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Privacy & Cookie Policy (UK)

This Privacy & Cookie Policy explains how Growth Habits Ltd ("we", "us", "our") collects, uses, and shares personal data when you use growthhabits.co.uk (the "Site") and our services. We are the data controller under UK data protection law. Contact: privacy@growthhabits.co.uk. Data Protection Officer (DPO): DPO Officer.
 

You have rights under UK GDPR and the Data Protection Act 2018. You can contact the UK Information Commissioner’s Office (ICO) at ico.org.uk.
 

1. What data we collect

  • Identity and contact data: name, email, phone, company, job title.

  • Marketing preferences: your choices on receiving marketing from us.

  • Technical & usage data: IP address, device identifiers, browser type, pages viewed, time on page, links clicked, referring URL.

  • Cookies & similar technologies: see the Cookie section below for details.

  • User enquiries/support: messages, enquiries, feedback.
     

2. How we get your data

  • Directly from you (forms, email, phone, events, surveys including ScoreApp).

  • Automatically via cookies, pixels, and analytics when you use the Site (where consented).

  • From third parties (e.g., analytics providers if enabled, and lead‑gen tools such as ScoreApp) where lawful.
     

3. Purposes & lawful bases

We process personal data for the following purposes and lawful bases:

Purpose

Lawful basis (UK GDPR Art. 6)

Provide and operate the Site and services

Legitimate interests (to run our business and provide our services)

Customer service and communications

Legitimate interests and/or contract

Troubleshooting, security, fraud prevention

Legitimate interests (to keep our services secure)

Analytics and Site improvement (non‑essential cookies only with consent)

Consent (PECR/UK GDPR)

Marketing by email to new prospects

Consent

Marketing to existing customers of similar products/services (soft opt‑in)

Legitimate interests under PECR with opt‑out at any time

Legal compliance and record‑keeping

Legal obligation
 

4. Who we share data with

  • Service providers (processors): website hosting and platform services (e.g., Wix), lead‑generation and survey tools (e.g., ScoreApp), email/SMS platforms, CRM, analytics (if enabled), IT/security support, and other vendors who act on our instructions.

  • Professional advisers: lawyers, auditors, insurers.

  • Authorities: HMRC, regulators, law enforcement where required.

  • Business transfers: in connection with a merger, sale, or reorganisation.
     

5. International transfers

Some of our service providers may process data outside the UK. Where this occurs, we implement appropriate safeguards such as the UK IDTA or the UK Addendum to the EU SCCs, or rely on an adequacy decision, as applicable. Details available on request.
 

6. Retention

  • Enquiry and lead records: typically 24 months after last meaningful interaction, unless you ask us to delete sooner (subject to legal holds).

  • Marketing data: until you opt out or after 24 months of inactivity, whichever is sooner.

  • Cookie identifiers: per the lifetimes listed in the Cookie settings page.
     

7. Your rights

You have rights to access, rectification, erasure, restriction, data portability, and to object to processing (including direct marketing). You also have the right to withdraw consent at any time. To exercise rights, contact privacy@growthhabits.co.uk. You can complain to the ICO at ico.org.uk if you are unhappy with our handling of your data.
 

8. Marketing communications

You can opt out of marketing at any time by clicking "unsubscribe" in our emails or contacting privacy@growthhabits.co.uk. For SMS, reply STOP. For the soft opt‑in to apply, you must be an existing customer and we will only market similar products/services. We will always offer an easy opt‑out at collection and in every message.
 

9. Cookies & similar technologies
 

9.1 What are cookies?

Cookies are small files placed on your device. Pixels, SDKs, and local storage may also be used. Cookies can be essential (strictly necessary) or non‑essential (analytics, personalisation, advertising).
 

9.2 How we use cookies

  • Make the Site work (e.g., security, load balancing and basic functionality).

  • Measure performance and improve the Site (analytics, only with consent).

  • Personalise content and marketing (only with consent).

  • Deliver and measure advertising (only with consent).
     

9.3 Your choices (consent)

On your first visit, we show a cookie banner asking for your consent for non‑essential cookies. You can Accept, Reject, or Manage settings. We will not set non‑essential cookies unless you consent. You can change your preferences at any time via the "Cookie settings" link on the Site.
 

9.4 Cookies we use

We operate on the Wix platform, which sets essential cookies required for security, load balancing and basic functionality. We may also use a lead‑generation survey tool (ScoreApp) which can place cookies or similar technologies when you interact with embedded forms. We will only use non‑essential cookies (e.g., analytics, advertising) with your consent via our cookie banner and preferences centre. A current list of cookies and lifetimes is available through our Cookie settings link on the Site, which updates automatically as services change.
 

9.5 Managing cookies in your browser

You can set your browser to block or delete cookies. Doing so may affect Site functionality. See your browser help for details.
 

10. Security

We use appropriate technical and organisational measures to protect personal data, including access controls, encryption in transit, regular patching, and backups. No method of transmission or storage is 100% secure; if we become aware of a data incident affecting your personal data, we will assess and, where required, notify you and/or the ICO.
 

11. Children

Our Site is not intended for children under 18.
 

12. Changes to this Policy

We may update this Policy from time to time. The "Last updated" date will change and, where appropriate, we may notify you by email or on the Site. Please check back regularly.
 

13. Contact

Questions about privacy or cookies? Email privacy@growthhabits.co.uk or write to 203 West Street, Fareham, Hampshire, United Kingdom, PO16 0EN.

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