Privacy Notice

Welcome to the Privacy Notice of Atomic Flow Limited trading as Growth Society (“we”, “our”, or “us”).

We are a company registered in England and Wales. Our company number is 11249713 and our registered office is Department, 4, The Boulevard, Leeds, England, LS10 1PZ.

1. Introduction

This notice describes how we collect, store, transfer and use personal data. It explains your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Processing personal data refers to any action performed on it.

Except as set out below, we do not share, sell, or disclose any information collected through our website to third parties.

2. How we obtain personal data

We collect Personal Data from various sources depending on the nature of our interactions. This includes:

Website users. Personal Data is collected through interactions on our website, such as form submissions and engagement with site features.
Clients. Personal Data is gathered during transitions, service engagements or communications related to purchases and service use.
Employees. Personal Data is collected as part of employment processes, including performance evaluations and administrative functions.
Freelancers. Personal Data is collected for contract management, work-related interactions and payment processing.
Third party suppliers. Personal Data is collected through business transactions, service agreements and interactions with external partners.

3. Types of personal data we collect directly

When you use our website, engage with our services, make a purchase from us, are employed by us or work as a third-party supplier, we may ask you to provide Personal Data such as:

Personal identifiers (e.g. your first and last names, title, and date of birth).
Contact information (e.g. your email address, telephone number, and postal addresses for billing, delivery, and communication).
Gender and pronoun preferences.
Occupation.
Payment information (e.g., debit or credit card number, expiry date, and bank account details).
Records of communication between us (e.g., messages sent through our website, email messages, and telephone conversations).
Marketing preferences indicating the types of marketing you would like to receive.
Video recordings, audio recordings, records of meetings and decisions
Account access information
Website user information
Employment details (including salary, sick pay and length of service)
Business information, including your business trading name and address, company number (if incorporated) and VAT number (if registered).
Information you contribute to our community, including reviews.
Your replies to polls and surveys.
Technical information about the hardware and software you use to access our website and services, including your IP address, browser type and version and your device’s operating system.
Usage information, including the frequency of service use, pages visited on our website, receipt of our messages and your responses.
Transaction information, including details of products/services bought and payments made.
Your preferences for receiving marketing from us, how you wish to communicate with us and responses and actions related to your service use.

4. Our use of aggregated data

We may aggregate anonymous data, such as statistical or demographic data, for any purpose. Aggregated data does not identify you as an individual so is not considered to be your Personal Data. If aggregated data is combined with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as your Personal Data which will be used in accordance with this Privacy Notice.

5. Failure to provide necessary Personal Data

If required Personal Data is not provided when requested, we may not be able to perform the contract with you. In such cases, we may have to stop providing a service to you. We will notify you of this at the time.

6. Your rights in respect of your Personal Data

Under UK data protection laws, we must have a “lawful basis” for collecting and using your Personal Data. There is a list of possible lawful bases in the UK General Data Protection Regulation (“UK GDPR”). You can find out more about lawful bases on the Information Commissioner’s Office (“ICO”) website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

Right of access. You have the right to ask us for copies of your Personal Data. You can request other information such as details about where we get Personal Data from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here
Right to rectification. You have the right to ask us to correct or delete Personal Data you think is inaccurate or incomplete. You can read more about this right here.
Right to erasure. You have the right to ask us to delete your Personal Data. You can read more about this right here.
Right to restriction of processing. You have the right to ask us to limit how we can use your Personal Data. You can read more about this right here.
Right to object to processing. You have the right to object to the processing of your Personal Data. You can read more about this right here.
Right to data portability. You have the right to ask that we transfer the Personal Data you gave us to another organisation, or to you. You can read more about this right here.
Right to withdraw consent. When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you wish to exercise any of the rights set out above, please contact us at will@growthsociety.co.uk. 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. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity. This is a security measure also in your own interest 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 1 month. Occasionally it could take us longer than 1 month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

7. Lawful bases for processing Personal Data

The below table outlines the lawful bases for collecting and using Personal Data, including the purposes for each basis and any exceptions to your data protection rights.

Purpose: Providing and improving products and services.
Lawful basis: Legitimate interests.
Explanation: We collect/use Personal Data to improve our products or services. All of your data protection rights may apply, except the right to portability.

Purpose: Operation of client or customer accounts.
Lawful basis: Contract.
Explanation: We collect/use Personal Data to enter into a contract with you. All of your data protection rights may apply except the right to object.

Purpose: Providing and improving products and services.
Lawful basis: Legitimate interests.
Explanation: We collect/use Personal Data to improve our products or services. All of your data protection rights may apply, except the right to portability.

Purpose: Information updates or marketing.
Lawful basis: Consent.
Explanation: We collect/use Personal Data with your permission after providing relevant information. All of your data protection rights may apply except the right to object. You can withdraw consent at any time.

Purpose: Research or archiving purposes.
Lawful basis: Legitimate interests.
Explanation: We collect/use Personal Data to improve business operations without undue harm to anyone. All of your data protection rights may apply except the right to portability.

Purpose: Compliance with legal requirements.
Lawful basis: Legal obligation
Explanation: We collect/use Personal Data to comply with the law. All of your data protection rights may apply except for the right to erasure, the right to object and the right to data portability.
Purpose: Recruitment purposes.
Lawful basis: Contract. Legal obligation.
Explanation: We collect/use Personal Data to enter into an employment contract with you and to comply with the law. All of your data protection rights may apply except for the right to erasure, the right to object and the right to data portability.

Purpose: Dealing with queries, complaints or claims.
Lawful basis: Legitimate interests.
Explanation: We collect/use Personal Data to resolve queries, complaints or claims in the best interests of all parties involved. All of your data protection rights may apply except the right to data portability.

8. How your Personal Data is shared

Organisations we’re legally obliged to share Personal Data with.
Suppliers and service providers including external marketing specialists and marketing agencies.
Professional advisors including lawyers, auditors and accountants.

9. How long your Personal Data is retained

We will only keep your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.

10. Information obtained from third parties

We may receive data indirectly composed of your personal data from third parties whose services we use.

12. Third-party advertising on our website

Third parties may advertise on our website and use technology to collect information about you. We do not control these technologies or the data they collect.

13. Referral partners

We may collect information from affiliates or referral partners to recognise visitors referred to us and credit commissions.

14. Use of our services by children

We do not market to or sell products/services for children. If under 18, you may use our website only with parental or guardian consent.

15. Encryption of data sent between us

We use Secure Sockets Layer ("SSL") certificates to encrypt data transferred between us, ensuring security.

16. Data may be transferred outside the UK

Whenever your Personal Data travels outside of the UK and/or the European Economic Area (“EEA”), we ensure that it is protected by putting in place one of the following safeguards:

We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data as endorsed by the ICO and identified and determined by the European Commission.
We will only transfer your Personal Data where we have entered into specific contracts with an organisation outside of the UK and/or the EEA which states that they will ensure that your Personal Data has the same level of protection as if it were in the UK and/or the EEA.

17. Complaining

If you are unhappy with our Privacy Notice or have a complaint, please contact us at will@growthsociety.co.uk. We aim to resolve complaints but you may also contact the ICO at https://ico.org.uk/make-a-complaint/.