Privacy and cookies

Who is responsible for your data

Pure Growth is a sole trader business run by Hyde Phillips, registered in the United Kingdom. Pure Growth is the data controller for the personal data described on this page. You can reach the controller at hyde@pure-growth.uk, and that address is read by Hyde personally.

What is collected, and why

Newsletter and resource sign ups

When you sign up for the newsletter or ask for one of the free resources, the following is recorded: your email address, which page you signed up from, the date and time, the exact wording of the consent statement you agreed to and its version, your browser user agent, and a one way hash of your IP address. The IP address itself is not stored, only the hash, which exists so that a record of consent can be evidenced without holding an identifier for you.

This is used to send you the newsletter and the thing you asked for, and for nothing else. Every sign up uses double opt in: you receive a confirmation email and nothing further is sent unless you click the link in it.

Free run requests

When you request a free competitor engagement run, the following is recorded: your email address, your company website, any competitor profiles you supply, anything you write in the notes field, the date and time, your user agent, a hashed IP address, and the consent wording you agreed to. This is used to prepare and return your run and to talk to you about it.

Email you send

If you email Pure Growth directly, the message and your address are kept so the conversation can continue.

Lawful basis

• Consent for the newsletter and for the free resources. You give it by ticking the box and confirming by email, and you can withdraw it at any time without giving a reason. Withdrawing it does not affect anything done before you withdrew it.
• Legitimate interests for handling a free run request you asked for, and for replying to an email you sent. The interest is running a business and answering people who get in touch. It is balanced against your interests, and it does not extend to sending you marketing you did not ask for.

Who else sees it

Personal data is never sold, and it is never shared for anybody else to market to you. It is handled by a small number of service providers acting on Pure Growth's instructions:

• The hosting provider for this website, which processes requests in order to serve pages.
• An email newsletter provider, which stores subscriber records, sends the confirmation email and sends each issue. The provider is being chosen at the time of writing, and this page will name it before the first issue is sent.

Some of these providers operate outside the United Kingdom. Where they do, transfers rely on the UK approved safeguards, such as the International Data Transfer Addendum or an adequacy decision.

How long it is kept

• Newsletter subscribers: for as long as you are subscribed, and for up to 24 months after you unsubscribe, so that the record of your consent and your unsubscribe can be evidenced. After that it is deleted.
• Free run requests: up to 24 months from the request, then deleted.
• Email conversations: up to 24 months from the last message.

Cookies and analytics

This site sets no advertising cookies, no tracking cookies, and no third party marketing cookies. There is no cookie banner because there is nothing to ask you about.

Page views are counted using a cookieless analytics tool, which records the page visited, the referring site, and a coarse country and device type. It does not set a cookie, does not store an identifier for you, and cannot follow you across other websites.

If you click a link in one of my emails, this site sets one first party cookie for 30 days so I can see which articles that email brought you to. It holds the newsletter id you already have with me, never your email address, it is not shared with anyone, and it is not used for advertising. Clearing your cookies removes it, and you will not be asked again unless you click another link in an email.

Your browser may store small amounts of data locally so pages work properly. That never leaves your device.

Your rights

Under UK data protection law you have the right to:

• ask for a copy of the personal data held about you
• have inaccurate data corrected
• have your data deleted
• restrict or object to how it is used
• ask for it in a portable format
• withdraw consent at any time
• unsubscribe from any email, using the link at the bottom of every issue

To use any of these, email hyde@pure-growth.uk. You will get a reply within one month.

If you are not happy with how a request was handled, you can complain to the Information Commissioner's Office at ico.org.uk, or by calling their helpline. You are welcome to raise it here first, but you do not have to.

Automated decisions

No decision producing a legal or similarly significant effect on you is made about you automatically on this website.

Children

This site is for people running businesses. It is not directed at children, and personal data is not knowingly collected from anyone under 18.

Changes to this notice

When this notice changes materially the version number at the top changes with it, and the new wording applies from the date shown.