Privacy Policy

socialgrowthsystems.co.uk · Last updated: September 2026

Danuta Grochowska, trading as Social Growth Systems ("I", "me", "my"), of 61 Bridge Street, Kington, HR5 3DJ, United Kingdom, protects your personal data. This policy explains how I collect, use, store and protect it.

For data about you as a visitor, enquirer or client, I am the data controller. I am registered with the Information Commissioner's Office under registration number ZC211790.

For personal data I handle on behalf of clients, for example messages sent to a client's own Facebook or Instagram account, my client is the controller and I am the processor. This is governed by the Services Agreement between us. See section 15.

1. What Personal Data I Collect

Information you give me

• Contact data: name, business name, email address, phone number and billing address
• Order, invoice and payment records. I don't store your full card details; the payment provider handles those.
• Communications data: the content of messages, emails or enquiries you send me
• Prize draw data: name, business name, email address and social profile link, if you enter the Free Audit Prize Draw
• Client brand assets, project media and business information you supply for a service

Information collected automatically

• Technical data: IP address, browser type, time zone and operating system
• Usage data: pages visited, links clicked and time spent on the site

Collected through cookies. See my Cookie Policy for the full detail and how to change your choices.

2. Where Your Information Comes From

• Directly from you, when you enquire, buy, enter a draw, complete a form or become a client.
• From the business you work for, or from someone who introduces you.
• From public business sources such as company websites, professional profiles, Companies House or public business directories, when I carry out proportionate B2B prospect research.
• From service providers and platforms used to run the website, store files, communicate, process orders or measure marketing.

3. How I Use Your Data

4. My Legitimate Interests

These may include running and improving SGS, responding to enquiries, keeping business records, preventing fraud, protecting accounts, understanding how my marketing performs, and B2B prospecting. I run a necessity and balancing check before relying on this basis, and I don't use it where your rights or PECR require a different approach.

5. Marketing and Your Right to Object

• If you've subscribed to updates, offers or a free resource, I email you on the basis of consent. Unsubscribe any time using the link in any email, or by emailing me.
• If I contact a company you work for as part of B2B prospecting, using a company email address, I may do so under legitimate interests, in line with PECR rules for corporate subscribers. Every message identifies me and gives you an opt-out.

6. When Information Is Required

Some information is needed to enter or perform a contract, process an order, verify prize-draw eligibility or meet legal record-keeping duties. Without it, I may be unable to provide the service, product or prize.

7. Sharing Your Data

8. International Transfers

Some providers above are based outside the UK, mainly the US. Transfers are protected by an approved safeguard: a UK adequacy decision, the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses. Ask me for details on any particular transfer.

9. Data Security

I use multi-factor authentication where supported, device lock and current software updates, and named-person or least-privilege file sharing. No "anyone with the link" sharing for personal or client data, and I never hold client passwords.

10. Data Retention

11. Your Rights Under UK GDPR

• Access a copy of the personal data I hold about you
• Correct inaccurate or incomplete data
• Erase your data, subject to my legal obligations
• Restrict or object to how I process your data
• Get your data in a portable format
• Withdraw consent any time, where consent is the basis
• Object to direct marketing any time. This is absolute.

Email dana@socialgrowthsystems.co.uk. I respond within one month, no fee.

12. Automated Decision-Making

I don't use automated decision-making that produces legal or similarly significant effects about you.

13. Cookies

Non-essential cookies, including analytics and any live chat, are only set after you agree via the cookie banner. Change your choice any time through the cookie settings. Full detail in my Cookie Policy.

14. Client-Controlled Data

When I process personal data for a client, for example messages sent to a client's Facebook or Instagram account, the client remains the controller and I act on their documented instructions, under the relevant Services Agreement and Service Schedule. If you contact me about data belonging to a client relationship, I may pass your request to that client. See also my Website Terms & Conditions.

15. Changes to This Policy

I may update this policy from time to time. Material changes are posted here with a revised date.

16. Complaints

Email me first at dana@socialgrowthsystems.co.uk and I'll put it right. You can also complain to the ICO at www.ico.org.uk or 0303 123 1113.

Danuta Grochowska trading as Social Growth Systems · 61 Bridge Street, Kington, HR5 3DJ · socialgrowthsystems.co.uk · © 2026