We are the data controller for the purposes of the Data Protection Act 2018, the EU General Data Protection Regulation (GDPR) and any other data protection legislation application in the UK from time to time.
We may change this policy from time to time by updating this page. You should check this page to ensure you are happy with any changes. This policy is effective from 19 February 2019.
Information we collect
This section describes how we lawfully collect and use your personal data. “Personal data” means any information which relates to an identifiable, living individual. It does not include anonymous data which cannot be linked to an identifiable person.
We will only use your personal information when the law allows us to. The law says that we must identify a lawful basis for each use of your personal data. We rely on a number of lawful bases, including:
Where we have obtained freely given, specific, informed and unambiguous consent from you to use your personal information in certain ways.
Where we need to use your personal data in order to perform a contract that you have entered into with us.
Where we need to comply with a legal obligation.
Where it is necessary for us to use your personal information to pursue our legitimate interests (or those of a third party) and we believe that using your personal information in that way is not overridden by your interests or your fundamental rights and freedoms.
Where it is necessary to protect your vital interests.
Below, we have set out the purposes for which we use each category of your personal data and the lawful bases which are relevant to those purposes.
What information do we hold about you, and how do we use it?
We collect, store and use some or all of the following categories of personal information about you:
Website Usage Information
When you visit our website, we may collect your IP address, location, browser details, operating system details, referral source, duration of visit, page views, website navigation information and service use details.
We use this information to analyse and improve the user experience and performance of our website and services.
Our lawful basis for this processing is our legitimate interest in delivering our services, and monitoring and improving our website and services.
Account and profile details
If you register as a member on our website, we may collect your name, address, email address, phone numbers, usernames and passwords. You will need to register as a member if you wish to use the website to its fullest extent, such as uploading listings and posting comments to the blog.
We use this information to provide our services to you on certain parts of our website, to administer your accounts and profiles on our website, to ensure the security of your information and to inform our communications with you.
Our lawful basis for this processing is our legitimate interest in the proper administration of our website and services. If you, as an individual, enter into a contract with us, we may also need to use this information in order to perform our obligations under that contract.
Contact details and communication information
Where you contact us using the contact forms or other details on our website, we may collect your name, email address, address, telephone number, job title and organisation and the content of your communications or enquiries.
We use this information to communicate with you, including responding to your questions and enquiries, providing information about our services, our website and our relationship with you, dealing with any complaints that you may have and providing information about changes to our business, policies or services.
Our lawful basis for this processing is our legitimate interest in building our relationship and communicating with you.
Where you register to receive updates from the Growth Hub, we may collect your name, email address and subscription preferences.
We use this information to send you our newsletters and other news and information about our events and services. We will only send you information about the Growth Hub in accordance with the preferences that you choose when you subscribe.
Our lawful basis for this processing is consent, as you have specifically requested to receive updates from us. If you no longer wish to receive these updates from us, you can change your preferences or unsubscribe at any time by using the links in any emails we send to you.
Business relationship management
Where you or your organisation engages with us, any of our partners or the advisors registered on our website, we may collect your name, contact details (including email and postal addresses and telephone numbers) and information about your relationship and history with us and our network of affiliates. We may collect this information directly from you, or it may be provided to us by one of our partners or advisors when you correspond with them.
We, and our partners and registered advisors, use this information to manage business relationships within our network and to facilitate and promote networking and communication between the businesses that engage with our network, and we have a legitimate interest to use your information in this way.
Verifying your identity
We may use the information that we hold about you where it is necessary for us to do so in order to meet our legal obligations or to detect and prevent fraud, money-laundering and other crimes.
Protecting you and others from harm
We may also use your information where it is necessary to protect your vital interests, or the vital interests of others. This may include in the event of criminality such as identity theft, piracy or fraud.
Information we collect about you from other sources
We may collect information about you from other sources. This may include the following:
Information that we receive from our partners and registered advisors (see “business relationship management” above)
Publicly available information, including from sources such as Companies House and the Electoral Roll
Information you have shared publicly, including on social media
Information from third party databases including credit reference agencies
Sometimes you will have given your consent for other websites, services or third parties to provide information to us. This could include information we receive about you if you use any of the other websites that we operate or the other services that we provide, including Growth Platform website (www.growthplatform.org) and our portal on Evolutive. In these cases we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data.
It could also include information from third parties that we work with to provide our products and services, such as payment processors, delivery companies, technical support companies and advertising companies. Whenever we receive information about you from these third parties, we will let you know what information we have received and how and why we intend to use it.
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this policy.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Who do we share your personal information with?
Sharing your information within our company and network
We share the information that you provide to us with our staff and the Growth Hub project, so that we can provide our products and services to you.
Depending on the nature of your relationship with us and our network, we may also share your personal data with our registered advisors and other Growth Platform partners. You can find out more information about our registered advisors and Growth Platform partners on our website.
Sharing your information with third parties
We may share your data with selected third parties. For example, we may share your information with:
Our web developers and hosting providers to manage and host our website, related infrastructure, services and applications
Our web-based Customer Relationship Management system, Evolutive, provided to us by Alcium Software.
