GROWTH INTELLIGENCE PRIVACY NOTICE



    1. Effective May 2018
    2. We are committed to protecting and respecting your privacy.
    3. This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand how we will use your personal data and your rights in relation to your personal data.
    4. Important information and who we are
    5. Growth Intelligence is a trading name of Pelucid Limited. We are registered in England and Wales under company number 07504062 and have our registered office at Uncommon, 25-27 Horsell Road, London N5 1XL, UK.
    6. References to “Growth Intelligence”, “we”, “us” or “our” in this privacy notice, refer to Pelucid Limited.
    7. Controller
    8. Pelucid Limited is the controller and responsible for your personal data.
    9. We have appointed a data privacy manager who is responsible for overseeing privacy matters. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager by emailing privacy@growthintelligence.com
    10. Changes to our privacy notice
    11. Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.
    12. Third party sites
    13. Our website may, from time to time, contain links to and from the websites of other businesses.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check their privacy notices before you submit any personal data to these websites
    14. The data we collect about you
    15. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data)
    16. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
      Identity Data includes first name, last name, username or similar identifier, employer and position/title.
      Contact Data includes address, email address and telephone numbers.
      Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
      Usage Data includes information about how you use our website, products and services.
      Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or we have bought from you.
      Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
      We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate statistics to understand usage of our website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
      We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
    17. How is your personal data collected?
    18. We use different methods to collect data from and about you including through:
      Direct interactions. You may give us your Identity Data, Contact Data and Marketing and Communications Data by corresponding with us at industry events [or other events], by phone, by email or by filling in forms on our website. This includes personal data you provide when:
      – You give us your business card so that we may contact you;
      – You email us;
      – You purchase or enter into negotiations to purchase products or services we offer;
      – You communicate with us to sell us your products or services;
      – You contact us through our website;
      – You register to attend events we organise, sponsor or attend; or
      – You provide us with feedback.
      Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.  Please see our Cookie Policy for further details.
      Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: – Identity Data and Contact Data from your employer if you are a user of Growth Intelligence services and have a unique log-in to use those services;
      – Technical Data from analytics providers such as [          ];
      – Usage Data from analytics providers such as Azalead and Google Analytics;
      – Identity Data and Contact Data shared with us by our partners and event organisers at events we sponsor or attend; and
      – Identity Data and Contact Data from publicly available sources such as LinkedIn, Twitter, press articles and publications, personal blogs and other websites.
    19. How we use your personal data
    20. 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 you have given your consent to the processing of your personal data for a particular purpose.
      – 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 it is necessary for the performance of a contract with you.
      – Where we need to comply with a legal or regulatory obligation.
    21. Purposes for which we will use your personal data
    22. We have set out below 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.

      Purpose/Activity Lawful basis for processing including basis of legitimate interest
      To build a database of contacts and prospects who might be interested in our products and services and to inform our marketing and sales activities, including market mapping, client and prospect mapping and analysis Necessary for our legitimate interests (so that we can market and sell our products and services)
      To invite you to our events and send you our marketing communications Necessary for our legitimate interests (so that we can market our products and services to B2B customers)
      To provide you with products and services you have purchased from us or are in negotiations to purchase from us including communications, managing the provision of your services including support services and to manage and collect fees (a) Performance of a contract with you
      (b) Necessary for our legitimate interests (to recover amounts due to us)
      To register you as a user and set up your user account so that you can access the Growth Intelligence services and so that we can provide you with support services in relation to our products and services As a processor under contract with a customer to provide our products and services to you at the request of a customer
      To buy products and services from you Performance of a contract with you
      To manage our relationship with you which will include:
      (a) Notifying you about changes to our terms or privacy notice
      (b) Asking you to update your information
      (a) Necessary to comply with a legal obligation
      (b) Necessary for our legitimate interests (to keep our records and database updated)
      To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
      (b) Necessary to comply with a legal obligation
      To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

    23. Marketing
    24. You may receive our communications or invitations to our events if you have requested information from us, if you provided us with your details or if we have or if we have identified you as someone who may be interested in our products and services and you have not unsubscribed from our marketing communications.
    25. Opting out
    26. You can ask us 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.
    27. Cookies
    28. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.
    29. Disclosures of your personal data
    30. We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
      – Service providers acting as processors who we use to help manage our business.  We currently use AWS, Salesforce, Google Drive and Dropbox for this purpose who are all based in the US.
      – Service providers acting as processors who we use to to send our marketing communications.  We currently use Active Campaign and Outreach who are based in the US.
      – Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
      – HM Revenue & Customs, regulators and other authorities based in the UK if required by such authorities.
      – Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
      We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
    31. International transfers of data outside of the EEA
    32. Your data will be transferred, stored and/or processed outside the European Economic Area (EEA) as our suppliers sometimes operate from outside of the EEA. We will only transfer your data outside of the EEA in compliance with data protection laws and provided appropriate or suitable safeguards are in place to protect your data, these being either Standard Contractual Clauses, Binding Corporate Rules or, in the case of transfers to the US, a Privacy Shield certification.  Please contact us if you would like details of the appropriate safeguards.
    33. Data security
    34. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
    35. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
    36. Data retention
    37. How long will you use my personal data for?
    38. We will retain your personal data for as long as necessary to provide you with our products and services. We will also retain your personal data as necessary to fulfil our contractual obligations and to comply with our legal obligations, resolve disputes, and enforce our agreements.
    39. We will retain personal data that is part of our marketing database for a period for which we think that information is relevant.  We actively manage our marketing database so that only relevant personal data is retained.
    40. Where we no longer need to process your personal data for the purposes set out in paragraph 4 of this Privacy Notice, we will delete your personal data from our systems unless we need to retain a limited amount of information to make sure that we act in accordance with your wishes.
    41. Where permissible, we will also delete your personal data on your request. Information on how to make a deletion request can be found in the Your Legal Rights section of this Privacy Notice.
    42. If you have questions about our data retention practices, please contact us through privacy@growthintelligence.com.
    43. Your legal rights
    44. You have the right:
      – To access any personal data we hold about you and we will provide a copy of your personal data together with details of the purposes of the processing, the types of personal data we hold and the people to whom your personal data has been disclosed;
      – To have inaccurate or incomplete personal data corrected or to restrict the processing of personal data whilst the accuracy is checked;
      – In certain circumstances, to have data we hold about you transferred to yourself or another data controller. Note, this right only applies to information that is processed by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you;
      – To ask to have personal data we hold about you erased. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law;
      – To ask us not to process your personal data for direct marketing purposes;
      – To object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms;
      – To withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent; and
      – To lodge a complaint with the UK Information Commissioner’s Office: https://ico.org.uk/concerns/ or other data protection supervisory authority applicable to you, if you have a concern about your personal data.
    45. You can exercise your rights at any time by contacting us at privacy@growthintelligence.com
    46. What we may need from you
    47. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
    48. Time limit to respond
    49. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.