Privacy Policy

 

This is the Privacy and Cookies Policy (the, or this “Policy”) of The Growth Stage Limited ("The Growth Stage", "we", "us" and "our"), company registration number 10833705, and registered office at 4th Floor, 18 St. Cross Street, London, EC1N 8UN, UK. We are committed to protecting the data privacy of third parties (including all users of our investment platform (the “Platform”), available at www.thegrowthstage.com (the "Website")). Please read the following Policy which explains how we use and protect your Personal Information.

 

We will only use information from which you can be identified, such as your name, contact details and ID data ("Personal Information") which is provided to us, or otherwise obtained by us, in accordance with this Policy. We will ensure that your Personal Information is handled in accordance with the law, including the following: (i) the Data Protection Act 2018; (ii) the UK General Data Protection Regulation (GDPR); (iii) the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR); and (iv) all similar or related data protection and privacy legislation relating to the processing of Personal Information in any relevant jurisdiction ("Data Protection Legislation").

 

According to the GDPR, you are considered a ‘data subject’ if you are a UK or EU visitor to our website and personal data concerning you is processed by us. For this reason, you can make use of various data subject rights which are laid out in the GDPR. These are the right to access information (Article 15 GDPR), the right to erasure (Article 18 GDPR), the right to object (Article 21 GDPR), the right to lodge a complaint with a supervisory authority (Article 77 GDPR) and the right to data portability (Article 20 GDPR). More information can be found in section 7 below.

 

By visiting and/or contacting us through the Website (or otherwise engaging with us), you acknowledge that we may collect, use and transfer your Personal Information as set out in this Policy. The Growth Stage reserves the right to change this Policy from time to time and you should therefore check this page regularly to ensure that you are happy with any changes.

 

For the purposes of the Data Protection Legislation, we are deemed to be the "data controller" in respect of any Personal Information that you provide to us or we otherwise obtain about you. We are registered with the Information Commissioner’s Office (“ICO”) under the Data Protection Register, our registration number is ZA300879.

 

This Policy covers:

1. Personal Information that we collect from you
2. Personal Information that we receive from other sources
3. What we do with your Personal Information
4. How we share your Personal Information
5. Our security measures and information about when we delete data
6. Transferring Personal Information outside of the UK and EEA
7. How you can access and updating your Personal Information
8. Complaints
9. Our use of cookies
10. Changes to our Privacy and Cookies Policy
11. Our contact information

 

1. PERSONAL INFORMATION THAT WE COLLECT FROM YOU

When you engage with us (e.g., sending us emails, contacting us via telephone or visiting or making an enquiry through the Website), you may provide Personal Information about yourself including your name and contact details (e.g., your address, email address and telephone number) and your job title. Where you make use of our Website, we may also collect information about your use of the Website or (e.g., your IP address and choice of web browser). Some of this Personal Information is collected and processed so we can perform a contract with you, some for the purpose of legal compliance and some for the purposes of our legitimate business interests (namely to carry out and improve our business, analyse the use of our Website and services and support our staff and clients). Please be aware that, in certain circumstance where you do not provide Personal Information, which is required by law or by us, we will not be able to provide the services under our contract with you or may not be able to comply with a legal obligation on us. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

 

2. PERSONAL INFORMATION THAT WE RECEIVE FROM OTHER SOURCES

We may receive information from third parties who collect Personal Information from you and pass it on to us. For example, a company seeking investment through the Website may provide Personal Information concerning its key personnel in reports about the company disseminated through the Website. Our staff may also give us emergency contact information as part of our emergency scenario planning and may give us details of their dependents and of other people in relation to their employee benefits arrangements. Where this is the case the third party is responsible for obtaining the relevant consents from you to ensure you are happy with the ways in which your Personal Information will be used.

 

3. WHAT WE DO WITH YOUR PERSONAL INFORMATION

We will only use your Personal Information in order to (a) supply the services you have requested and correspond with you, including providing you with a monthly newsletter, (b) allow other users of the Website to correspond with you in connection with any investment or related activities (to the extent you have consented to this), (c) provide support to you in respect of these services, (d) improve our Website and services, (e) for our internal business processes, including providing support to our staff and (f) where relevant, process any application for employment.

Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in section 1 above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third-party service provider of software/ applications that allows marketers to send out email marketing campaigns to a list of users. Email marketing messages that we send may contain tracking beacons/tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as times, dates, IP addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign. Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences/the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences. Our EMS providers are Salesforce and MailChimp.

We may also use your Personal Information to let you know about our services, and/or to inform you about important changes or developments to our Website, by post, telephone and/or e-mail. If you change your mind about us using your Personal Information in the ways described in this Policy, please let us know by contacting us at info@thegrowthstage.com. You may also opt out of receiving marketing emails from us by following the instructions outlined in the email.

 

4. HOW WE SHARE YOUR PERSONAL INFORMATION

Where it is necessary for the performance of our contract with you or for our internal business processes, or where you have expressly consented to this in connection with any investment or related activities, we may share your Personal Information with certain third parties, such as our advisors or other users of the Website. By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. The Growth Stage asks all third parties to treat your Personal Information securely and in accordance with this Policy and will take reasonable steps to enforce this. We will never sell your data.

