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HOW WE USE YOUR PERSONAL DATA

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where the processing is necessary to perform a task in the public interest or an official function.

More information about the lawful basis we use is found in the Glossary.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message or where required to process Special Category Data. You have the right to withdraw consent to marketing at any time by Contacting us.

 

a. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you as a new customer or supplier or participate in a procurement opportunity

 

(a) Identity

(b) Contact

(c) Payment

(d) Financial Status

(e) Employment & Educational

(f) Special Category Data

 

(a)    Performance of a contract with you

(b)   Necessary for our legitimate interests in developing our relationship with you as a potential client or supplier

Where Special Category or Criminal Conviction Data is used, we will explain to you separately on what grounds we use these.

To deliver agreed services to you (or prepare for their delivery)

(a)    Identity

(b)   Contact

(c)    Employment and Education

(d)   Profile

(e)    Payment

(f)     Financial Status

(g)    Technical

(h)   Usage

(i)     Communication

(j)     Marketing & Contact

(k)    Special Category Data

(l)     Criminal Conviction Data

(a)    Performance of a contract with you

(b)   Necessary for our legitimate interests in (i) assessing your suitability in relation to a vacancy, (ii) delivering a service we offer, and (iii) tracking and reporting on contract progress

Where Special Category or Criminal Conviction Data is used, we will explain to you separately on what grounds we use these.

To manage our relationship with you which will include but is not limited to:

(a) Managing your account and providing services support

 

(b) Notifying you about changes to our terms or privacy notice

© Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Contact

(e) Financial Status

(f) Payment

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests in keeping our records updated and studying how customers use our products/services)

 

To manage consultancy or advisory services you provide to us or our clients

(a)    Identity

(b)   Contact

(c)    Financial Status

(d)   Payment

(e)    Financial Status

(f)     Technical

(g)    Profile

 

(a)    Performance of a contract with you

To use data analytics to measure and report on the performance of our services

(a)    Identity

(b)   Contact

(c)    Usage

(d)   Profile

(a)    Performance of a contract with you

To administer our day-to-day business operations, including but not limited to (i) enabling you access to our facilities and/or services, (ii) meeting our legal obligations in carrying out our business, (iii) assessing applications to deliver services to us, and (iv) appointing oversight bodies to govern and advise on our activities

(a)    Identity

(b)   Contact

(c)    Payment

(d)   Financial Status

(e)    Special Category Data

(f)     Criminal Conviction Data

(g)    Communication data

(a)    Performance of a contract with you

(b)   Necessary for our legitimate interests in ensuring our business functions are cost-effective, compliant and accessible

Where Special Category or Criminal Conviction Data is used, we will explain to you separately on what grounds we use these.

To enable you to take part in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests in studying how customers use our products/services, to develop them and grow our business

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), including measure or understand the effectiveness of our website and products / services

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Contact

(f) Technical

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests (i) in running our business, providing administration and IT services, ensuring network security, preventing fraud and in the context of a business reorganisation or group restructuring exercise, (ii) in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

To make suggestions and recommendations to you about goods, services, opportunities or events that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Contact

(a) Necessary for our legitimate interests in developing our products/services and growing our business

(b) Your consent, where this is required by law

 

b. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

You will receive marketing communications from us if you have requested information from us or if we can demonstrate that we have a legitimate interest in sending marketing material to you (and you have not opted-out).

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside The Growth Company group for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

 

c. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the cookie policy on our website.

 

d. Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.