Privacy & Terms

Gearing for Growth Ltd is committed to protecting and respecting your privacy. The last update was made on 7 June 2022.

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). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed, stored and disclosed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting https://www.gearingforgrowth.com (the Site) or using the Reflexivity mobile application (the App) or using any services offered through or associated with our Site or App (the Services), you are deemed to have accepted and consented to the practices described in this policy.

The Site may contain links to and from the websites of our partner networks, advertisers and affiliates or to websites shared by other users. 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 these policies before you submit any personal data to these websites.

The Site and App are owned and operated by:

Gearing for Growth Ltd, registered in Scotland Company Number SC 372678

Email address: hello@gearingforgrowth.com

Postal address: 1 Rutland Ct, Edinburgh EH3 8EY

Telephone number: 07425 629816

In general, Gearing for Growth Ltd processes personal data as a Data Controller, as defined in the Directive and the General Data Protection Regulation (GDPR).

You have the right at any time to make a complaint to the Information Commissioner's Office (ICO) the UK supervisory authority for data protection (www.ico.org.uk)

We collect and process personal information so we can provide our Services to you. It’s important that the personal data we hold about you is accurate and current. Please let us know if at any time your personal information changes by emailing us at hello@gearingforgrowth.com

The data we collect and process about you is explained in the sections below.

Data You Give Us

You give us information about you by filling in forms on our Site or App or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use the Site or App, request a quote or subscribe to our Services, subscribe to our marketing database, participate in interactive features or other social media functions on our Site, or report a problem with the Site or App.

For all types of users, we ask for your name, email address and login details. This data is necessary for us to provide our Services to you. For App users we may request company or educational establishment, phone number and job title.

We may ask users to provide your phone number, date of birth and location data. If you are a student, you can provide your education information (such as the name of your university and your field of study), education history and work history. If you are a professional, you can provide your job title, company information, education history and work history. If you are a business or organisation, we collect additional business information (such as your industry and information about your point of contact). We collect this information for our legitimate interest in providing a more customised Service to you.

We also collect behavioural data about all our users, which we explain further in the sections below.

Data We Automatically Collect

Each time you visit or use our Site, we automatically collect the following information:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types and versions, languages, operating system and platform;

information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

We use this information for our legitimate interests in enabling our user reporting features, system administration, and to evaluating, providing, protecting or improving our Services (including by developing new products and services).

Data We Receive From Third Parties

We use third parties such as Google Analytics to track and report website traffic, Facebook Analytics to measure the performance of our page and Eventbrite to create and promote events. We collect information through these third parties for our legitimate interest in marketing and improving our Services.

We use your data to carry out our Site, App and Services in the following ways:

To administer and manage your account, to provide you with information you request from us, and to carry out any other obligations arising from any contracts entered into between you and us.

To ensure that content from our Site and App is presented in the most effective manner for you and for your device.

To allow you to participate in interactive features of our Service when you choose to do so.

To respond to communications from you and to provide you with information about our Services, including notifying you about changes to our Site, App or Services.

We also use your data to make our Site, App and Services better in the following ways:

To administer the Site and App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

As part of our efforts to keep the Site and App safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect your IT system.

Customers of ours, may have previously agreed to receive communications from us, or we are contact you for direct marketing on the basis of legitimate interest. If you would prefer to not receive these emails, or would like to object to receiving our direct marketing emails you can opt out at any time by emailing us at hello@gearingforgrowth.com

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

Once we have received your information, we use strict procedures and the security features described above to try to prevent unauthorised access.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements. For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers. In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Parties with whom we share your information

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Third parties include such platforms as Google Analytics to track and report website traffic, Facebook Analytics to measure the performance of our page, and our chosen Email Service Provider.

The only other circumstances under which we would share your personal data are:

If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

If the Company or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.

If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our Terms & Conditions and other agreements, or to protect the rights, property, or safety of the Company, our customers, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Parties with whom you may choose to share your information

If you choose to connect to social media networks from the our Site or App or post any of your content on our Site or App to those networks, then in accordance with your social media privacy settings, the personal information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other users of those networks and we have no control over such viewing and use and cannot prevent further use of such information by third parties. When you interact with us through social media networks, you acknowledge that we may access your information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any information posted via social media through our Site or App, or any third party you allow to access your content, is done entirely at your own risk and that by posting to a public platform you make that information visible to third-parties who can use that information at their discretion.

You may review, modify, update, correct or remove any personal data you have submitted to the Site or App at any time. If you remove information that you posted to the Site or App, copies may remain viewable in cached and archived pages of the Site, or if other users or third party APIs have copied or saved that information.

Always think carefully before disclosing personal data or other information to other users or otherwise posting personal data on the Site or App. It’s important that you’re aware that any data you choose to disclose on the Site or App may then be viewed and even used by other users (in accordance with your settings and this Privacy Policy). We do not control the contents of communications made between users (although you can make a complaint about another user by contacting us using the information provided in the Contact section below).

You must respect the privacy of others and you must not disclose any personal details about other people including your family, friends, acquaintances, or other persons that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior express permission in respect of any submission of their data at any time.

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or

Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at hello@gearingforgrowth.com

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 or refuse to comply with your request in these circumstances. 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. 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. If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to our Company Address or to our email at hello@gearingforgrowth.com.

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