We are Growth Mentality. We’re a company registered in England and Wales with company number 13941334, whose registered address is 17 Halden Close, Romsey, Hampshire, United Kingdom, SO51 7TS. In this privacy notice we will refer to ourselves as ‘we’, ‘us’ or ‘our’.

We are the Data Controller of the Personal Information we collect, hold, and use about you, as explained in this notice. You can contact us in any of the following ways:

by emailing us at matthew.vamplew@growthmentality.co.uk

We take the privacy, including the security, of Personal Information we hold about you seriously. This privacy notice tells you how we collect Personal Information about you and how we use that Personal Information.

You should read this privacy notice carefully so that you know and can understand why and how we use the Personal Information we collect and hold about you .We do not have a data protection officer but if you have any questions about this privacy notice or issues arising from it, you should contact Matthew Vamplew, who is responsible for matters relating to data protection at our organisation, including any matters in this privacy notice. You can contact them using the details set out above.

We may update this privacy notice from time to time. This version was last updated on 15th March 2025.

1. Key definitions

1.1 The key terms used in this privacy notice are defined below, for ease:

1.2  Data Controller: the organisation or person responsible for deciding how Personal Information is collected, stored and used.
1.3 Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks on its behalf in relation to the Personal Information. (This may include hosting of a site containing Personal Information, for example, or providing an email marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer base).
1.4 Personal Information: any information from which a living individual can be identified. It does not apply to information that has been anonymised.
1.5 Special Information: certain very sensitive Personal Information requires extra protection under data protection law. Sensitive data includes information relating to health, racial and ethnic origin, political opinions, religious and similar beliefs, trade union membership, sex life, and sexual orientation. It also includes genetic information and biometric information.

2. Details of Personal Information that we collect and hold about you

2.1 Set out below the categories and details of retention periods in relation to data areas, in each case, the types of Personal Information that we collect, use, and hold about you.

Identity Information. Includes details such as name (including previous names and titles), gender, marital status, and date of birth.  Retention period: Data is kept only as long as necessary, following the principle of "storage limitation".

Contact Information.  Includes details such as email address, addresses, and phone numbers.  Retention period: Data is kept only as long as necessary, following the principle of "storage limitation".

Payment Information. Covers methods of payment, such as bank account details, credit or debit card details, and payment history (including amounts and dates). Retention period: Data is kept only as long as necessary, following the principle of "storage limitation".

Transaction Information. Includes details of transactions, such as goods, services, and/or digital content provided, as well as return details.  Retention period: Data is kept only as long as necessary, following the principle of "storage limitation".

Marketing Information. Relates to marketing and communication preferences.  Retention period: Data is kept only as long as necessary, following the principle of "storage limitation".

Website, Device, and Technical Information. Includes website usage and technical data such as IP address, browser type and version, operating system, time zone and location settings, and other device-related data.  Retention period: Data is kept only as long as necessary, following the principle of "storage limitation".

2.2 We will only hold your Personal Information for as long as is necessary. How long is necessary will depend upon the purposes for which we collected the Personal Information and whether we are under any legal obligation to keep the Personal Information (for example, in relation to accounting or auditing records, or for tax reasons). We may also need to keep Personal Information in case of any legal claims, including in relation to any guarantees or warranties that we have provided with the services.

2.3 The types of Personal Information we collect about you may differ from person to person, depending on who you are and the relationship between us.


3. Details of Special Information that we collect and hold about you

3.1 Special Information is explained in Section 1 above.
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3.2 We do not collect or hold any Special Information about you. We do not collect information from you relating to criminal convictions or offences.

4. Details of how and why we use Personal Information

4.1 We are only able to use your Personal Information for certain legal reasons set out in data protection law. There are legal reasons under data protection law other than those listed below; but, in most cases, we will use your personal information for the following legal reasons:

-Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you;
- Legitimate Interests Reason: this is where the use of your Personal Information is necessary for our (or a third party’s) legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms, or interests;
- Legal Obligation Reason: this is where we have to use your Personal Information in order to perform a legal obligation by which we are bound; and
- Consent Reason: this is where you have given us your consent to use your Personal Information for a specific reason or specific reasons.

4.2 So that we are able to provide you with services, we will need your Personal Information. If you do not provide us with the required Personal Information, we may be prevented from supplying the services to you.

4.3 It is important that you keep your Personal Information up to date. If any of your Personal Information changes, please contact us as soon as possible to let us know. If you do not contact us to keep your information updated, we may be prevented from supplying the services to you. (For example, if you change address and do not tell us, your goods may be delivered to the wrong address).

