Privacy policy for Growth Engine

1. GENERAL INFORMATION

We are all about creating new businesses, and our offer is to brainstorm and validate your business idea in collaboration with you. To get the ball rolling, we need to get in touch with each other. This document describes how we use and process personal data to communicate with you and to operate our website. 

Growth Engine is owned and operated by Breed Ventures AB, company registration number 559218-9103, having its registered address at Hamngatan 13, 111 47 Stockholm (“Breed”, “we” or “us”). This “Privacy Policy” is applicable when you use visit and use our website (the “Website”), and when you reach out to contact us. 

All definitions in this Privacy Policy shall be interpreted in accordance with applicable data protection laws which refers to the General Data Protection Regulation (Regulation no. 2016/679), as well as the national implementations and related national legislation, unless otherwise is set out herein.

2. DATA PROCESSED

When you provide us with your contact details so that we can contact you, we will process the following personal data:

(a) your full name;
(b) your company’s name;
(c) your phone number; and
(d) your email address.

We need the information above in order to communicate with you. Since you provide us with this information on our Website, we believe that you are ok with us reaching out to you.

PURPOSE
to communicate with you;

to send you alerts or messages by email or otherwise, including to provide you with marketing of our and our related parties’ products and services;

to inform you about updates of our services, their terms of use, and if necessary, changes in how we process personal data;

to improve and develop our business and possible new services and products and to analyse your use of the Website (we use Hotjar for this purpose);

to ensure the technical functioning and security of the Website;

to protect our rights, property and safety and also the rights, property and safety of third parties if necessary;

to fulfil requirements by law, if necessary.
LEGAL GROUND
Our legitimate interest to make contact with new persons, to manage our existing relations, and to reach out with news and updates regarding our offerings.

Our legitimate interests to improve our business, our Website, and our services.

Our legitimate interest to safeguard data within our services, to protect our business and employees, and if necessary to help third parties to do so.

Our legal obligations, pursuant to e.g. the Bookkeeping Act (1999:1078), the Procedural Code (1942:749), and the GDPR.
3. DISCLOSURE OF PERSONAL DATA

We may share and disclose personal data about you to third parties, either for the provision of our services, where the recipients acts as processors, or to other third parties as may be necessary to for instance fulfill legal obligations or to safeguard our interests.

The recipients below are located outside the EU/EEA and we are therefore applying specified safeguards for the data transfers as set forth in the table below. You can acquire further information regarding the transfer by contacting us at hello@growthengine.se.

When visiting our Website, you may be directed to other websites where the personal data collected is not in our control. The privacy policy of the other website will govern the personal data obtained from you on that website.

Recipient
1. Snitcher

2. Google Analytics
Location of the processing
1. Processing is undertaken within the EU (Frankfurt, Germany & Amsterdam, The Netherlands).

2. Google uses sub-processors globally. This information includes data related to the device/browser, IP address and website/app activities, and is transmitted to a Google server in USA, where it will be stored and analysed by Google. The respective results will then be made available to us in anonymised form. Google may use the transmitted data for any of its own purposes, such as profiling and personalised advertising, and may link them with other user data such as your IP address, search history, personal accounts, usage data of other devices and any other data that Google has about you as a user. This may also allow Google to identify links to an existing Google account.
Safeguard used
1. Standard Contractual Clauses.

2. Standard Contractual Clauses.
4. RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM

We may access, preserve and share your personal data in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations.

5. COOKIES, PIXELS AND OTHER SYSTEM TECHNOLOGIES

We collect information by using technology such as cookies, pixels and tags on your browser or device. For information about how we use this type of technologies, please see our cookie policy (available here).

6. RETENTION of personal data

After we have received your contact information, we will reach out and start discussing your ideas. If either of us, or we mutually decide to not work together anymore, your contact details will be erased within a year of the last time of contact.

If we have entered into any contracts or made other deals, we may store the relevant personal data for up to ten years after the completion of the deal in order to keep it documented.

Technical data from our Website used for analytics is not stored for longer than 365 days from the date of its creation.  

7. CHILDREN

The services are not directed to persons under the age of 18. If you are a parent or guardian of a person under the age of 18 and you become aware of that the child has provided personal data to us without your consent, please contact hello@growthengine.se to exercise your access, rectification, erasure, limiting of processing and objection rights.

8. YOUR RIGHTS

You have the right to object to the processing of your personal data when it is based on our legitimate interests, and you have an absolute right to object to the processing of your personal data for direct marketing as described in section 2, above. You also have the right to withdraw your prior given consent. The withdrawal of your consent does not affect the lawfulness of the processing based on the consent before its withdrawal, and we may continue processing your personal data based on other legal grounds, except for direct marketing.

You have the right to request access and further information concerning the processing of your personal data, or request that we correct, rectify, complete, erase or restrict the processing of your personal data. You have the right to obtain a copy of the personal data that we process relating to you free of charge once (1) every calendar year. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs.

If the processing is based on the legal grounds consent or fulfilment of contract you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to another data controllers.

9. CONTACT INFORMATION

To exercise your rights, or if you have any questions regarding our processing of your personal data, please contact us using the details set out in the beginning of this Privacy Policy, or send an email to hello@growthengine.se. Note that you should sign the request to receive information of the processing of your personal data yourself.

If you have any complaints regarding our processing of your personal data, you may file a complaint to the competent data protection authority. You can find out more about the local data protection authorities under the following link European Commission.

10. Change of Control

If there is a change of control in our business, we may transfer your information to the new owners for them to continue to provide the Services. The new owners shall continue to comply with the commitments we have made in this Privacy Policy.

11. NOTICE OF CHANGES TO THE PRIVACY POLICY

If we make changes to this Privacy Policy, we will notify you by email. If your consent is required due to the changes, we will provide you additional prominent notice as appropriate under the circumstances and, ask for your consent in accordance with applicable law.