The terms, in plain sight.

01 Terms of Use

Terms of Use

These Terms of Use govern your access to and use of the website at 41streetmanagement.com (the “Site”), operated by 41st Street Inc (“41st Street”, “we”, “us”, or “our”), a company registered in Saint Christopher and Nevis with its registered office at Jessops, Jessops Estate, St Kitts and Nevis. By using the Site you agree to these terms. If you do not agree, please do not use the Site.

Who we are and what this Site is

41st Street is a social-led digital marketing company. We plan and run promotional campaigns — influencer-led and across paid social, search, and content — for our clients. This Site is an informational and marketing resource. It is not a platform through which any product or service is supplied.

No advice and no offer

Nothing on this Site is, or should be relied on as, financial, investment, banking, foreign exchange, tax, legal, or other professional advice, and nothing on this Site is an offer or solicitation to buy or sell any product or service. We do not provide any of the services associated with the sectors we serve. Those services are provided by our clients and other third parties, who are solely responsible for them.

Permitted use

We grant you a limited, non-exclusive, revocable licence to view the Site for your own lawful and non-commercial use. You agree that you will not:

• use the Site in any way that breaches any applicable law or regulation;
• copy, reproduce, republish, or redistribute any part of the Site except as permitted by these terms;
• attempt to gain unauthorised access to the Site or any server, system, or network connected to it;
• introduce any malicious code, or interfere with the proper working of the Site.

Intellectual property

All content on the Site, including text, graphics, the 41st Street name and logo, and the overall design, is owned by or licensed to 41st Street and is protected by intellectual property laws. You may not use our brand, marks, or content without our prior written permission.

Third-party links

The Site may link to third-party websites, including the social platforms on which we operate. We do not control those sites and we are not responsible for their content, policies, or practices. A link does not imply our endorsement.

Disclaimers and limitation of liability

The Site is provided on an “as is” and “as available” basis. To the fullest extent permitted by law, we exclude all warranties, express or implied, regarding the Site and its content. To the fullest extent permitted by law, we will not be liable for any indirect or consequential loss, or for any loss of profit, revenue, data, or goodwill, arising from your use of, or inability to use, the Site.

Governing law

These terms are governed by the laws of Saint Christopher and Nevis, and the courts of Saint Christopher and Nevis have exclusive jurisdiction over any dispute arising from them.

Changes to these terms

We may update these terms from time to time. The version published on the Site is the version that applies, so please review it when you visit.

02 Privacy Policy

Privacy Policy

This Privacy Policy explains how 41st Street Inc collects, uses, shares, and protects personal data. We handle personal data in line with the Data Protection Act, 2018 (Act No. 5 of 2018) of Saint Christopher and Nevis, and, where a client or campaign falls within its scope, the European Union’s General Data Protection Regulation.

Who is responsible for your data

41st Street Inc is the data controller for the personal data described in this policy. You can reach us about data protection at privacy@41streetmanagement.com or by writing to Jessops, Jessops Estate, St Kitts and Nevis.

The personal data we collect

We collect personal data in three main ways:

• Data you give us directly. When you contact us or complete a form on the Site, we collect details such as your name, company, email address, the sector you are interested in, and the contents of your message.
• Data we collect through campaigns. When we run campaigns for our clients, we may process the personal data of people who respond. This can include name, contact details, social media handle, location, and an expression of interest in a product or service.
• Technical data. When you use the Site, we may collect technical information such as your IP address, browser and device type, and how you interact with our pages, including through cookies. See our Cookie Policy.

How and why we use personal data

We use personal data to operate our digital marketing business, to respond to enquiries, to run and measure campaigns, to maintain and improve the Site, and to meet our legal and regulatory obligations. We rely on one or more of the following lawful bases: your consent, our legitimate interest in running our business responsibly, the performance of a contract, and compliance with the law.

Working with our clients

We run marketing campaigns on behalf of our clients. Depending on the campaign, we may act as a processor, handling personal data on a client’s instructions, or as a controller for data we collect directly. We do not sell personal data. Where we share personal data with a client or partner — for example, to pass on an enquiry that a person has asked us to forward — we do so only where we have a lawful basis, ordinarily the individual’s consent, and under a written agreement. Where a client receives data as its own controller, its privacy policy governs what it does with it.

Other recipients

We may also share personal data with service providers who support our operations, with the influencers and partners who run our campaigns, and with regulators, law enforcement, or advisers where we are required or permitted to do so by law.

International transfers

Our clients and service providers may be located outside Saint Christopher and Nevis. Where we transfer personal data across borders, we take steps to ensure it remains protected to a standard consistent with this policy and applicable law.

How long we keep personal data

We keep personal data only for as long as is necessary for the purposes set out in this policy, including any period required to meet legal, accounting, or reporting obligations. When data is no longer needed, we dispose of it responsibly.

How we protect personal data

We use technical and organisational measures appropriate to the sensitivity of the data and the risk of harm, and we keep those measures under review.

Your rights

Subject to applicable law, you have the right to be informed about how your personal data is processed, to access the data we hold about you, and to have inaccurate or incomplete data corrected. Where we rely on your consent, you may withdraw it at any time. Where the GDPR applies, you may also have rights to erasure, restriction, objection, and portability. To exercise any of these rights, contact us at privacy@41streetmanagement.com.

Complaints

If you have a concern about how we handle your personal data, please contact us first so we can try to resolve it. You also have the right to complain to the Office of the Information Commissioner of Saint Christopher and Nevis.

Children

Our Site and services are intended for adults. We do not knowingly collect personal data from anyone under the age of 18.

Changes to this policy

We may update this policy from time to time. The version published on the Site is the version that applies.

03 Cookie Policy

Cookie Policy

This Cookie Policy explains how 41st Street Inc uses cookies and similar technologies on the Site.

What cookies are

Cookies are small text files placed on your device when you visit a website. They help the site work, remember your preferences, and understand how the site is used.

The cookies we use

We aim to keep our use of cookies to a minimum. Where we use cookies that are not strictly necessary, we ask for your consent first through the banner shown when you arrive.

Managing cookies

You can accept or decline non-essential cookies using the banner on the Site. You can also control cookies through your browser settings, including deleting cookies already stored and blocking future cookies. If you block strictly necessary cookies, some parts of the Site may not work as intended.

Changes to this policy

We may update this Cookie Policy from time to time to reflect changes in the cookies we use.

04 Contact

How to contact us

For any question about these policies, or to exercise your data protection rights, contact us at privacy@41streetmanagement.com, or write to 41st Street Inc, Jessops, Jessops Estate, St Kitts and Nevis. For partnership enquiries, please use our contact page.