Privacy Statement and Data Processing Principles
Our Privacy Statement governs any kind of processing where we are acting as a data controller or co-controller (including collection, use, transfer, storage and deletion) of personally identifiable information (any information that may be used to identify a physical person, and any other information associated therewith) about natural persons. This statement applies to our processing of data collected through any means, actively as well as passively, from persons located anywhere in the world.
The Growth Chain is responsible for collecting, processing, storing, and safe-keeping personal and other information as part of providing a service and carrying out our regular business activities. We manage personal information in accordance with the Data Protection Act and General Data Protection Regulations and we are registered as a Data Controller with the Information Commissioner’s Office Registration Number 00017038288
Any questions regarding our processing of personal data should be directed to us via the contact form on our website.
Our Privacy Statement governs any kind of processing where we are acting as a data controller or co-controller (including collection, use, transfer, storage, and deletion) of personally identifiable information (any information that may be used to identify a physical person, and any other information associated therewith) about natural persons. This Privacy Statement applies to our processing of data collected through any means, actively as well as passively, from persons located anywhere in the world.
We are guided by the following principles when processing data:
- We will only collect data for specific and specified purposes; we will make it clear at the point when we request your information, what we are collecting it for and how we are going to use it;
- We will not collect data beyond what is necessary to accomplish those purposes; we will minimise the amount of information we collect from you to what we need to deliver the services required;
- We will collect and use your personal information only if we have sensible business reasons for doing so, such as contacting you with a weekly newsletter or to provide you with an update in respect to our programmes and services;
- We will seek to verify and/or update your data periodically and we will accept requests from you for amendment of the data held;
- We will apply high technical standards to make our processing of data secure;
- Except otherwise stated, we will not store data in identifiable form longer than is necessary to accomplish its purpose or as required by law.
The information we may collect about you could include, but is not limited to:
- Personal details
- Lifestyle and social circumstances
- Financial and business details
If we obtain special category data from you we will always get your consent first. We will make it clear at the point when we request your information, what we are collecting special category data for and how we are going to use it.
We will collect information from you when:
- You sign up to our newsletter or mailing list
- You download an opt-in
- You join one of our courses/services
- You contact us for information via our website or social media channels, by phone or email
- You post on our social media channels, website, or blog
- You work with us in a commercial capacity
We may use the information collected to:
- Allow you to purchase one of our courses and / or services
- Send you our newsletters or provide you with information, products, or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
- Ensure that content from our site is presented to you in the most effective manner for you and your computer
- Allow you to participate in the service you have chosen to do so
- Notify you about changes to our service
INFORMATION COLLECTION AND STORAGE
If you provide us with your email address it will be stored, along with your first name and surname via our email marketing software.
Payments for purchases made by our site are handled, either directly through Stripe or PayPayl who both have their own privacy policies. We do not collect or store payment information.
We will never sell or share your personal information with third parties.
LEGAL BASIS FOR PROCESSING YOUR DATA
The General Data Protection Regulation (GDPR) provides that processing of your data shall only be lawful if and to the extent that at least one of the following applies:
- You have consented
- For the performance of a contract
- For compliance with a legal obligation which we must perform
- To protect vital interests of yours or another person
- It is in the public interest
- It is in the legitimate interests pursued by us or a third party
We collect data for the purposes set out above. Data is managed to ensure that it is either erased from our system when it is no longer required for the purpose for which it was collected, retained for legal reasons, or minimised and retained.
LINKS FROM OUR SITE
SHARING OF DATA WITH AFFILIATES
We work with trusted affiliates and in doing so it may be necessary to provide third party affiliates with information so that they can deliver services to you as part of your purchase. If an affiliate is connected to a purchase you make, then they may receive a copy of your name and your email address, they may also be aware of the purchase price of any transaction made through our site. We do not store card or payment information and so would never transfer such information. Please contact us before making a purchase if you do not wish for your information to be shared with an affiliate. Please be aware that you may not be able to receive affiliate bonuses if your contact information is not provided to the third party affiliate who will be fulfilling such a bonus.
