1) At the GrowTraps, we’re committed to protecting and respecting your privacy.
This Policy explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.
Any questions regarding this Policy and our privacy practices should be sent by email to breakthrough@GrowTraps.com or by writing to our registered address, below.
2) Who are we?
The GrowTraps website and services are run by AlsoThus limited. We help people break through their personal and professional growth traps. We are a limited company, registration number 10377484. The registered address is, AlsoThus Limited, 71-75 Sheldon Street, London WC2H 9JQ, UK
From time to time, GrowTraps partners with other organisations to deliver these services. Our privacy policy covers the work of GrowTraps and data captured by GrowTraps when partnering with these other organisations.
3) Collection and processing of Data
Personal data is Data about you that is personally identifiable like your name, address, e-mail address, or phone number, and that is not otherwise publicly available.
We may capture your information by registering interest on our website, or from a training course registration, providing us with a business card, contacting us via phone or e-mail, or by becoming a member of any of our associated partnership networks.
By registering with us, you have agreed to allow GrowTraps to store, process, display and deal with your personal information to facilitate the use of the website and for the purposes of administration, analysis and direct marketing, not limited to the use of the GrowTraps site. GrowTraps also reserve the right to further identify and contact you using third party social networks.
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. For example, we may have purchased a license to use your Data for professionally relevant direct marketing from a third party.
The legal basis for processing your data is ‘contract’ while you are a customer or supplier; and ‘legitimate interest’ if you are not an active customer or supplier, because GrowTraps benefits commercially from active customers and would like you to become a customer.
GrowTraps does not use your data for any automated decision making or profiling.
GrowTraps will keep your data for as long as GrowTraps believes it is accurate and up to date.
4) Disclosure of information
GrowTraps’s use of your Data for any of the purposes disclosed in this Policy, or any other purposes disclosed in any separate communication, may involve GrowTraps sharing it with third party suppliers such as contractors, agents or professional advisers appointed by GrowTraps to assist GrowTraps in providing customer services, facilities and products.
These may include entities located in countries outside the European Economic area (currently the European Union and Iceland, Liechtenstein and Norway), who will be required to comply with our strict privacy requirements, and to demonstrate that they follow best practice guidelines for data protection.
In no other case, unless obliged to do so by law, will GrowTraps sell, rent, lease or otherwise share your Data with third parties, unless you have provided your specific, positive and unambiguous consent.
5) What we use your data for
Data about you, provided to GrowTraps will be used for the purposes described at the time of collection. It may also be used for the other purposes described in this Policy. For instance, Data will be used by GrowTraps to record website usage patterns and your use of GrowTraps’s other services, goods and facilities, thus helping us to administer these effectively and provide the highest possible level of service. It also helps us better understand your needs and interests.
If you are a GrowTraps customer your Data may be used to send you, by post or by email, any publications made available to other customers including regular monthly newsletters and updates on regional events and activities.
If you are not an GrowTraps customer, your Data may be used to send you regular updates about the latest information, events and services available from GrowTraps, by post, e-mail or other channels.
Data may also be used to send customers and non-customers promotional communications as described in the ’Promotional Communications’
6) Photo and Video Disclaimer
Images and sound may be captured during events organised and/or hosted by GrowTraps using film photography, digital photography, video or other mediums. GrowTraps reserves the right to use the images and sound captured in any brochures, booklets, videos, websites or other media and publicity material produced by GrowTraps. Unless express objections are received individuals attending an event are deemed to have given their consent by attending or remaining at the event.
7) Promotional communications
Unless you have previously opted out of receiving such communications your Data will be used by GrowTraps for marketing, advertising and promotions (’Promotions’). These Promotions may advertise events and other services, goods and facilities, some of which are offered to you in partnership with specially selected partners of GrowTraps. Because of this, Data may be shared with them solely for the purpose of informing you of such events, services, goods and facilities.
