Privacy Policy

Last Updated: 17th March 2026

Growth Engineering Technologies Limited known as “Growth Engineering” or the “Company” respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we process your personal data on our website, when you subscribe and register to our services.

This privacy notice also tells you about your privacy rights pursuant to the Data Protection Act 2018, UK GDPR and EU GDPR (“Data Protection Laws”).

Controller for Personal Data

A “controller” is a person or organisation who alone or jointly determines the purposes for which and the way any personal data is or is likely to be processed. Unless we notify you otherwise, Growth Engineering is the controller of your personal data for the purpose of this website.

On some occasions we can act as a Processor under Data Protection Laws for our Customers, where this is the case we only act upon the instructions of our Customer.

Scope

This privacy notice applies to the processing of personal data by us in connection with any:

• Organisations or persons for the provision of services by us.
• Suppliers: For the provision of products and services to us by suppliers or service providers.
• Visitors: For the provision of services by us as a visitor on our website.

Types of Personal Data

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. This is known as anonymised data. Anonymised data falls outside the scope of Data Protection Laws.

What Information Do We Collect?

We collect different types of information from you depending on your relationship with us. For example, we collect information when you visit our service, register, place an order, subscribe to our newsletter, respond to a survey or fill out a form.

The categories of personal information include:

• Identity Data such as Name / Username.
• Contact Data such as Phone Numbers, Email Addresses, Mailing Addresses / Country.
• Job Data such as Job Titles.
• Company Data such as Company Name, Company Employee Count.
• Purchasing & Financial Data such as Current Buying Stage, Billing Addresses, Debit/Credit Card Numbers.
• Technical Data such as internet protocol (IP) address, your login data, 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.
• Profile Data includes your username and password, searches made by you, your ratings and comments, preferences, feedback and survey responses, user-uploaded content (which may include personal data contained in documents, images, or videos).
• Usage Data such as information about how you use our website and services.
• Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences.

How We Collect Your Personal Data

Directly From You

You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, Purchasing & Finance Data, Profile Data, Usage Data, Technical Data, Marketing and Communications Data (i) by filling in forms on our website (ii) by leaving ratings and comments (iii) by corresponding with us by email or post (iv) by calling us over the telephone.

This includes personal data you provide when you:

• register for our services.
• subscribe to our service or publications.
• request marketing to be sent to you.
• give us feedback or contact us.
• participate in our marketing or other promotional events.

From Use of Our Website

We gather information and statistics collectively about visitors to our website. Analysis of this information demonstrates the most frequently used sections of the website and assists us in continually improving the online service. You give us your personal data, which includes Profile Data, Usage Data, Technical Data and/or Marketing and Communications Data when you use our website or which we have agreed with you to use or when you review any publications or marketing material we send you. Please see our Cookies Notice for more information.

Indirectly

Third-party sources: We receive Identity Data and Contact Data about you from third parties when:

• we provide our services or other parties send us your personal data to enable the provision of those services from us.
• you provide your personal data to a third party for the purpose of sharing it with us.

Providing Personal Data

Where we need to collect personal data by law or under the terms of a contract we have with you and you do not provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel our service but we will notify you if this is the case at the time.

How We Use Your Personal Data

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

• Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you. For example when you sign up to our services.
• Legal obligation: Where we need to comply with a legal obligation. For example, for accounting or legal purposes.
• Legitimate interests: 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.
• Consent: We do not generally rely on consent as a legal basis for processing your personal data. Where we do rely on consent, you have the right to withdraw consent at any time. Please contact us at contact@growthengineering.co.uk to withdraw consent. Please also see the section of this notice titled Marketing Communications.

Purposes For Which We Will Use Your Personal Data

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. 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.

Information About Your Trial Account

In some cases, you may enter into a trial experience for a Growth Engineering product or solution. During the trial sign-up, personal data like your name and personal email address may have been provided. This data is gathered and processed to personalise your trial experience and ensure accurate email notifications.

As with any data collected by Growth Engineering Technologies Ltd., we will never disclose, sell, rent, or lease any personally identifiable information to third parties.

Please take into account the following:

• Your name, email address, and profile image may appear alongside your user profile, which might be accessible to other users.
• Information posted on a social stream or within your user profile area may be accessible to other users.
• Growth Engineering reserves the right to employ our trial environments when showcasing our products to interested parties, potentially revealing the details entered within the trial environment.

AI Processing

We use AI functionality to support personalised learning and assist users in creating course content based on materials they upload (e.g. PDFs, images, and videos).

Uploaded content is processed solely to generate outputs and is not used to train or improve AI models. We do not share this data with any third-party AI providers; all processing takes place within our own systems.

Uploaded materials may contain personal data. We process such data only as necessary to provide the AI functionality.

We may log AI interactions (such as inputs and outputs) for security, performance, and troubleshooting purposes, and retain these logs only as long as necessary.

Users are responsible for ensuring they have the right to upload any content and must not upload personal or confidential data without appropriate authorisation.

Our AI functionality does not make automated decisions that produce legal or similarly significant effects.

Marketing Communications

We may send you marketing communication. You have the right to object to processing of your personal data for direct marketing purposes. You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. Please see the section titled Contact Information.

Where you opt out of receiving marketing communications this will not apply to personal data provided to us as a result of registering for or using our service, your service experience or other interactions with this website.

By submitting your email address on our website, you consent to receive emails from us. You can unsubscribe from these email lists at any time by clicking the opt-out link or other unsubscribe option included in the respective email.

We do not send unsolicited commercial emails, as we share your aversion to spam. Submitting your email address also permits us to utilise it for customer audience targeting on platforms such as Facebook, where we display custom advertising to specific individuals who have opted-in to receive communications from us.

