Introduction & General Terms
Our Privacy Policy, detailed in this document, and our Cookies Policy, which you can find at https://growthxgalaxy.com/cookie-policy/, demonstrate our dedication to protecting private information. In particular, this applies to users of our websites, those that have subscribed to our newsletter and mailing list and to any other individual whose personal information we store.
Personal data discussed in this Privacy Policy is processed by GrowthX OÜ and referred to as ‘we, ‘our’, ‘us’ and ‘GrowthX’ in this document. You can learn more about GrowthX on our home page at https://growthxgalaxy.com/.
In the future, if GrowthX is sold or goes into receivership, we reserve the right to carry on sharing your personal information with third parties. This will be in line with the latest preferences you have set. If this does happen, you will be informed.
Our Commitment to you
Our priority is ensuring that your personal data is protected and managed in a way that conforms with the current legal regulations and best practices. Our goal is to be responsible and dependable with your personal data. All of our actions are based on this Privacy Policy when we are processing personal information. The way that we process your personal information is based on our legitimate interests of providing the best user experience and one that is secure and trustworthy. We strive to ensure your data remains accurate and protected at all times. We also take your data preferences very seriously regarding direct marketing.
On our websites, you may notice hyperlinks that lead to third parties. It is important to note that these third parties will have their own Privacy Policy and cookies. It is best that you read over them. The documents will advise you on how they are going to use your personal data and what cookies will be used. GrowthX does not accept any responsibility for what takes place on these third-party websites nor is liable for any actions.
In order to complete some of our services, we might work with third-party suppliers. Indeed, they may be located outside of the EEA, which might affect the laws of protection you enjoy when it comes to personal information. If this happens, we may:
- Make sure that any transfer of personal information only takes place to countries that have acceptable legal protections deemed by the European Commission. You can read more about this (European Commission: Adequacy of the protection of personal data in non-EU countries.)
- Create special contracts with specific service providers that are approved by the European Commission. This is in order to offer the same level of data protection available in Europe. You can read European Commission: Model contracts for the transfer of personal data to third countries.
- Transfer data to US providers when part of the Privacy Shield. This ensures adequate data protection like that that is used in Europe. You can read European Commission: EU-US Privacy Shield.
Other than for legal purposes, we do not share your personal information with state institutions or local authorities. If this is required, we will verify through our own investigation that the release of the data is only for genuine reasons.
At GrowthX, we reserve the right to make changes or alter this Privacy Policy in order to follow legal changes or developments with our business. These amendments can be made at any time. If they are important adjustments, we aim to email everyone that is registered with our websites so that they are aware of the changes. Nevertheless, we believe that it is your responsibility to read through this Privacy Policy before you use our websites.
Who are GrowthX?
There is a range of brands at GrowthX and all of them operate under this Privacy Policy. You are able to find more about these brands at https://growthxgalaxy.com/.
Information/Data we collect
There are going to be instances when you send our team personal information. For example, this might be through an online form or when you are speaking to a representative over the telephone. This is called pseudonymous data and it cannot identify you as an individual. But it can be data that we use for analysation purposes.
Data You Provide
There are a number of circumstances when we may receive your personal information. For instance, when you make a purchase of one of our products or services or when you subscribe to a magazine or newsletter. Personal information can include your full name, date of birth, telephone number or email address. Other examples of information we can receive are your income, credit rating and relationship status. We can also know when you use our websites and how long you stayed on them.
Data on Children
In addition to a child’s data, parents or guardians of a child under 13 years old might have some limited personal information processed by us. This is to enable us to store and process data about our child and in order to offer the product or service that you have purchased on the behalf of your child. The details that are provided can be used to contact you regarding the products or services that your child requires. We do not actively send any marketing communications to children under 13. If you think that personal data about your child is being stored by us without your consent, you can write to us at info@growthxgalaxy.com. Please request that your child’s data be deleted.
Data Purchased from a Third Party
There are circumstances that mean GrowthX buys data from a third-party supplier. Normally, this is business data, which can include business email addresses, job titles and postal addresses. This means that you might start to receive communications from our team without asking for business information. There will always be the option to unsubscribe from communications. In order to request more information on business data that has been purchased, you can contact info@growthxgalaxy.com.