4.4 Where we rely on consent for a specific purpose as the legal reason for processing your Personal Information, you have the right under data protection law to withdraw your consent at any time. If you wish to withdraw your consent, please contact us using the details set out at the beginning of this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your Personal Information for that purpose unless we have another legal reason for processing your Personal Information, in which case we will confirm that reason to you.

4.5 We explain  below the different purposes for which we use your Personal Information and, in each case, the legal reason(s) allowing us to use your Personal Information. Please also note the following:

-if we use the Legitimate Interests Reason as the legal reason for which we can use your Personal Information, we have also explained what that legitimate interest is; and
- for some of the purposes, we may have listed more than one legal reason on which we can use your Personal Information, because the legal reason may be different in different circumstances. If you need confirmation of the specific legal reason that we are relying on to use your personal data for that purpose, please contact us using the contact details set out at the start of this privacy notice.

To register you as a customer – Legal reason: Legitimate Interests (to offer other goods, services, and/or digital content to develop the business).
‍To process your order, including taking payment, providing updates, or enforcing payment recovery – Legal reason: Legitimate Interests (to recover money owed).
‍To manage our contract with you and notify you of any changes – Legal reason: Legal Obligation.To comply with audit and accounting matters – Legal reason: Legal Obligation.
‍To improve the goods, services, and/or digital content we supply – Legal reason: Legitimate Interests (to improve offerings for future customers and grow the business).
‍To recommend and send communications about goods, services, and/or digital content that may interest you – Legal reason: Legitimate Interests (to grow the business).
‍To ensure the smooth running and correct operation of our website – Legal reason: Legitimate Interests (to ensure the website functions correctly).
‍To analyze customer interactions with the website and improve user experience – Legal reason: Legitimate Interests (to improve and grow the business and understand customer needs).

4.6 Use of Anonymized and Statistical DataWe may anonymize information you provide so that you can no longer be identified and use it for our own purposes.We may combine your information with others' to generate statistical data.Since this data is grouped and non-identifiable, we can use it freely.

4.7 Use of Personal InformationUnder data protection law, we can only use your Personal Information for the purposes stated.If a new purpose arises:We assess its compatibility with the original purpose.If it is incompatible, we will notify you and provide a supplementary privacy notice.

5. Collection of Personal and Special Information

5.1 Direct CollectionWe collect identity, contact, payment, and transaction information when you:Purchase goods, services, and/or digital content.Contact us via email, phone, or writing.Subscribe to our mailing list.

5.2 Collection from Third Parties and Public SourcesWe may receive your Personal Information from:Selected data brokers (e.g., LinkedIn – identity and contact information).Public sources (e.g., Companies House – identity and contact information).Analytics providers (e.g., Google – website, device, and technical information).

6. Sharing of Personal InformationWe may need to share your Personal Information with:Third parties, including:IT support services, payment providers, administration providers, marketing agencies.Government and regulatory bodies (e.g., HMRC, fraud prevention agencies).Advisers (e.g., lawyers, accountants, auditors, insurance companies).Credit reference agencies.Email platforms.Potential purchasers of our business and assets.

6.1 Data Processors vs. Data ControllersDepending on the circumstances, recipients of your data will act as:Data Processors – We ensure contracts outline security and responsibility.Data Controllers – They independently decide how to use your data.

6.2 No Sale of Personal InformationWe do not sell or trade your Personal Information.

7. Data Transfers Outside the EEAWe do not transfer your Personal Information outside the EEA.

8. Your Rights Under Data Protection LawRight to access – Obtain a copy of your Personal Information and related details.Right to correction – Request corrections or completion of incomplete data.Right to erasure ("right to be forgotten") – Request deletion (applies in certain cases).Right to restrict processing – Request restriction of processing (applies in certain cases).Right to data portability – Request transfer of your data to another party.Right to object – Object to:Processing for direct marketing.Processing based on Legitimate Interests if it affects you.Profiling (including for direct marketing).

8.1 Exercising Your RightsTo exercise your rights, contact us using the details in this notice.We may:Require verification of your identity.Charge a fee only if requests are excessive or unfounded.Refuse requests that are excessive or unfounded.

9. Marketing PreferencesYou may receive marketing communications if:You have consented.We have another legal basis to contact you.Managing marketing preferences:Every email includes an unsubscribe or preference link.You can contact us to stop marketing communications.Opting out of marketing will not stop non-marketing service communications.We do not share your Personal Information with third parties for marketing.

10. ComplaintsIf unhappy with our handling of your Personal Information, you can:Contact us first to resolve the issue.Complain to the UK Information Commissioner’s Office (ICO) if necessary.

11. Third-Party WebsitesOur website may contain links to third-party websites.If you click on them:You will be subject to their privacy policies.We are not responsible for their data collection practices.