defined expiration date. Please remember that we use this technology to ensure comfort of use and to provide the services of the highest quality rather to track or identify the users. We use the LS technology e.g. to save the settings, radio configuration or data on recommended entries.

Browser settings management

In many cases, software used to surf the Internet (browser) enables storage of information in the form of cookies and other similar technologies in the end device of the User by default. The User can however change these settings at any time. Failure to do so means that this information can be saved and stored in its end device and therefore that we will store information in the end device of the user and have access to this information. Managing the cookies by the User itself is available at the level of User’s browser. The most common browsers enable, among others:

Where to seek help?

Comprehensive information is available in this software (browser) settings. Detailed information for the persons using the specific browsers is available among others in:
Internet Explorer
Mozilla Firefox
We inform hereby that any limitations or exclusions of the use of cookie files and other similar technologies can affect certain functionalities available in our websites.

Additional information

Additional information on cookies and other technologies are available, among others at the following addresses:, or in the Help section of your browser.

Useful tips

Dear User, please remember that:

My data and consents

You express your consent for data collection. Thank you for your trust!
Your consent will enable use better personalisation of our content!

Consent for data collection:

I hereby express my consent for processing of my personal data collected during the use of services, including websites, services and other functionalities of 4Element*, including any data saved in the cookie files for marketing purposes (including analysing and profiling for marketing purposes) by 4Element* and Trusted Partners*.

Expressing of this consent is voluntary. You can withdraw it at any time using the tool available here, provided that the withdrawal I express my consent on voluntary basis. This withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.


Dear Guest !

In order to continue providing you with services of the highest quality, we need your consent for better tailoring of our marketing content to your preferences. Your privacy is of a great importance to us. We do not extent the scope of our rights. Your data are safe with us. You can withdraw your consent at any time on the Privacy policy subpage.