Privacy Policy

Privacy Policy
Thank you for your interest in this Privacy Policy! We, Growe Global Limited, (hereinafter “Growe Global”, “Growe”, “Growe SAP”, “Growe Greentech”, “Growe Lifesciences”, “Growe Technology”, “we”, “us”, or “our”) are committed to protecting and respecting your privacy when you use our website at www.growe-global.com and our Services. 
 
In principle, we will only use your personal data in accordance with applicable data protection laws, in particular the UK`s Data Protection Act (“DPA”), the General Data Protection Regulation (“GDPR”), and only as described in this privacy policy.

What is Personal Data?
Personal data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not personal data. This includes, for example, the number of users of a website.

Responsible for data processing
Responsible for data processing is:

Growe Global Limited

128 City Road, London,
EC1V 2NX, UK
Web: www.growe-global.com
E-Mail: info@growe-global.com
LinkedIn

General information on data processing
 

a)  international data transfer

In the course of our business and website operations, we process data. This also includes disclosure by transmission to third parties and, where applicable, to so-called third countries outside the UK and the EEA. Where we transfer data outside the UK or the EEA, we make sure to use the necessary and appropriate safeguards to ensure that the security of your personal data is maintained and guaranteed. In particular those include standard contractual clauses, binding corporate rules and data processing agreements. If you have any questions relating to our third-party providers, please refer to their relevant Privacy Policies or contact us for further details.

b)   the legal bases of processing

All personal data that we obtain from you via the website will be processed for the purposes described in more detail below. This is done within the framework of the DPA and the GDPR or with your consent. In particular, we process personal data only when processing is permitted and if:

• you have given your consent,

• the data is necessary for the fulfilment of a contract / pre-contractual measures,

• the data is necessary for the fulfilment of a legal obligation or

• the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.

 

c)   your data subject rights

The following rights are available to you as a data subject:

• the right to information,

• the right to rectification,

• the right to erasure,

• the right to restriction of data processing,

• the right to data portability,

• the right to object to data processing,

• the right to revoke any consent you have given, and

• the right to lodge a complaint with the competent supervisory authority.

 

Please contact us at any time with questions and suggestions regarding data protection and/or to enforce your rights, using info@growe-global.com
 

d)   exercising your rights

If you wish to access your personal data or exercise any of the rights listed above, you should apply in writing, providing evidence of your identity. Any communication from us in relation to your rights as detailed above will be provided free of charge. However, in case of requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or refuse to act on the request.
 

e)   Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please contact us.
 

f)   the competent supervisory authority 

The Information Commissioner`s Office (ICO) is the relevant authority in the UK. The ICO is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK (www.ico.org.uk). If you believe that the processing of your personal data is not lawful, you can lodge a complaint with a data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach any Supervisory Authority.

 

g)    storage and retention of your data 

We process and store your personal data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period (in particular commercial and tax law) exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

 

h)   security 

We use State-of-the-art internet technologies to ensure the security of your data. For secure storage of your data, the systems are protected by firewalls that prevent unauthorised access from outside. In addition, technical and organisational security measures are used to protect the personal data you have provided against accidental or intentional manipulation, loss, destruction, or access by unauthorised persons.

Processing of Automatically Collected Data

a)    Hosting
To provide our website, we use the services of SITE123 (sOptions LTD) who process the below-mentioned data and all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.

b)   Collection of access data and log files
We, rather WIX.com on our behalf, also collects data on every access to our website. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website.

c)   Use of cookies
We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.

d)   Google Analytics
We use Google Analytics, a service provided by Google Inc. This means that the data collected can in principle be transmitted to a Google server in the USA, whereby the IP addresses are anonymised by means of IP anonymisation so that an allocation is not possible. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can object to the collection and processing of this data by Google Analytics by setting an opt-out cookie that prevents the future collection of your data when you visit this website: http://tools.google.com/dlpage/gaoptout?hl=en. The legal basis for this processing is our legitimate interest and your consent. For further information please refer to our Cookie Policy.

e)   Content Management System (CMS)
We also use the Content Management System (CMS) of WIX.com, to publish and maintain the created and edited Content and texts on our website and to provide the forms used. This means that all content and texts submitted to us by users for publication is transferred to WordPress. In addition to texts, this also includes, for example your data in our forms. This represents a legitimate interest.

