Privacy Policy 

1. Who we are 

This Privacy Policy explains how personal data is collected and used by: 

OBT Synergy Ltd, a company registered in England and Wales, 
Registered office: 7 Ledbury Drive, Crewe, CW2 6SL, United Kingdom, 
Trading as Growvation. 

This policy applies to our website growvation.org and to all services provided under the Growvation brand. 

2. How to contact us about privacy 

If you have any questions about this policy or how we use personal data, you can contact us at: 

Email: [email protected] 

We use a role‑based contact rather than naming an individual. Privacy‑related complaints and enquiries are handled through the same contact route. 

3. Our regulatory position 

We are a UK‑based professional services business. Our initial focus is the United Kingdom, with planned international activity over time. We may process personal data relating to individuals outside the UK, including in the EU, where this is necessary to deliver our services. 

We do not knowingly process personal data relating to children under the age of 16. 

4. Personal data we collect 

We collect personal data directly from you and indirectly through third parties, depending on how you interact with us. 

4.1 Data you provide directly 

This includes personal data collected through: 

• Website contact forms 
• Newsletter or waitlist sign‑ups 
• Account creation or gated downloads 
• Discovery calls or advisory sessions 
• Client delivery and consultancy work 
• Partner referrals 
• Events or webinars 
• Invoicing and contractual arrangements 
• Recruitment or associate onboarding 

The types of data may include names, contact details, professional information, communications, and information necessary to provide our services. 

4.2 Data we collect indirectly 

We may also collect personal data through: 

• LinkedIn interactions or scraping tools 
• CRM imports from partners 
• Purchased or licensed contact lists 
• Analytics and website usage tools 

5. Lawful bases for processing 

We process personal data only where we have a lawful basis to do so. Depending on the context, this may include: 

• Consent – where you have explicitly agreed 
• Contract – where processing is necessary to deliver services 
• Legitimate interests – where processing supports our business activities and does not override your rights 
• Legal obligation – where we are required to process data by law 

The lawful basis used depends on the purpose for which the data is collected. 

6. Cookies and tracking technologies 

We use cookies and similar technologies on growvation.org. 

• We do not use cookies beyond those required for essential website functionality without consent 
• A cookie consent banner is used where required 
• Users can manage their cookie preferences through the banner 

We use the following tools: 

• Google Analytics 
• Microsoft Clarity 
• Facebook tools 
• Go High Level 

These tools help us understand how our website is used and improve performance and relevance. 

7. Data storage and processing 

Personal data is stored and processed using the following primary systems: 

• Microsoft 365 
• SharePoint 
• Go High Level 

We do not intentionally use non‑UK or non‑EEA data processors. 

We also use AI‑enabled tools, including Microsoft Copilot and Azure OpenAI services, which may process personal data as part of productivity, analysis, or service delivery activities. These tools are used within managed environments designed to protect data confidentiality. 

8. Sharing personal data 

We do not sell or rent personal data. 

We may share personal data: 

• With partners or advisors, only where there is a formal co‑branded or delivery relationship 
• Where necessary to deliver services you have requested 
• Where required by law 

Client details may appear in case studies or marketing materials only where we have explicit written permission. 

9. Data retention 

We do not currently maintain a formally documented data retention schedule. 

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, including legal, contractual, accounting, or regulatory requirements. When data is no longer required, it is securely deleted or anonymised using standard, defensible UK‑GDPR compliant practices. 

10. Your data protection rights 

You have rights under UK GDPR, including the right to: 

• Access your personal data 
• Request correction of inaccurate data 
• Request erasure of data 
• Restrict or object to processing 
• Request data portability 
• Withdraw consent where applicable 

We provide a simple contact route for exercising these rights. Requests can be made by emailing [email protected]. We may need to verify your identity before responding. Requests will be handled within statutory time limits. 

11. Data security 

We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or disclosure. Access to personal data is restricted to those who need it for legitimate business purposes. 

12. Changes to this policy 

We may update this Privacy Policy from time to time to reflect changes in law, regulation, or our business practices. The latest version will always be published on growvation.org. 

13. How to raise concerns 

If you have concerns about how we handle personal data, please contact us first at [email protected]. 

You also have the right to raise a complaint with the UK Information Commissioner’s Office (ICO).