How Growvation uses your personal information
This Privacy Policy explains what personal information we collect, where it may come from, why we use it, who may process it on our behalf, how long we keep it and the rights you have under UK data protection law.
The organisation responsible for your information
Growvation is the trading name of OBT Synergy Ltd.
OBT Synergy Ltd is the data controller for personal information collected through the Growvation website, through direct communications with Growvation and for professional contact information that Growvation lawfully obtains and uses for its business activities.
OBT Synergy Ltd
Trading as Growvation
Registered office: 7 Ledbury Drive, Crewe, CW2 6SL, United Kingdom
Registered in England and Wales
Company number: 12469667
General enquiries:
[email protected]
Privacy and data protection enquiries:
[email protected]
We collect information relevant to the purpose
Depending on how you interact with Growvation, we may hold:
- Your name.
- Your email address.
- Your telephone number, where provided.
- Your organisation, job title and professional role.
- Your LinkedIn profile address and professional profile information where relevant.
- Information about an existing professional connection or relationship with Growvation or one of its founders.
- Information you provide about a broad decision, client situation or enquiry.
- Communication history, agreed next steps and relationship-management notes.
- Internally assigned categories relevant to professional or adviser fit, relationship strength or business relevance.
- Technical information generated when you use the website or submit a form, which may include date, time, device, browser, IP address and timezone information.
Please do not send unnecessary confidential or sensitive information
Our initial enquiry and contact processes are not intended for confidential client documents, special category personal data, sensitive personal information or detailed internal business records. If further information becomes relevant to an agreed engagement, its purpose and appropriate handling should be established first.
A filtered subset of existing first-degree LinkedIn connections
Growvation may import into its customer relationship management system a filtered subset of existing first-degree LinkedIn connections of Growvation's founders.
Our current process is limited to selected existing first-degree connections considered potentially relevant to Growvation's professional adviser-led route to market, business relationships or related professional engagement.
The information may include:
- name;
- LinkedIn profile address;
- job title or professional role;
- organisation or employer;
- professional information visible to us through the LinkedIn connection;
- the fact that an existing first-degree connection exists; and
- internal relationship, relevance or adviser-fit notes created by Growvation.
The source of this information is LinkedIn and the existing professional connection through which the information is made available to us. Some profile information may also be publicly visible on LinkedIn.
How we provide privacy information to imported contacts
Where we obtain personal information from LinkedIn rather than directly from you, we will take reasonable steps to make this Privacy Policy available to you within the period required by UK data protection law and, where we use that information to contact you, no later than the first relevant communication where required.
Purposes and lawful bases
UK data protection law requires us to have a lawful basis for each use of personal information.
| Purpose | How we use the information | Lawful basis |
|---|---|---|
| Responding to enquiries | To review your enquiry, contact you, understand the situation and agree an appropriate next step. | Legitimate interests in responding to genuine business enquiries and managing professional relationships; and, where applicable, taking steps at your request before entering into a contract. |
| Managing existing professional relationships | To maintain appropriate records of existing professional contacts, conversations, introductions and agreed next steps. | Legitimate interests in maintaining and developing relevant professional and business relationships. |
| Identifying relevant professional contacts | To review a filtered subset of existing first-degree LinkedIn connections and identify contacts who may be relevant to Growvation's adviser-led route to market or professional network. | Legitimate interests in developing Growvation's business through relevant existing professional relationships, subject to an appropriate balance against individual rights and expectations. |
| Relevant professional outreach | Where appropriate and lawful, to contact selected existing professional connections about Growvation, a relevant adviser proposition, a business situation or another professional matter. | Legitimate interests where appropriate under UK GDPR. Where a communication constitutes direct marketing, additional UK electronic communications rules are applied where required. |
| Managing adviser or client conversations | To record agreed actions, maintain appropriate contact and continue a conversation that you have asked us to pursue. | Legitimate interests and, where applicable, contract or pre-contractual steps. |
| Operating and protecting our systems | To operate our website, CRM, forms, email and related systems, investigate problems and maintain appropriate business records. | Legitimate interests in operating, administering and protecting our business and systems. |
| Legal and regulatory obligations | To comply with applicable laws, respond to lawful requests and maintain records where required. | Legal obligation and, where appropriate, legitimate interests. |
| Data protection rights and complaints | To respond to rights requests, investigate data protection complaints and maintain appropriate records of our response. | Legal obligation. |
Where we rely on legitimate interests, we consider the purpose of the processing, whether the processing is necessary and whether our interests are appropriately balanced against your rights, interests and reasonable expectations.
A LinkedIn connection does not automatically mean marketing consent
Growvation may contact selected existing professional connections where there is a reasonable relationship or business context for doing so.
Some communications may constitute direct marketing under UK law. Where this applies, we comply with the applicable UK GDPR and Privacy and Electronic Communications Regulations requirements.
The rules can differ depending on the communication method and whether the recipient is a corporate subscriber, an individual, a sole trader or another type of organisation.