Our mailing list is refreshed annually, and if there has been no activity during that period, your data will be deleted from our system. You can opt out of receiving such information at any time by clicking the unsubscribe link in emails or contacting us.

Do We Share the Information We Collect With Third-Parties?

Marketing Partners: We share both personal and non-personal information collected with third parties, including advertisers, contest sponsors, promotional and marketing partners, and providers of content or products and services we believe may interest you.

Merger & Sales: We share such information with our current and future affiliated companies and business partners. In the event of a merger, asset sale, or other business reorganisation, we may transfer your personal and non-personal information to our successors-in-interest.

Trusted Third-Party Service Providers: who may be engaged to perform various functions and services for us, such as server hosting, database management, email management, marketing, credit card processing, customer service, and order fulfilment for products and services you may purchase through our website or platforms. We do not share uploaded content with third-party AI providers.

Analytics and Technical Partners: Portions of our log file data, including IP addresses, may be shared with third parties for analytics purposes, including web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics, such as connection speed, and device type used to access the service. This information may be aggregated for auditing, research, and reporting purposes for us and our advertisers.

Legal Obligations: We disclose personal and non-personal information about you to government or law enforcement officials or private parties if, at our sole discretion, we believe it is necessary or appropriate to respond to claims or legal processes (such as subpoenas) to protect our rights, interests, or those of a third party, safeguard public safety or any individual, prevent or halt illegal, unethical, or legally actionable activities, or comply with applicable court orders, laws, rules, and regulations.

International Transfers

We transfer and process your personal data outside of the United Kingdom/European Union to countries where data protection laws are less stringent than those in the UK/EU. When we transfer your personal data outside of the UK/EU, we only do so to entities that offer our users the same level of data protection as that afforded by the UK Data Protection Act 2018, UK GDPR and the EU GDPR.

1. We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or
2. We will use specific contracts approved for use in the UK or EU which give personal information the same protection it has in the UK/EU. For example, the use of Article 46 UK and EU GDPR safeguard mechanisms to transfer personal data endorsed by the UK Government or European Commission.

To find out more about the transfer mechanism used please contact us. Please see the section titled Contact Information.

Is the Information Collected Through a Secure Service?

We employ physical, electronic, and managerial measures to safeguard the security of your information. These measures are in place to prevent unauthorised access, maintain data security, and ensure the appropriate use of your information.

We employ various security measures to safeguard your personal information when you place orders or submit, access, or enter your personal data.

We offer a secure server for these transactions. All sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology, encrypted into our Payment gateway provider’s database, and accessible only to authorised personnel who are bound by confidentiality obligations.

Following a transaction, sensitive information (e.g., credit card details, social security numbers) is not stored on our servers. Nonetheless, we cannot guarantee absolute security for information you transmit to us or ensure that your information on the Service remains invulnerable to breaches, despite our physical, technical, or managerial safeguards.

However, no security system, including encryption systems, is infallible. People can commit intentional crimes, make errors, or neglect to adhere to policies. Therefore, while we make reasonable efforts to protect your personal information, we cannot guarantee absolute security.

If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standard used to assess our compliance with that duty.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.

We may anonymise your personal data so that it can no longer be associated with you for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Data Subject Rights

Under certain circumstances, you have rights under Data Protection Laws. You can:

• Request access to your personal data: This is known as a “data subject access request” and enables you to receive a copy of the personal data we hold about you.
• Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note: We may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you at the time of your request.
• Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims. Please see the section of this notice titled Marketing Communications.
• Request restriction of processing your personal information: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information’s accuracy (b) where our use of the information is unlawful but you do not want us to erase it (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal information (“data portability”): This is where in some circumstances we will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: This is where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. Depending on the processing activity, if you withdraw your consent we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
• Automated decision making: This is where decisions are made about you by automated means. We do not carry out automated decision making.

Keeping Personal Information Accurate and Current

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you wish to update your personal data please contact us.

Carrying Out Your Data Subject Rights

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information 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.

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.

If you wish to exercise any of the rights set out above, please contact us.

Concerns and Complaints

We would appreciate the chance to deal with your concerns in the first instance. Please see the Contact Information section below. If you have unresolved concerns and you live or work in the UK or believe that a personal data breach happened in the UK you have the right to complain at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

If you live or work outside the UK or you have a complaint concerning our personal data processing activities you may lodge a complaint with another supervisory authority.

Changes to Our Privacy Notice

This privacy notice may be changed from time to time in response to legal, technical or business developments. We will take appropriate measures to inform you when we update our privacy notice. We will obtain your consent to any material privacy notice changes if and where this is required by applicable Data Protection Laws.

Links to Other Websites

This Privacy Notice exclusively pertains to our website and the services offered by Growth Engineering Technologies Ltd. Our website and services may include links to external websites not operated or controlled by Growth Engineering Technologies Ltd.

We bear no responsibility for the content, accuracy, or opinions expressed on these external websites. They are not subject to our monitoring, investigation, or assessment for accuracy and completeness.

Please bear in mind that once you follow a link from our website or services to another website, our Privacy Notice ceases to apply. Your activities and interactions on any other website, including those linked on our platform, are governed by the rules and policies of that specific website. Such third parties may employ their own cookies or data collection methods.

Contact Information

For any inquiries, please do not hesitate to contact us through the following channels:

• Via Email: contact@growthengineering.co.uk
• Via Phone Number: +44 (0) 208 103 9005
• Via Our Contact Page: Get in Touch
• Via this Address: 27 Old Gloucester Street, London, WC1N 3AX

Version Control: See beginning of Privacy Notice.