Other Promotional communications may also invite you to participate in surveys or prize events sponsored by third parties. These third parties will have been specially selected by GrowTraps and third party Promotions will not result in your Data coming into the third party’s possession unless you give separate consent to this occurring, for example if you participate in a survey or prize draw or subsequently place an order with the third party. In that event please check notices supplied by that third party for information as to how they will make use of your Data.
Promotional communications may be made by post or by email.
8) Under 16
GrowTraps is aimed at adults and we do not expect users or customers who are under 18, nor do we record data of people under 18. If you are under 18, please do not sign up to newsletters or and undertake activity where we might save personal data.
9) Opting out
You may at any time opt out of any future GrowTraps and associated group communication, digital or non-digital, Promotional or non-Promotional. If you wish to opt out of receiving postal communications, please contact GrowTraps (contact details below). If you wish to opt out of email communications, please use the ‘Unsubscribe’ link provided and follow the instructions. Alternatively, you can email breakthrough@GrowTraps.com
GrowTraps will retain your Data to know not to contact you again in the future.
10) Surveys
GrowTraps may from time to time invite you to participate in surveys and benchmarks. This may occur online or using other communication channels. Anonymity of individual respondents and protection of personal details will be maintained except where you have expressly granted permission to the contrary. Information gathered through surveys will be researched and compiled on an aggregated basis and results may be published on the GrowTraps website or elsewhere. Such results will not identify you. The information will be used to help us formulate our policy positions and to monitor or improve the GrowTraps website, social media presence, products and services.
11) The Data Protection Act
We are registered to process personal data under the Data Protection Act 1998. Under the terms of the Act, we have a legal duty to protect any information we collect from you.
12) Security
GrowTraps places great importance on the security of all Data associated with our members, suppliers, registered users of GrowTraps.company and other contacts. We have security measures in place to protect against loss, misuse or alteration of Data under our control.
Unfortunately, no transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, we cannot warrant the absolute security of any Data you transmit to us. You are responsible for maintaining the security of your passwords in your possession and/or any account information in your control.
We limit access to personal information about you to staff who we believe reasonably need to use that information to provide services to you or to do their jobs.
We take all reasonable precautions to keep your personal information secure and we have put in place physical, electronic, and procedural safeguards to protect personal information about you.
13) Maintaining the information we hold about you
GrowTraps aims to keep the Data it holds about you accurate and up to date. As a customer if at any time, you want to verify, update or amend any Data we hold about you or if you become aware of possible errors or inaccuracies in that Data.
If you wish to opt out of further use of your Data for any purpose, please refer to ‘Opting Out.’ (section 9)
14) Right to request information and contact details
You have the right to request a copy of any personal data held by GrowTraps at any time, to check its accuracy. If you wish to do this, please write (explaining that your interest is in personal data maintained by GrowTraps) to GrowTraps Data TEam , AlsoThus Limited, 71-75 Sheldon Street, London WC2H 9JQ, UK.
15) Cookies
Our websites, and the tools we use, may place certain information automatically onto a user’s hard drive when a user views the site (known as a “Cookie”). Cookies are used to help GrowTraps provide and improve its services to the registered user. A user can configure the Internet browser to reject a Cookie. Further information about this can be found in the Internet browser software instructions or help screen.
GrowTraps may provide hyperlinks to other websites outside the GrowTraps Site. Use of websites outside GrowTraps’s site will not be governed by this Policy. The user is responsible for checking the other websites and any privacy policies that may govern those websites to find out how their data will be treated by the operators of those websites.
We currently use analytic software to measure and analyse visitor information related to our web site. For that purpose, your IP address, Internet traffic data and data on your browser type and device are collected. We will not use any of this data to identify you personally, it is used only to monitor and improve our site.
16) Changes to this privacy policy
Due to changes in legislation and best practice or enhancements to functionality and content on our sites, GrowTraps may update this policy and accordingly you should check here from time to time.
This policy was last updated on 31 March 2019