Privacy Policy

This Privacy Policy sets out the data processing practices of Growth Track.  Please note that all data thus captured will be used and held in accordance with the requirements of the Data Protection Act 2018.

Our registered address is: 2 Adelaide Street, St Albans, Hertfordshire AL3 5BH

Growth Track is the controller. If you have any requests concerning your personal data or any queries with regard to how we handle your data you can contact us by phone on 020 3670 1000, email hello@growthtrack.co.uk or write to us at Growth Track, Churchill House, Stirling Way, Borehamwood, Herts, WD6 2HP.

 

Reasons for processing your personal data

Activity – Completing a form on our website

Purpose for processing – To provide you with information about our products and services/newsletter

Lawful basis – Consent/Legitimate interest

Activity – Registering for an event

Purpose for processing – Dealing with your request to attend an event/Providing you with information about our products and services

Lawful Basis – Consent/Legitimate interest

Activity – Making an enquiry

Purpose for processing – Dealing with your enquiry/Providing you with information about our products and services/newsletter

Lawful Basis – Consent/Legitimate interest

 

The legal basis on which we rely are:

Consent – In some instances where we collect details either online or offline for newsletter or marketing communications sign-ups we ask for consent. We only collect the data required to process the request and you can opt out of communications at any time.

Contract – processing is necessary for us to administer the pre-contract and contractual relationship between ourselves and our suppliers/customers/potential employees in connection with the performance of a contract.

Legitimate interests – We use legitimate interests and PECR to process electronic communications and marketing to soft opt-in data records and you can opt out of communications at any time.

 

  1. Marketing

We would like to use your personal data to send you details of products or services that we offer that we have identified as likely to be of interest to you where applicable.  We will only send you information in line with the preferences you indicated when you provided the personal data.

If at any point you would like to opt-out of receiving communications from us, or would like to change the channels (such as email or post) that we use to contact you, please contact us at hello@growthtrack.co.uk or use the unsubscribe options available within every electronic communication. We do not carry out any 3rd party marketing

 

  1. Recipients/categories of recipients

In carrying out our business including our obligations to you, we may use sub-contractors. These may include mailing houses, email broadcasters, marketing agencies. We will ensure that they respect your privacy and abide by all data protection laws.

 

  1. Transfers to third countries

As part of our processing activities we may transfer your personal data to other countries. We will always ensure we have a written data processing agreement with these processors to ensure the same level of data protection in the United Kingdom will apply. We do not process data outside of the EEA.

 

  1. Retention periods

We will keep your personal data in connection with the services/products you have bought for 7 years after the last purchase. We need to retain this data for our own accounting purposes and for legal and tax purposes.

In terms of personal data we use for marketing, we will keep this data for as long as we are able to market to you and if you withdraw your consent or opt-out of marketing communications, we will keep your contact details only to ensure that we do not contact you again for marketing purposes.

 

  1. Data subject’s rights

You have rights in respect of your personal data. We will need to confirm your identity before we can consider your request so, if you wish to exercise any of these rights, we will 2 forms of identity to ensure you are the data subject. These can be a passport, driving licence or utility bill.

The right to be informed – you have the right to be told about the collection and use of the personal data you provide. This privacy policy sets out the purpose for which we process your personal data, how long we will keep your data, who we will share your data with. If you have any questions on how and why we process your data please contact us using the details above.

Right of access – you have the right to know whether we are processing your personal data, and to a copy of that data. We would need as much information as possible to enable us to locate your data. We will respond to your request within 28 days of receipt of your request. If you want to exercise this right, please contact the us using the details above.

Right to rectification – you have the right to have any incorrect personal data corrected or completed if it is incomplete. You can make this request verbally or in writing. We will need as much information as possible to enable us to locate your data. We will look at any request and inform you of our decision within 28 days of receiving the request.  If you want to exercise this right, please contact us using the details above.

Right to erasure – this right, often referred to as the right to be forgotten allows you to ask us to erase personal data where there is no valid reason for us to keep it. We will look at any request and inform you of our decision within 28 days of receiving the request.  If you want to exercise this right, please contact us using the details above.

Right to restrict processing – you have the right to ask us to restrict processing of your data. We will look at any request and inform you of our decision within 28 days of receiving the request.  If you want to exercise this right, please contact us using the details above.

Right to data portability – you have the right to move, copy or transfer your personal data from one IT environment to another. This right applies to data that you have provided to us and that we are processing on the legal basis of consent or in the performance of a contract and that processing is by automated means. We will respond to your request within 28 days of receipt of your request. If you want to exercise this right, please contact us using the details above.

Right to object – you have the right to object to our processing of your personal data based on (i) legitimate interests, or for the performance of a task in the public interests/exercise of official authority (including profiling); (ii) direct marketing (including profiling); and (iii) for purposes of scientific/historical research and statistics.

  • Legitimate interests/legal task – your objection should be based on your particular situation. We can continue to process the data if we can demonstrate compelling legitimate grounds which override your interests.
  • Direct marketing – you have an absolute right to ask us to stop processing for the purposes of direct marketing. We will action your request as soon as possible.
  • Scientific/historical research and statistics – your objection should be based on your particular situation. If we are conducting research where the processing is necessary for the performance of a public task, we can refuse to comply with your objection.

If you want to exercise this right, please contact the us using the details above.

Rights relating to automated decision making including profiling – you have the right in respect of automated decision making, including profiling. Where we carry out solely automated decision making, including profiling, which has legal or similarly significant effects on you, we can only do this if it is in connection with a contract with you, we have a right under law or you have provided your explicit consent. We will tell you if this happens and tell you how you can request human intervention or challenge the decision. If you want to exercise this right, please contact us using the details above.

 

  1. Processing based on consent

Where we process your personal data based on your consent you have the right to withdraw that consent at any time without reason. You can opt-out by using the unsubscribe/opt-out in any marketing we send you and you can contact us at the contact details above.

 

  1. The right to lodge a complaint to the supervisory authority

If you are unhappy with any aspect of our handling of your data you can contact us on directly at hello@growthtrack.co.uk or if you prefer you can make a complaint to the Information Commissioner’s Office.

 

  1. Statutory/contractual requirement to provide personal data.

The personal data that you provide to us is necessary for us to carry out the contract you have entered into with us or for us to perform our obligations under Statute including access to our mailing system, social platform or hosting and maintenance.

 

  1. Cookies

Please see our cookies policy at: https://growthmail.co.uk/cookie-policy/ 

 

  1. Third party websites.

Our website may contain links to other websites that are outside our control and are not covered by this Privacy Policy.  If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours.

 

  1. Changes to the privacy policy.

This privacy policy is regularly reviewed and will be updated when necessary. If we make any significant changes to the policy we will communicate these to you.

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