Collection of Data Through Use of Our Websites
Information on your browsing device can be collected by us when you use GrowthX websites. This can comprise of your IP address, which is a line of unique characters that allow the ability to identify a computer. We may also collect anonymous information from visitors, which can help analyse website traffic and use of advertisements. In addition, we do partner with third parties, which can mean that we might receive data. For further information on this, you can read about Online Advertising in this Privacy Policy. If you do not wish to receive personalised advertisements, you can see http://youronlinechoices.eu/.
You can also read about our Cookies below and view our Cookie Policy.
How we use your data
With the data that we collect through our websites, we may use this information in certain ways that we have outlined below.
Competitions & Prize Draws
If you wish to be entered into a competition or prize draw through our website, we will use your information for this purpose. The details can extend to your name, telephone number and email address. The information given is used for entry and in order to notify you if you win. Your data is kept for the duration of the competition. You shall not be added to marketing lists except for when you have consented. Any information is shared with third parties if you were aware during entry to the competition or if they are in charge of delivering prizes.
Newsletters
When you subscribe to one of our newsletters, we can use the details you have provided. But we do not share with third parties. Your details are not for marketing lists and this only happens if you consent to the use of your details. On each newsletter, there is a link for you to unsubscribe if you no longer want to receive it.
Events
If you have signed up for an event, we will use your details for the purpose of registration. The details might be your email address, mobile or home telephone number, as well as other information you may provide concerning the event. Only if you have consented will your information be used for marketing. In addition, your data can only be given to a third party if they are named during registration or they are managing the event.
Magazine Subscription
Any details that are provided for a magazine subscription will be used to manage this subscription. For example, this will involve sending out your magazine, ensuring secure and safe payments, to send any promotional gifts, to answer questions and to contact you about your subscription by email or telephone. You can also be notified of any changes to our Privacy Policy or Cookies Policy. Unless you have consented, your data cannot be included in marketing lists. If third parties are involved with the management of a subscription, your data may be shared with them.
Customer Services
Any information that is given to us during customer services may be used to help us with any purchases or inquiries. Unless you have consented, your data cannot be included in marketing lists. If third parties are involved with customer care you are receiving your data will be shared with them.
Research
If we are conducting surveys and focus groups in order to learn more about our products and services, we might invite you using your data. You are not required to participate unless you want to. All answers are anonymous and only used to improve customer experience. Unless you have consented, your data will not be included in marketing lists. Information will only be shared with third parties if they are involved with research procedures.
There may be occasions when commercial parties monetise research and we conduct it for them. You might share your information for this process where they are named at the point of capture or you agree to this research. All data is anonymous.
Direct Marketing
You might find that personal data you have shared with us, such as your email address or telephone number, is used to provide you with deals and promotions. This will only be done when you have not objected to this communication and when there is something we think will interest you. You can stop this marketing communication at any time, whether this is at point of data capture or once you have started to receive contact. To avoid future promotions, you can contact info@growthxgalaxy.com. We do not use your personal information for campaigns if you have not been consulted first.
Demand Generation
Your personal details can be used to receive relevant and interesting content. In other words, you might receive offers and information from us or an associated partner that we trust through emails, calls or post. At any time, you are able to opt-out of this.
Legitimate Interest
If there is a legitimate interest, we might choose to process your personal data about you. This will only be after careful consideration between the purpose and your rights. Some examples of legitimate interest are:
- The promotion of comparable products and services that you may be interested in as identified with previous interactions with our website. This will apply if you have not opted out.
- For fulfilling unsubscribe requests
- For sending an invitation to a research survey about products or services
- In order to make improvements to products or services
- Looking at your purchase history and data in order to provide a better service
- For the prevention of fraudulent activities
- To utilise Facebook’s audience function and Google customer match
- For the analysation of trends with the intention of improving targeted advertising and campaigns.
If your personal information is used for any of the above processes, we always certify that we will use it responsibly and ensure your rights are protected.