Data processing when you submit it to our website and when you use our services

When you contact us through our website or use our services, some data is collected and processed by us or on our behalf by our selected third-party providers.

a)   Contacting us
If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfil the contract and/or to fulfil our pre-contractual obligations and/or our overriding legitimate interest in processing your request.

b)   Data management and customer support
For optimal customer support, we use first name, last name, e-mail address, and the data related to your contract with us. Your data will be stored on our website and or our customer relationship management system ("CRM system") provided by Bullhorn Inc. This data processing is based on our legitimate interest in providing our customer service.

c)   Contract processing when using our services

i)    Candidate Data
We need to process certain information about you in order to provide you with optimal, tailored employment opportunities. We only ask for information that we believe will actually help us to serve you better, such as your name, age, contact details, education details, employment history, emergency contacts, residency status, financial information. Where appropriate and permitted by laws and regulations, we will also collect information about your health, diversity information or details of any criminal record.

ii)    Potential Candidate Data
If we believe that you may be interested in our services or that they may be of benefit to you, we will collect and use this information about you to evaluate how we might help you and contact you. We also collect certain information about you when you access our website or click on a link in an email we send.

iii)    Client Data
If you are a client, we may need to collect and use information about you or individuals within your organisation in order to provide or offer services to you, such as:

1. search for candidates who are a good match for you or

2. providing a managed service provider programme to you (or assisting another organisation to do so),

3. providing recruitment process outsourcing services to you (or assisting another organisation to do so),

4. providing services to your employees such as training, and/or

5. notifying you of content published by us that is likely to be important and useful to you.

6. In all cases, the legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your Consent.

e)   Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services (point c) and b) above). The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. Furthermore, based on our business interests, we store information on suppliers, and other business partners, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.

f)   Careers and Applications at Growe Global Limited
If you apply for a role or job with us, we process the information we receive from you as part of the application process, e.g., through your letter of application, CV, references, correspondence, telephone, or verbal details. In addition to your contact details, information about your education, qualifications, work experience and skills is particularly relevant to us.

Your data will initially be processed solely for the purpose of carrying out the application process. If your application is successful, it will become part of your personnel file and will be used to carry out and terminate your employment and will be deleted in accordance with the rules applicable to personnel files. If we are unable to offer you employment, we will continue to process your data for up to six months after sending the rejection in order to defend ourselves against any legal claims, in particular alleged discrimination in the application process.

The legal basis for processing data during the application process contract and, and your consent, for example by sending us information that is not necessary for the application process. The legal basis for data processing after a rejection is our legitimate interest.

As a rule, we do not require any special categories of personal data within the meaning of Art. 9 GDPR for the application process. We ask you not to provide us with any such information from the outset. If such information is relevant to the application process, we process it together with your other data. Your data will not be used by us for automated decision-making or profiling, nor will it be passed on to third parties. Your data will be processed by us or on our behalf.

You are not obliged to provide us with personal data. However, we can only assess your suitability for the respective position under consideration if we receive information in particular about your education, work experience and skills, and we cannot include you in the application process without providing your contact details.

How will your personal data be used?

Candidate Data
The main reason we use your personal data is to help you find employment or other suitable employment. The more information we have about you, your skills, and your goals, the better we can tailor our service to you. Where appropriate and permitted by laws and regulations, we will also use your personal data to advertise our services to you, profiling, and diversity monitoring, etc. We may ask you to provide us with more information about yourself. Where appropriate, we will ask for your consent to do some of these things.

Potential Candidates
We use information about potential candidates to determine whether you are interested in or may benefit from our services. If this is the case, we will assess whether and how we could help you. If we think we can help you, we will use your information to contact you about our services.