Contact management systems to send emails, newsletters, instant messages, social media messages and SMS messages
There are certain other exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:
Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings
Necessary to protect the safety of our employees, our property or the public
Necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction
Proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved
Links to other websites
Please note that links from our website may take you to external websites which are not covered by this policy. We recommend that you check their privacy policies before submitting any personal information to such sites. We will not be responsible for the content, function or information collection policies of these external websites.
How long do we hold your personal data?
We will only hold your personal data for as long as we need it for the purposes for which it was collected. Where we provide you with any service, we will retain any information you provide to us at least for as long as we continue to provide that service to you. Where we are using your personal data for one of our legitimate interests, we will only hold your personal data for as long as we have that interest.
Where you are (or your business is) a registered advisor of the Growth Hub, or where you engage with us or our registered advisors, we may retain your personal data for as long as the Growth Hub project operates, for the benefit of our wider network. Where our relationship has come to an end, you may request that we delete your personal data, but we may still retain non-personal information about your business relationships with our network.
Otherwise, we will retain your personal data for a period of up to 3 years.
In certain circumstances, you can ask us to stop using your personal data earlier. You can find more information about your rights below, alternatively you can contact us at any time using the contact details at the top of this page.
How do we protect your personal information?
We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
We try to ensure that all information you provide to us is transferred securely via our website (always check for “https” in the URL, or the padlock symbol in your browser). Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
All information you provide to us is stored on third party secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
You have the right to be informed
We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to do just that, but if you have any questions or require more specific information, please contact us using the details at the top of this page.
You have the right to access your data
You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:
Why we are using your information
What categories of information we are using
Who we have shared your information with
How long we envisage holding your information
In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold. The first copy of your information that you request from us will be provided free of charge, if you require further copies within a short period of time we may charge an administrative fee to cover our costs.
You have the right to correct our records
Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case you can contact us on the details at the top of this page so that we may correct our records.
You have the right to be forgotten
There may be times where it is no longer necessary for us to hold personal information about you. This could be if:
The information is no longer needed for the original purpose that we collected it for
You withdraw your consent for us to use the information (and we have no other legal reason to keep using it)
You object to us using your information and we have no overriding reason to keep using it
We have used your information unlawfully
We are subject to a legal requirement to delete your information
In those situations, you have the right to have your personal data deleted. If you believe one of these situations applies to you, please contact us on the details set out at the top of this page.
You have the right to have your personal data transferred to you or a third party in a common format
Also known as data portability, you have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy or transfer your personal data more easily from one IT system to another, in a safe and secure way.
If you would like us to transfer a copy of your personal data to you or another organisation in a structured, commonly used and machine-readable format, please contact us on the details set out at the top of this page.
There is no charge for you exercising this right.
You have the right to object to direct marketing
You can tell us at any time that you would prefer that we do not use your information for direct marketing purposes. If you would not like to receive any direct marketing from us, please contact us on the details at the top of this page, or use the links provided in any of our marketing communications, and we will stop sending direct marketing immediately.
You have the right to object to us using your information for our own legitimate interests
Sometimes, we use your personal information to pursue our own legitimate interests. We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal data for these purposes.
In order to exercise your right to object to our use of your data for the purposes above, please contact us on the details at the top of this page.
You have the right restrict how we use your information
You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:
You have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this
You have objected to us using your information for our own legitimate interests and we are in the process of considering your objection
We have used your information in an unlawful way, but you do not want us to delete your data
We no longer need to use the information, but you need it for a legal claim
If you believe any of these situations apply, please contact us on the details at the top of this page.
You have rights related to automated-decision making and profiling
Any automated decision-making or profiling we undertake is solely for the purpose of tailoring the information which we provide to you. We will not use automated decision-making or profiling to make any decisions which will have a legal effect upon you or otherwise significantly affect you, and you have the right not to be subject to such decisions. If you have any concerns or questions about this right, please contact us on the details at the top of this page.
If you have any concerns or complaints over how we use your data, please contact us in the first instance so that we can try to help. Our contact details are set out at the top of this page.
If you are not satisfied that we have addressed your concerns properly, you have the right to lodge a complaint with the Information Commissioner’s Office (the ICO) (www.ico.org.uk).
What is a cookie?
A cookie is a small text file that is sent by a website server to your browser and stored on your computer. Cookies are needed for a number of functions which make websites work (or work more efficiently) and they can provide information to website owners about how you use their website.
We use both persistent cookies (which expire on a specified date) and session cookies (which expire when you close your browser). The cookies used on this site have been categorised based on definitions given in the ICC UK Cookie Guide. We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region – or your cookies and marketing preferences).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed.
Our website runs the popular WordPress CMS and cookies are used to store basic data on your interactions with WordPress, and whether you have logged into WordPress. We use a session cookie to remember your log-in for you if you are a registered user and we deem these as being strictly necessary to the working of our website. If these are disabled then various functionality on our website will be broken.
Changing your cookie preferences
You can configure which types of cookies may be placed when you visit our website by [e.g. clicking on consent banner or going to preferences page].
Most browsers allow you to turn off cookies or to receive a warning before a cookie is stored on your hard drive. You can find out more about how to do this at the following links:
Further information about cookies
There’s a lot of good information about cookies available online. For more information about cookies generally visit: allaboutcookies.org