MARKETING EMAILS AND NEWSLETTERS
We will make it as easy as we can for you to opt out of unwanted processing, providing it does not restrict our ability to provide you with the primary service you have requested.
Please note if you wish to unsubscribe from any marketing emails and / or newsletters that you have signed up for, you can do so by clicking onto the unsubscribe link on the marketing email and / or newsletter that was sent to you. It may take 48 hours for this to become effective.
Please be aware that from time to time we may utilise Facebook marketing, through Facebook and Instagram, including re-targeting features and Google Analytics Advertising Features, including GA4. When using these marketing features an international transfer of data will occur. More detail on those is found below.
For the most part, the capture of any data will be anonymous. At all times when you are using our site you should have the ability to select marketing preferences and opt in or out of your data being captured as to your preference. You may be asked to “opt-in” to additional marketing features and at that stage you will be presented with any additional relevant information and you can select your preferences.
It may be necessary to store your information in a way which involves transferring your data outside of the UK. At all times your data will be protected in accordance with the UK General Data Protection Regulations which require that in order to transfer data outside of the UK we ensure that certain safeguards are in place. Such safeguards include ensuring that equivalent safeguards are in place as would be in the UK and that data is only transferred to countries that the UK has approved as being adequate and appropriate to handle data.
Data that we collect from you may be transferred to, processed, or stored at a location outside the local jurisdiction, including the US, Canada, the UK, and other locations. This means that we may be required to disclose your data in response to lawful requests by public authorities, the courts, law enforcement, or national security authorities in that other jurisdiction.
We will take steps to ensure that your data receives an equivalent level of protection as required by laws of that jurisdiction, including by entering into data transfer agreements. For transfers from the EU, UK, or Switzerland to the US, we rely on adequacy decisions by the EU Commission or putting in place Standard Contractual Clauses as approved by the European Commission (the form for the Standard Contractual Clauses can be found here: EU Commission Standard Contractual Clauses) or another applicable supervisory body.
If none of the necessary safeguards are available we may seek your express consent to transfer of specific data. You may withdraw your consent at any time.
- For EU Residents
The European Union’s General Data Protection Regulation (“GDPR”) gives you certain rights, including: a right to be notified of our data collection practices; the purposes and lawful bases under which we process your data; if our legitimate interests are a basis for processing, what those interests are; the categories of data processed; the categories of third parties with whom data is shared; the details of any data transfers outside of the EU and the safeguards in place; the applicable retention periods or policies; the right to access, correct, and delete (under certain circumstances) your personal information; the right to receive a copy of your information in a “portable” form so that you may transfer it to other services; the right to withdraw consent for processing; the right to lodge a complaint with a data protection authority; the right to be advised of the existence of any automated decision-making, including profiling, and the right to object such decisions; and, the right to withdraw consent without detriment.
- For Californian Consumers
Californian law gives you certain rights, including: a right to be notified of (and to request more information about) our data collection practices; the categories of data we process; the categories of third parties with whom data is shared; the right to request disclosure (up to twice per year) of the personal information we have about you or have had within the last 12 months: the right to delete that information (under certain circumstances); the right to know if your data is being sold; the right to know what personal information is being sold and to opt-out of such sales (if applicable); the right to receive a copy of your information in a “portable” form so that you may transfer it to other services; and, the right to not be discriminated against for exercising these rights.
CHANGES TO OUR POLICY & FUTURE PROCESSING
We do not intend to process your personal information except for the reasons stated within this Privacy Statement. However, we do continually review our privacy practices and if we do change our processes this Privacy Statement will be amended and placed on our website at www.thegrowthchain.co.uk/privacy
If you are concerned about how we are collecting, using and/or sharing your personal information, you can contact us via the contact form on our website.
This Privacy Statement was first published on 28th July 2023