Cookies and how we use them
When you visit a website on your computer or smartphone, a small piece of data can be stored on your device. These are called cookies and we can use the following:
Strictly Necessary Cookies – Just as the name suggests, we only use these when they are essential for website functionality. They are required in order to access features, such as adding a product to a cart. They can also be necessary for logging into your account. They do not store any data that can personally pinpoint you. Be aware that you can stop these cookies. However, you should be aware that some of our websites might not function properly.
Performance Cookies – in order to improve how our websites perform, we can use performance cookies. This provides us with information on visitors and how they operate with our websites. Any data that is gathered is anonymous.
Functional Cookies – These cookies have the job of supporting the functioning of a site. They can remember the choices you make for a personal experience. We might create them at GrowthX or one of our third-party providers.
Targeting Cookies – They are able to learn about your browsing interests and display adverts that interest you. Targeting cookies might be used by our advertising partners. However, they do not have the ability to store personal information. They can only know your browser and the device you are using.
Social Media Cookies – They are going to originate on social media and they can be added to GrowthX websites. The purpose of this is to allow you to share any content that you like with your loved ones. Social media cookies have the ability to track your browsing habits and display your interests.
You can find out more about cookies by reading our Cookie Policy.
Analytics
In order to make improvements to our websites and ensure we provide the best content, we use Google Analytics. This allows us to track everything from visits to interactions users have with our collection of websites.
To learn more about how Google may process your information, you can read: https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008
Online Advertising
You might notice that advertising is displayed on our websites and this helps to keep our services free to enjoy. We can use Online Behavioural Advertising, which is advertising that is customised for the interests of the visitor. This is enabled through cookies, which have the ability to find out the webpages you have visited. Thus, you can enjoy adverts that may interest you. This type of advertising does not collect personal data and will not gather your email address, telephone number or full name.
On occasion, we might choose to share aggregated data. This can be with advertising partners and advertising may be displayed based on your behaviour monitored by GrowthX.
A type of Online Behavioural Advertising to be aware of is behavioural retargeting. This means that you can see adverts that are based on your general browsing habits.
Please be aware that if you opt-out of Online Behavioural Advertising, you will still receive advertising from us. Only, this advertising will not be customised for your interests. Learn more about this at www.youronlinechoices.com or http://www.networkadvertising.org/.
Ad blocking extensions that are present on web browsers might be discovered by JavaScript on our websites. GrowthX does not store data on your device nor do we process any of this personal information.
Links to third party websites
The act of clicking onto any links or adverts provided on GrowthX websites will have the result of leaving and entering the website of a third party. At this point, we do not take any responsibility for the site nor does our Privacy Policy apply. You will be subject to their data processing procedures and it is recommended to read their Privacy Policies. In addition, when you see an advertisement on a GrowthX website, we are not endorsing or approving any of their products or services.
Using our websites from outside the UK
The servers for storing data are situated in the European Economic Area. This means that when you use our websites and submit any information, you are agreeing to have your data kept in the EEA. Your details will also be processed according to the terms of Regulation (EU) 2016/679 (GDPR) and in line with UK data protection legislation. If you do not want this to happen, do not submit your personal data.
We cannot guarantee that the content we provide on our websites is going to be available and relevant to other countries. If you decide to still use our services from outside the UK, this is done at your own risk. It will also be your duty to comply with any relevant local laws.
Ensuring the Security of Your Personal Data
Our goal is to prevent the unauthorised or inappropriate use of your personal data by having security policies.
Our GrowthX representatives ensure that the confidentiality of your data is satisfied in order to fulfil legal obligations.
It is important to realise that you will find forums and ways to comment on our websites. This means that you can post public information and this can be seen and used by other visitors.
Who we share your personal data with
GrowthX only works and create partnerships with trustworthy and limited companies. We may share information with these companies to carry out certain tasks, which are outlined in How We Use Your Data.
It is also possible that we will share your personal information with selected third parties. This will be the case if we decide to sell, acquire, merge or transfer any of our assets. Thus, the third parties that become new owners might decide to use your personal data in line with this Privacy Policy.