We do not treat an existing LinkedIn connection, inclusion in our CRM or submission of a website enquiry as automatic consent to receive electronic marketing.
Your right to object to direct marketing
You can ask us at any time to stop using your personal information for direct marketing.
If you object, we will stop using your information for that purpose. We may retain a minimal suppression record so that your preference can continue to be respected.
Submitting an enquiry does not sign you up for marketing
We may use the contact details you provide to respond to your enquiry and follow up on agreed next steps.
Administrative or enquiry-related communications will remain focused on the enquiry or agreed next step and are not treated by Growvation as permission for unrelated promotional communications.
Access is limited to people and service providers with a relevant purpose
Personal information may be accessed by authorised members of the Growvation team where necessary to manage an enquiry, professional relationship or relevant business contact.
We also use service providers that process information on our behalf, including:
- HighLevel / GoHighLevel — website, forms, customer relationship management, contact records, conversations and related workflow services.
- Microsoft 365 — business email, shared mailbox, communications and related productivity services.
Imported professional contact information from LinkedIn may therefore be stored in HighLevel as part of Growvation's contact and relationship-management records.
We may also disclose information where required by law, to protect legal rights, or where disclosure is otherwise permitted under applicable law.
Some technology providers process information outside the UK
Growvation operates in the United Kingdom, but some technology providers used by Growvation operate internationally.
HighLevel is headquartered in the United States and its services and subprocessors may involve processing outside the UK, including in the United States and India.
Microsoft also operates an international service infrastructure and may process information outside the UK in connection with providing Microsoft 365 services.
Where UK personal information is transferred outside the UK and UK law requires additional safeguards, the relevant provider's contractual arrangements use applicable transfer mechanisms such as UK adequacy arrangements, the UK International Data Transfer Addendum or other legally recognised safeguards.
Contact [email protected] if you would like further information about the safeguards relevant to our principal service providers.
We keep personal information only for as long as it remains necessary
The appropriate retention period depends on the reason we hold the information.
When deciding how long information should be kept, we consider:
- whether an enquiry or professional relationship remains active;
- whether a LinkedIn-derived professional contact remains relevant to a legitimate business purpose;
- whether there has been any meaningful interaction or agreed next step;
- any applicable contractual, accounting or legal requirements;
- whether records are required to establish, exercise or defend legal rights;
- whether records are required to demonstrate a data protection request, complaint or marketing objection; and
- whether the information can instead be securely deleted or anonymised.
Imported professional contacts will not be retained indefinitely solely because a LinkedIn connection exists.
Where an individual objects to direct marketing, we may retain a minimal suppression record to ensure that the objection continues to be respected.
Cookies and similar technologies
The Growvation website currently uses essential cookies only. More information is provided in our Cookie Policy.
Technology may support analysis, but material decisions remain human
Growvation may use technology to organise, filter or review professional contact information and to support internal relationship-management activity.
We may also use AI-enabled tools in parts of our wider evidence and business operations.
We do not currently use LinkedIn-derived contact information or website enquiry information to make a decision about you based solely on automated processing that produces legal or similarly significant effects.
Rights available under UK data protection law
Depending on the circumstances and the lawful basis being used, you may have rights including:
- the right to be informed about how your information is used;
- the right to request access to your personal information;
- the right to ask us to correct inaccurate or incomplete information;
- the right to ask for information to be erased in certain circumstances;
- the right to ask us to restrict processing in certain circumstances;
- the right to object to processing based on legitimate interests;
- the absolute right to object to processing for direct marketing;
- the right to data portability where the legal conditions apply; and
- the right to withdraw consent where a particular activity relies on consent.
To exercise a data protection right, contact [email protected].
Your right to object
Where we rely on legitimate interests, you may object to the processing based on your particular situation.
If your objection relates to direct marketing, the right to object is absolute and we will stop processing your information for that purpose.
How to raise a concern
If you believe Growvation has not handled your personal information in accordance with data protection law, you may make a data protection complaint directly to us.
Email [email protected] and make clear that your message is a data protection complaint.
We will acknowledge receipt of a data protection complaint within 30 days, take appropriate steps to investigate it, keep you informed where appropriate and communicate the outcome without undue delay.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data protection regulator.
We encourage you to contact Growvation first where appropriate so that we have an opportunity to understand and address your concern.
Access and appropriate safeguards
We seek to limit access to personal information to people who have a relevant business reason to use it and use business technology providers that provide contractual data protection commitments.
No method of electronic storage or transmission can be guaranteed to be completely secure. If we identify a personal data breach, we will assess and respond to it in accordance with applicable UK data protection law.
Keeping our privacy information current
We may update this Privacy Policy when our processing, technology, services, professional contact activities or legal obligations change.
Where a change materially affects how we use personal information, we will provide appropriate information before introducing the new use where required by law. The date at the top of this page shows when this policy was last updated.
Privacy and data protection enquiries
Growvation / OBT Synergy Ltd
Privacy email:
[email protected]
General enquiries:
[email protected]
Registered office:
7 Ledbury Drive
Crewe
CW2 6SL
United Kingdom