In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose your Personal Information in order to comply with any legal obligation (such as anti-money laundering obligations), carry out an internal investigation, enforce our Terms and Conditions (set out when you log into www.thegrowthstage.com) and any other agreement, or protect the rights, property, or safety of The Growth Stage and our clients, directors, employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention.

 

5. OUR SECURITY MEASURES AND INFORMATION ABOUT WHEN WE DELETE DATA

We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required. We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as the Data Protection Legislation allows.

Where you have chosen a password, which allows you to access certain parts of the Website, such as our TGS platform, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

Unfortunately, the transmission of information via the internet is not completely secure and, although we will take steps to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via the Website, any transmission is therefore at your own risk.

 

6. TRANSFERRING PERSONAL INFORMATION OUTSIDE OF THE UK AND EEA

The Personal Information you provide to us will be transferred to and stored on third party servers in London, UK. We take steps to protect your Personal Information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.

In processing your Personal Information, it will sometimes be necessary for us to transfer your Personal Information outside the UK and European Economic Area ("EEA") to our staff and our third-party service providers. It may also be accessed by staff operating outside the UK and EEA who work for us or for one of our suppliers or group companies. This includes people engaged in, among other things, the provision of support services to us. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and the Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the UK and EEA. This means that we will only transfer your Personal Information to our non-UK and non-European offices and to third parties based outside the UK and EEA if that party (a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to Personal Information or (b) has agreed (by way of written contract) to provide all protections to your Personal Information as required by the Data Protection Legislation.

 

7. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

You have the right to ask us not to process your Personal Information for marketing or research purposes. We will usually inform you (before collecting your Personal Information) if we intend to use your Personal Information for such purposes or if we intend to disclose your Personal Information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Information. You can also exercise the right at any time by contacting us at the details set out at section 11 below.

You have the right to see the Personal Information we hold about you and to ask us to: (a) make any changes to ensure that any Personal Information we hold about you is accurate and up to date; (b) erase or stop processing any Personal Information we hold about you where there is no longer a legal ground for us to hold it; or (c) in some cases transfer any information we hold about you to a specified third party. If you wish to do this, please contact us at info@thegrowthstage.com. This may limit the service we can provide to you. We remind you that we are not obliged by law to delete your Personal Information or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

The law also requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

 

8. COMPLAINTS

Should you have any queries or complaints in relation to how we use your Personal Information, please contact us at info@thegrowthstage.com. If a query or complaint is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration. Should you wish to take any complaints or queries further, you have the right to contact the ICO (www.ico.org.uk) regarding such issues. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

Our Website may, from time to time, contain links to and from third party websites. 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 websites or their related policies. Please check these policies before you submit any Personal Information via these websites.

 

9. OUR USE OF COOKIES

A cookie is a small file that is sent to your browser from a web server and is stored on your computer. Cookies help us to analyse web traffic and identify which pages of our Website are being used. Our Website also uses cookies to respond to you as an individual so that it can tailor its operations to your needs by gathering and remembering information about your preferences as well as enabling you to login to and use our Website. We only use this information for statistical analysis and authentication - then your Personal Information is removed from our systems.

A cookie in no way gives us access to your computer or any information about you, other than information about how you use the Website and the Personal Information you choose to share with us (including Personal Information you automatically share with us by way of your browser settings).

We only use some strictly necessary cookies (as set out in out the table below). These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas.

You will normally see a message on our Website before we store a cookie on your computer which describes the types of cookies we use and what information they might collect. We may also use banners and pop-ups from time to time to give you options around cookies use.

You can also manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies) and your browser provider may ask you to confirm your settings. Note, however, that if you block all cookies (including essential cookies) via your browser settings you may not be able to access all or parts of our Website.

You can find more information about the specific cookies we use and the purposes for which we use them in the table attached to this Policy. You can also find more information about cookies generally at www.allaboutcookies.org

We also use some cookies that do not collect personal information but that do help us collect anonymous information about how people use our Website. We use Google Analytics for this purpose.  Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users' computers. The information collected by Google Analytics about usage of our Website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google's privacy policy is available at www.google.com/privacypolicy.html

Please note that third party providers may also use cookies to assess the ways in which you make use of their websites and we have no control over these.

 

10. CHANGES TO OUR PRIVACY AND COOKIES POLICY

The Growth Stage may amend this Policy at any time without notice. By continuing to use the Website and making use of our services you agree to the updated Policy. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) the Website and/or use our services. Any changes to this Policy will be posted on the Website.

 

11. OUR CONTACT INFORMATION

If you have any questions, please feel free to contact us by email at info@thegrowthstage.com

 

 

OUR COOKIES:

Necessary Cookies
Name:              Description/Purpose:                                                                Duration:
has_js	Internal Drupal cookie used to determine if your browser is able to run JavaScript		Session
SSESS {token}	Internal Drupal cookie. Created when you log in, used to identify and authorise users. {token} may vary to improve the security.		23 days
AWSALB AWSALBCORS	Registers which server-cluster is serving the visitor. This is used in context with load balancing, in order to optimise user experience.		6 days

© THE GROWTH STAGE LIMITED, MARCH 2021