About this notice
This notice explains how personal information is handled when you visit todogrowth.com, submit a form, contact To-Do Growth or take part in editorial activity. To-Do Growth is based in the City of London, London, United Kingdom.
“Personal information” means information that identifies you or can reasonably be linked to you. We aim to use it lawfully, fairly and transparently, and only for clear purposes.
Information we may collect
Information you provide
Depending on how you use the website, you may provide:
- your name and email address;
- your business or organisation name;
- an optional website address;
- the type and content of your enquiry;
- information included in editorial feedback, a proposed contribution or a media enquiry;
- your communication preferences;
- correspondence, feedback and records of our response; and
- material you submit for editorial review or publication consideration.
Please do not submit special-category personal data, criminal-offence data, passwords, payment-card details or confidential information that is not necessary for your enquiry.
Information collected when you use the website
The website and its hosting or security providers may process technical information such as:
- IP address;
- device, browser and operating-system information;
- the date, time and pages requested;
- referral information;
- security, error and diagnostic events; and
- cookie or consent choices where the relevant technology is used.
See the Cookies page for more information about cookies and similar technologies.
Information from other sources
We may receive information from:
- a colleague or representative who includes you in an enquiry;
- contributors, sources or representatives who include you in editorial correspondence;
- publicly available sources used for editorial research or verification;
- suppliers that help operate forms, email, hosting, security or analytics; and
- professional advisers where this is necessary to operate the publication or protect legal rights.
If information is obtained from another source, we will provide privacy information when required and explain the source where appropriate.
How we use personal information
We may use personal information to:
- receive, route and respond to enquiries;
- assess proposed contributions, media enquiries and publication partnerships;
- communicate with contributors, sources and other editorial participants;
- manage editorial questions, feedback and corrections;
- handle privacy requests and maintain records of them;
- operate, secure, troubleshoot and improve the website;
- understand website use where optional analytics have been enabled with the required choice;
- prevent spam, abuse, fraud or security incidents;
- maintain appropriate business, financial and legal records; and
- establish, exercise or defend legal rights and comply with legal obligations.
We will not use information for a materially incompatible purpose without a lawful basis and, where required, further notice.
Lawful bases
The lawful basis depends on the purpose:
- Steps before a contract or performance of a contract: when you ask us to consider a separately agreed contribution, licence, sponsorship or other publication arrangement, or when information is needed to administer it.
- Legitimate interests: when it is reasonably necessary to respond to an enquiry, operate and secure the website, improve relevant content, maintain proportionate records or protect legal rights, provided those interests are not overridden by your rights and interests.
- Consent: where you make an optional choice, including consent to non-essential cookies or an optional communication that requires consent. You can withdraw consent at any time without affecting processing that was lawful before withdrawal.
- Legal obligation: where records or disclosure are required by law.
Where a form asks for required information, it is needed to route or respond to the request. If you do not provide it, we may be unable to respond or take the requested step.
Sharing personal information
We may share only what is reasonably necessary with:
- website-hosting, form, email, security, storage and IT providers;
- analytics or consent-management providers, where enabled appropriately;
- professional advisers such as accountants, insurers or legal advisers;
- contractors, editors or collaborators who need the information for editorial or operational work and are subject to appropriate obligations;
- a buyer, investor or successor in connection with a proposed business transaction, subject to appropriate confidentiality and legal safeguards; and
- courts, regulators, law-enforcement bodies or other authorities when disclosure is required or permitted by law.
We do not sell personal information.
International transfers
Some suppliers may process information outside the United Kingdom. Where personal information is transferred internationally, we will use an available lawful mechanism and appropriate safeguards. These may include UK adequacy regulations, an approved contractual transfer mechanism or another permitted exception. Information about the relevant safeguard can be requested through the Contact page.
Retention
We keep personal information only for as long as it is reasonably needed for the purpose for which it was collected, including any legal, accounting, security or dispute requirements.
Retention decisions take account of:
- the nature, amount and sensitivity of the information;
- the purpose for which it is used;
- whether the purpose can be achieved in another way;
- the risk created by unauthorised use or disclosure;
- applicable limitation periods and record-keeping duties; and
- an ongoing enquiry, engagement, complaint or legal issue.
When information is no longer needed, it is deleted or anonymised, subject to secure backup cycles and legal holds.
Security
Reasonable technical and organisational measures are used to protect personal information against unauthorised access, alteration, disclosure or loss. No website or transmission method can be guaranteed completely secure, so please use care when choosing what to send online.
Access should be limited to people and suppliers who need the information for an authorised purpose and who are subject to appropriate duties.
Your data-protection rights
Depending on the circumstances and the lawful basis, you may have the right to:
- be informed about how your information is used;
- request access to your personal information;
- ask for inaccurate or incomplete information to be corrected;
- ask for information to be erased;
- ask for processing to be restricted;
- receive certain information in a portable format;
- object to certain processing; and
- ask for human involvement where a decision with legal or similarly significant effects is made solely by automated means.
These rights are not absolute and may not apply in every situation. We do not intend to make decisions with legal or similarly significant effects about website visitors solely by automated means.
Your right to object
You have the right to object to processing based on legitimate interests in certain circumstances. You also have the right to object at any time to the use of your personal information for direct marketing.
If processing is based on consent, you can withdraw that consent at any time. Withdrawal does not affect processing that was lawful before it.
To exercise a right, choose “Privacy request” on the Contact page. We may ask for information reasonably needed to confirm your identity and locate the relevant records. You will not normally have to pay a fee, although the law allows a reasonable fee or refusal in limited circumstances involving manifestly unfounded or excessive requests.
Complaints
Please use the Contact page first if you have a privacy concern so it can be reviewed.
You also have the right to complain to the UK data-protection regulator. Information about raising a concern is available from the Information Commissioner’s Office at ico.org.uk/make-a-complaint/.
Children
This website is intended for a general business audience and is not directed at children. If we learn that personal information from a child has been submitted inappropriately, we will take reasonable steps to delete it.
Third-party websites
The website may link to external websites or services. Their handling of personal information is governed by their own notices and practices. A link does not make To-Do Growth responsible for another organisation’s website.
Changes to this notice
This notice may be updated when the website, editorial activities, suppliers or legal requirements change. The latest version will be published on this page with a revised date. Where a change materially affects how existing information is used, additional notice will be provided when required.
How to contact us about privacy
Use the Contact page and choose “Privacy request”. Include enough information to understand the request, but do not send identity documents unless they are specifically requested through an appropriate channel.