Client Data
The main reason we use information about clients is to be able to introduce ourselves to you and to ensure that the contractual arrangements between us can be properly implemented to ensure a smooth business relationship. This will include:
 

• identifying candidates that we believe are a good fit for you or your organisation,

• providing services to you (or supporting another organisation in doing so,

• providing services to your staff such as training.

 

The more information we have, the better we can tailor our service to you.

Sharing of personal data
We will not disclose or otherwise distribute your personal data to third parties unless this:

• is necessary for the performance of our services,

• you have consented to the disclosure,

• or the disclosure of data is permitted by relevant legal provisions.

a)   Candidate Data
We will share your personal data with different recipients in different ways and for different reasons. First and foremost, we will share your information with potential employers to increase your chances of getting the job you want. Unless you have indicated otherwise, we will also share your information with any of our group companies as well as related third parties, such as service providers we use and selected job search engines, if we believe this will help us to provide the best service to you and maximise your chances of getting the job you want.

b)   Potential Candidate Data
If you have been identified as a potential candidate, we may share your information with all group companies and related third parties, such as service providers we use, in order to contact you about our services.

c)   Client Data
We share your data for the following purposes:

• primarily to ensure that we can provide you with access to an appropriate pool for candidates,

• to provide (or assist another organisation to provide) services to you and/or

• to provide services to your employees such as training.

 

Unless you have indicated otherwise, we will share your information with any of our group companies as well as related third parties, such as service providers we use, in order to better achieve these objectives.

However, we are entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors within the framework of the DPA and GDPR. External service providers support us, for example, in the technical operation and support of the website, data management, the provision and performance of services, marketing, as well as the implementation and fulfilment of reporting obligations.

The service providers commissioned by us however will process your data exclusively in accordance with our instructions and we remain in accordance with the DPA and GDPR responsible for the protection of your data. Doing so we always make sure that service providers commissioned by us are carefully selected, follow strict contractual regulations, technical and organisational measures, and additional controls by us.

We may also disclose Personal Data to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfil our legitimate interests.

Equality monitoring and other sensitive personal data

We want to ensure that our recruitment processes are consistent with our approach to equality. Some of the data we collect about you (in certain circumstances and in accordance with local laws and regulations) falls within the scope of 'diversity information'. This may be information about your ethnic background, gender, disabilities, age, sexual orientation, religion, or similar beliefs and/or socio-economic background. This diversity information is considered "sensitive" or "specially categorised" personal information and is subject to stricter data protection rules.

Where appropriate and in accordance with local regulations and requirements, we will use this information in anonymised form to monitor whether we are complying with our Equality Policy. We will also provide this information (appropriately anonymised where appropriate) to clients (including their internal or external auditors) where contractually agreed or where the client specifically requests this information in order to comply with their own employment processes.

We may collect other sensitive/special categorisation personal information about you, such as health or religious affiliation information, where permitted by local law. In these circumstances, we will use this information to comply with employment rights and obligations, such as calculating annual leave entitlement or making appropriate adjustments for candidates or part-time employees.

We may also collect details of any criminal convictions were permitted by local law which may require us to obtain your consent. If you do not agree, you can withdraw your consent at any time.

Please note that in some jurisdictions where we operate, different rules apply to this sensitive/special categorised data.

Automated decision-making
Automated decision-making including profiling does not take place.

Direct marketing in the context of a customer relationship
Insofar as you have also given us your separate consent to process your data for consulting, marketing, and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

Personal data and children
Our services are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal data from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact.

Online presences in social media
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply. Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g., write posts on our online presences or send us messages.

Changes and updates to the privacy policy
We kindly ask you to regularly inform yourself about the content of our privacy policy. We will amend the privacy policy as soon as changes to the information processing activities we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

Concerns and Contact
If you have any concerns about a possible compromise of your privacy or misuse of your personal data on our part, or any other questions or comments, you can contact us. This Privacy Policy was last updated on Friday, 10th March 2023

 

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