How long we keep your personal data for
We only keep your personal data for the duration that is necessary to provide you with the products and services you require. If you choose to sign up for marketing emails, we keep your email address in order to provide this service. We will also keep it when you choose to opt-out so that we adhere to this request. Every marketing email you receive shall have an unsubscribe link. You can use this at any time and this will update your preferences to not receive further emails. You can also contact us directly to ensure you do not receive marketing materials.
In certain situations, you may inform us that you wish to delete your data. You can learn more about this in Your Rights Under the GDPR. In addition, for research or other learning practices, we may choose to convert your personal data so that it is anonymous. In this case, we might use the information for an indefinite period of time.
Personal Data – Your rights
In the United Kingdom, you have rights regarding your personal data under the GDPR and associated data protection legislation. This includes the following:
- Right to be informed
- Right to access
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right to data portability
- Right to object
- Right in relation to automated decision making and profiling.
Right of Access
You have the right to access the personal information that we currently hold on you. Your right of access or subject access request enables you to enjoy a copy of your personal data and you can examine it to see whether it is correct and to ensure it is being processed according to the law. You cannot request to see someone else’s personal information nor documents that do not include your personal data.
In order to enjoy your right of access, you can tell us you wish to make a subject access request in writing. There are no forms for this process.
Right to Rectification and Erasure
If you think that your personal data is wrong and invalid, you have the right to ask us to correct the information. In addition, you can request that your personal data be erased from our systems if you think it is no longer necessary to store it. This is also referred to as the right to be forgotten.
Any new data may have to be verified. Indeed, we might carry out our own investigations and checks to ensure that the new information provided is correct. Note that we do not have to erase personal information. For instance, if we think we have a valid legal to process your data, we will share this with you.
Both of these rights, the right to rectification and erasure, can be exercised at any time. You can do this in writing and by describing why you are making this request and on what grounds. In the event you want your personal information to be updated, you should outline what the new data should be. There are no forms for this process.
Right to Restrict Processing
If there is a legitimate interest that leads us to process your personal information, you do have the right to request the revocation of that processing. You are able to do this if you think it is interfering with your rights or if the legitimate interest is baseless.
There are a few other reasons why you can request the restriction of processing. This includes:
- If you believe there are inaccuracies in the personal data and you wish for this to be examined
- There is unlawful use of data but do not wish for it to be erased
- Where the processing of your information is not needed but you want it to be stored in order to deal with legal claims.
It should be noted that we may maintain we are processing your personal data for a valid legal reason. We will share this reason with you if you make a request or after carrying out investigations.
You can use your right to restrict processing at any time. All you have to do is send your request in writing and expand on why you are choosing to make that request and the conditions you believe the processing is violating. There are no forms necessary to exercise this right.
Right to Data Portability
You can write to us and inform us on whether you want to relocate personal data to another party. We can provide this information in computer-readable data. We are willing to honour this type of request. However, it is unlikely that this right will prove relevant for persons using our websites.
Your Right to Stop Communication from Us
If you no longer want to receive communications from us, you can contact our team to find out your rights.
Right in Relation to Automated Decision Making and Profiling
Under the GDPR, you possess a right to be informed of any automated decision making and profiling of your personal data. This includes details on why it is happening and how it is important, as well as what it means for you.
Choosing to Exercise your Rights
You can exercise your rights at any time or request more information on them. If you wish to do this, you can create a request in writing. This should be sent to the following email: info@growthxgalaxy.com.
Please provide our team with some details about you so that we can pinpoint your information. For instance, you can start your full name and address, as well as give us your telephone number or email address
Contact Us
If after reading our Privacy Policy you have any questions or concerns, please feel free to contact a member of our team. You can email your response to info@growthxgalaxy.com. If you are not satisfied with the answer you receive, you are able to share your concern with the Information Commission on their website.
If there is a revision made to one of the terms of our Privacy Policy, necessary changes will also be made on this page. This ensures that you are always kept in the loop about any way the collection of your data is changed.