How we collect, use
and protect your data.

• 1.1 Registered number — 16578730
• 1.2 Registered office — 71-75 Shelton Street, London, WC2H 9JQ
• 1.3 Email address — enquiries@growmoneygroup.co.uk
• 1.4 Our Data Protection Officer (DPO) — Our DPO welcomes communication from you regarding any matter relating to data protection, and can be contacted by email at enquiries@growmoneygroup.co.uk.

We will only collect personal information relating to you if one of the following conditions has been satisfied:

• 2.1 You have clearly told us that you are content for us to collect that information for the particular purpose or purposes that we will have specified.
• 2.2 The processing is necessary for the performance of a contract that we have with you.
• 2.3 The processing is necessary so that we can comply with the law.
• 2.4 The processing is necessary to protect someone's life.
• 2.5 The processing is necessary for the performance of a task that's in the public interest.
• 2.6 The processing is necessary for our or another's legitimate interests — but in this case, we'll balance those interests against your interests.

• 3.1 If we need your consent to collect and use certain information, we'll provide you with the opportunity to tell us that you're happy to provide that information at the point of collecting it.
• 3.2 If at any point in time you change your mind and decide that you want to withdraw your consent, please let us know and we'll endeavour to stop processing your information in the specified manner, or we'll delete your data if there is no continuing reason for possessing it.
• 3.3 If you don't consent to a particular bit of processing, we'll endeavour to ensure that the Website and our service continue to operate without the need for that information.

• 4.1 Certain information we collect may be considered to be in special categories of personal information. In particular, it may: reveal political opinions, racial or ethnic origins, religious or philosophical opinions, trade union membership, relate to biometric data, genetic data, your health, or your sex life or sexual orientation.
• 4.2 If we do collect such information as specified in clause 4.1, we'll also ensure that one of the additional reasons for processing outlined in the UK GDPR applies.
• 4.3 It's likely that we'll need to process information relating to criminal convictions or offences or related security measures. If we do so, we'll make sure we comply with the extra conditions set out in the UK GDPR.

5.1 We envisage collecting the following types of information from you:

• 5.2 We may collect personal information about you from a number of sources, including: from you when you agree to take a service or product from us; when you contact us with an enquiry; as you interact with this Website (automatically collecting technical information); from documents available to the public; and from third parties to whom you have provided information with your consent.
• 5.3 If you refuse to provide information requested, then if that information is necessary for a service we provide to you we may need to stop providing that service.
• 5.4 If at any point you think we've invited you to provide information without explaining why, feel free to object and ask for our reasons.

• 6.1 Data protection, privacy and security are important to us, and we shall only use your personal information for specified purposes and shall not keep such personal information longer than is necessary to fulfil these purposes. Examples include: to help identify you when you contact us; to identify accounts, services and products you could benefit from; to administer and contact you about improved services; to carry out marketing analysis; to help prevent and detect fraud; and to contact you about products and services where you have consented.
• 6.2 We will not disclose your personal information to any third party except in accordance with this Policy, including where they process data on our behalf as a data processor, where it's necessary to share with another data controller, or where we consider it to be in your interest (with your agreement).
• 6.3 Where you give us personal information on behalf of someone else, you confirm that you have provided them with the information set out in this Policy and that they have not objected to such use.
• 6.4 In connection with any transaction, we may carry out credit checks and share information with credit reference agencies as detailed in our full policy.
• 6.5 We may allow other people and organisations to use personal information we hold about you in limited circumstances, such as business acquisitions, legal proceedings, or where companies perform functions on our behalf.
• 6.6 The data retention period — we keep personal data only for as long as necessary for its purpose and to meet legal or regulatory obligations.

• 7.1 We have strict security measures to protect personal information.
• 7.2 We work to protect the security of your information during transmission by using appropriate technology to encrypt information you input.
• 7.3 We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information.
• 7.4 It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.

• 8.1 If you communicate with us using the internet, we may occasionally email you about our services and products. When you first give us personal information through the Website, we will normally give you the opportunity to say whether you would prefer that we don't contact you by email for that purpose.
• 8.2 Please remember that communications over the internet, such as emails and webmails, are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered — this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

• 9.1 When we provide services, we want to make them easy, useful and reliable. This sometimes involves placing small amounts of information on your computer, which is sent back to us at a later time. These are called 'cookies'.
• 9.2 Where applicable, this section of the Policy also relates to related technology but the term 'cookie' is used throughout.
• 9.3 Some of these cookies are essential to services you've requested from us, whereas others are used to improve services for you.
• 9.4 To learn more about cookies, you may wish to visit: allaboutcookies.org, youronlinechoices.eu or google.com/policies/technologies/cookies.

9.5 This Website uses, or allows use of, the following cookies:

9.6 Cookie categories:

• Category 1 — Strictly Necessary: Essential cookies to move around the website and use its features.
• Category 2 — Performance: Collect information about how visitors use a website, used only to improve how a website works.
• Category 3 — Functionality: Allow the website to remember choices you make and provide enhanced, more personal features.
• Category 4 — Targeting and Advertising: Used to deliver adverts more relevant to you and your interests.

9.7 As with any other information we may collect from you, we'll work to protect the security of your information during transmission by using appropriate technology to encrypt information you input.

• 10.1 Under certain circumstances, you have rights under data protection laws in relation to your personal information.
• 10.2 You have the right to: request access to your personal information; request correction of incomplete or inaccurate information; request erasure of your personal information; object to processing; request restriction of processing; request the transfer of your personal information; and withdraw consent at any time.
• 10.3 You will not have to pay a fee to access your personal information. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
• 10.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information.
• 10.5 We try to respond to all legitimate requests within one month.
• 10.6 You have the right to lodge a complaint with the Information Commissioner's Office (ICO) or another supervisory authority if you are dissatisfied with how we manage your personal data.

• 11.1 If you would like any more information or you have any comments about this Policy, or if you wish to exercise any of your legal rights, please write to our Data Protection Officer as detailed in clause 1.4.
• 11.2 Please note that we may have to amend this Policy on occasion. If we do that, we will publish the amended version on the Website.
• 11.3 You can ask us for a copy of this Policy by writing to the above address or by emailing us at enquiries@growmoneygroup.co.uk. This Policy applies to personal information we hold about individuals. It does not apply to information we hold about companies and other organisations.