Privacy Policy

This Privacy Policy explains how Tamar Ari Ltd, trading as Growth Market (“Growth Market”, “we”, “our” or “us”), collects, uses, stores, shares and protects personal data when you visit our website, use our Platform or purchase our Services.

We are committed to protecting your privacy and processing your personal data transparently, fairly and in accordance with:

• the UK General Data Protection Regulation (“UK GDPR”);
• the Data Protection Act 2018;
• the Privacy and Electronic Communications Regulations (“PECR”); and
• any other applicable data protection legislation.

By using our Services, you acknowledge that your personal data will be processed as described in this Privacy Policy.

Data Controller: Tamar Ari Ltd, trading as Growth Market. Company Number: 17350294. Registered in England and Wales.

Registered Office: 87-189 Great Portland Street, London, W1W 7LT, United Kingdom.

For privacy-related enquiries, you may contact us using the contact details published on our website.

This Privacy Policy applies to:

• visitors of our website;
• customers;
• prospective customers;
• suppliers;
• business partners;
• authorised users of our Platform;
• applicants;
• individuals communicating with us by email, telephone or other electronic means.

Depending on the Services requested, we may collect the following categories of personal data.

Identity Information

• full name;
• job title;
• company;
• date of birth (where required);
• nationality (where required);
• identity verification documents where legally required.

Contact Information

• email address;
• telephone number;
• billing address;
• business address.

Account Information

• username;
• encrypted password;
• account preferences;
• authentication information;
• security logs.

Billing Information

• invoices;
• payment history;
• VAT number;
• company registration number.

Payment card information is processed directly by our authorised payment providers and is not stored by Growth Market unless strictly necessary.

Technical Information — we may automatically collect:

• IP address;
• browser type;
• operating system;
• device identifiers;
• referring website;
• pages visited;
• session duration;
• cookies;
• diagnostic information.

Communications — we may retain communications exchanged through:

• email;
• support tickets;
• online chat;
• meetings;
• contact forms.

Marketing Information — where permitted by law, we may collect information relating to:

• newsletter subscriptions;
• marketing preferences;
• event registrations;
• survey responses.

We collect personal data:

• directly from you;
• when you create an account;
• when you purchase Services;
• when you complete online forms;
• when you contact us;
• through cookies;
• through analytics tools;
• from publicly available sources;
• from business partners where legally permitted.

We process personal data only where we have a lawful basis.

This includes:

• providing our Services;
• managing customer accounts;
• processing payments;
• communicating with customers;
• responding to enquiries;
• complying with legal obligations;
• preventing fraud;
• improving our Platform;
• maintaining security;
• sending marketing communications where permitted.

Depending on the circumstances, processing is based on:

• performance of a contract;
• legitimate interests;
• compliance with legal obligations;
• consent;
• protection of vital interests where applicable.

We carefully assess the lawful basis applicable to each processing activity.

We do not sell personal data.

We may disclose personal data only where necessary for the operation of our business, the provision of our Services or compliance with legal obligations.

Recipients may include:

• payment service providers;
• cloud hosting providers;
• customer support providers;
• communication service providers;
• analytics providers;
• identity verification providers;
• professional advisers;
• insurers;
• auditors;
• regulators;
• law enforcement authorities;
• courts and competent governmental authorities.

All third-party service providers processing personal data on our behalf are required to implement appropriate confidentiality and security measures and may process personal data only in accordance with our documented instructions where applicable.

Growth Market may transfer personal data outside the United Kingdom where necessary for the provision of the Services.

Where personal data is transferred to a country that is not subject to an adequacy decision issued by the UK Government, we shall implement appropriate safeguards, including where appropriate:

• the UK International Data Transfer Agreement (IDTA);
• the UK Addendum to the EU Standard Contractual Clauses;
• contractual safeguards recognised under Applicable Law; or
• any other legally recognised transfer mechanism.

Where required, additional technical and organisational safeguards may also be implemented to protect transferred personal data.

Personal data shall be retained only for as long as reasonably necessary to fulfil the purposes for which it was collected, including compliance with legal, accounting, tax and regulatory obligations.

Retention periods depend on the nature of the information and applicable legal requirements.

When personal data is no longer required, it shall be securely deleted, anonymised or otherwise rendered permanently inaccessible, unless continued retention is required by Applicable Law or for the establishment, exercise or defence of legal claims.

Growth Market implements appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

These measures may include:

• encryption of data in transit where appropriate;
• role-based access controls;
• multi-factor authentication;
• network monitoring;
• vulnerability management;
• regular security updates;
• secure cloud infrastructure;
• logging and audit controls;
• staff confidentiality obligations.

Although we implement reasonable security measures, no method of electronic transmission or storage can be guaranteed to be completely secure.

Subject to Applicable Law, individuals may exercise the following rights in relation to their personal data:

• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to object to processing;
• the right to data portability;
• the right to withdraw consent where processing is based on consent;
• the right not to be subject solely to automated decision-making where legally applicable.

Requests should be submitted using the contact details provided in this Privacy Policy.

We may request reasonable proof of identity before responding to any request.

Where permitted by Applicable Law, certain rights may be subject to legal exceptions or limitations.

Where permitted by Applicable Law, Growth Market may send information relating to:

• products;
• services;
• newsletters;
• events;
• updates;
• promotional communications.

Recipients may opt out of marketing communications at any time by:

• using the unsubscribe link contained in electronic communications;
• updating their account preferences where available; or
• contacting us directly.

Withdrawal of marketing consent shall not affect communications relating to existing contractual relationships or legal obligations.

Our website uses cookies and similar technologies to improve functionality, security, analytics and user experience.

Certain cookies are strictly necessary for the operation of the website. Other cookies are used only where permitted by Applicable Law and, where required, with the user’s consent.

Further information is available in our separate Cookie Policy.

Our Services are intended for business users and are not directed towards individuals under the age of eighteen (18).

We do not knowingly collect personal data from children.

If we become aware that personal data relating to a child has been collected without appropriate legal authority, we shall take reasonable steps to delete such information without undue delay.

Our website and Services may contain links to third-party websites, platforms or applications.

Growth Market is not responsible for the privacy practices, content or security of third-party services.

Users should review the privacy policies of those third parties before submitting personal data.

Growth Market maintains procedures designed to detect, investigate and respond to personal data breaches.

Where required by Applicable Law, we shall notify the relevant supervisory authority and affected individuals within the applicable statutory timeframes.

Growth Market may amend this Privacy Policy from time to time in order to reflect changes in legislation, regulatory requirements, business operations or technological developments.

The updated version shall become effective upon publication on our website unless otherwise stated.

Where required by Applicable Law, appropriate notice of material changes shall be provided.

Questions regarding this Privacy Policy or the processing of personal data may be addressed using the contact details published on the Growth Market website.

Where an individual believes that their data protection rights have been infringed, they may also lodge a complaint with the competent supervisory authority in accordance with Applicable Law.

This Privacy Policy shall be governed by and interpreted in accordance with the laws of England and Wales, without prejudice to any mandatory rights available under applicable data protection legislation.