Privacy Policy

1. Who we are

ROWE GROWTH LTD (trading as Rowe Growth) is an advertising agency registered in England and Wales. We are the data controller for the personal data described in sections 2, 4 and 5 of this policy.

ROWE GROWTH LTD
Company number 17195788
15-17 Middle Street, Brighton, England, BN1 1AL
Email: [email protected]
Phone: +44 7700 900318
Website: rowegrowth.uk

We process personal data in accordance with the UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR).

2. Data we collect

• Enquiry details. When you use the enquiry form or write to us: your name, email address, phone number, company name, website address and whatever you tell us about your business and your requirements.
• Correspondence. Emails, call notes, meeting notes and briefs exchanged while we scope or deliver work.
• Client and supplier records. Contact details of the people we deal with at your organisation, contract documents, purchase orders, invoices and payment records.
• Campaign material. Approvals, feedback and sign-off on creative and claims.
• Technical data. Basic server log information generated when this website is requested, such as IP address, browser type and the time of the request.

This website has no server-side form handling. Details you type into the enquiry form stay in your browser until you choose to send them to us by email; nothing is transmitted or stored by the page itself.

We do not ask for special category data (such as health, religion, political opinions or trade union membership), and we do not use it for targeting.

3. Client advertising accounts and audiences

While managing campaigns we are given access to advertising and analytics accounts that belong to our clients, and we handle the data those accounts contain — including audience segments and retargeting lists.

For that data we act as a processor on the documented instructions of the client, who is the controller. This is governed by a written agreement that meets the requirements of Article 28 UK GDPR. Advertising accounts remain in the client's name, and the client keeps ownership of and access to them.

The client is responsible for the lawfulness of any audience data, customer list or contact list it provides to us or uploads to an advertising platform — including having a valid legal basis and, where required, valid consent from the individuals concerned. We will not upload a list on a client's behalf without that confirmation, and we will follow the client's instructions to correct, restrict or delete such data.

4. Purposes and legal bases

• Responding to enquiries and preparing proposals. Legal basis: steps taken at your request prior to entering a contract (Article 6(1)(b)), or our legitimate interests in answering business enquiries (Article 6(1)(f)).
• Delivering the agreed work — creative, production, media buying, campaign management and reporting. Legal basis: performance of a contract (Article 6(1)(b)).
• Managing the client relationship, including project administration, billing and credit control. Legal basis: contract and our legitimate interests in running the business (Article 6(1)(b) and (f)).
• Compliance with advertising rules. Keeping records of approvals and evidence for product claims, so adverts meet the CAP Code and the rules of the platforms where they run. Legal basis: legitimate interests, and legal obligation where it applies (Article 6(1)(f) and (c)).
• Accounting and statutory records. Legal basis: legal obligation (Article 6(1)(c)).
• Our own marketing emails. Legal basis: consent (Article 6(1)(a)); see section 5.
• Site security and troubleshooting. Legal basis: legitimate interests (Article 6(1)(f)).

5. Marketing and PECR

We send our own marketing emails only to people who have given clear, specific consent to receive them. Every message includes a working unsubscribe link, and you can also unsubscribe at any time by emailing [email protected]. Withdrawing consent does not affect processing carried out before you withdrew it, and does not stop us replying to an enquiry you send us.

Answering your enquiry is not marketing: we use the details you send to reply to that enquiry and nothing else, unless you separately opt in.

6. Sharing with third parties

We do not sell personal data. We share it only with the following categories of recipient, and only as far as needed:

• Advertising and analytics platforms on which campaigns are planned, placed, measured and reported.
• Media owners, publishers and printers used to place or produce advertising.
• Production freelancers and studios engaged on a specific project under confidentiality terms.
• IT and business service providers: email and file hosting, project management and website hosting.
• Accountants, auditors, insurers and legal advisers.
• Regulators, courts or law enforcement where we are legally required to disclose, and buyers or their advisers in connection with a sale or reorganisation of the business.

Where a recipient processes personal data on our behalf, we put a written processor agreement in place under Article 28 UK GDPR.

7. International transfers

Some of our suppliers and advertising platforms are based outside the UK, or store data outside the UK. Where personal data is transferred abroad, we rely on UK adequacy regulations, or on the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with any additional safeguards the transfer requires. You can ask us which safeguard applies to a particular transfer.

8. Retention

• Enquiries that do not become projects: up to 12 months from the last contact.
• Client project records, briefs, approvals and campaign reports: 6 years from the end of the engagement.
• Records supporting advertising claims and approvals: 6 years, to answer any regulatory query.
• Invoices and accounting records: 6 years after the end of the relevant financial year, as required by UK tax law.
• Marketing consent records and unsubscribe records: for as long as we send marketing, plus 2 years.
• Data inside client advertising accounts: kept and deleted according to the client's instructions and the platform's own settings.

9. Security

We use access controls, individual accounts with multi-factor authentication, encrypted connections and encrypted devices, least-privilege access to client advertising accounts, and confidentiality obligations for staff and freelancers. We review access when a project ends and remove it when it is no longer needed. No method of transmission or storage is completely secure, but we take these measures seriously and will notify you and the ICO where a breach requires it.

10. Cookies

This website does not set cookies, does not use analytics or advertising trackers, and does not store your form input in your browser. The only third-party request the site makes is to Google Fonts to load the typeface; that request reveals your IP address to Google as the font provider. If you prefer to avoid it, block third-party font loading in your browser and the site will fall back to a system typeface.

11. Your rights

Under the UK GDPR you have the right to:

• access a copy of the personal data we hold about you;
• have inaccurate data rectified;
• have data erased in certain circumstances;
• restrict our processing in certain circumstances;
• receive data you gave us in a portable, machine-readable format;
• object to processing based on legitimate interests, and to object to direct marketing at any time;
• withdraw consent at any time where processing is based on consent.

To exercise a right, email [email protected]. We respond within one month and may extend that by two further months for complex requests, telling you if we do. We may ask for information to confirm your identity. There is normally no charge.

If your data sits inside a client's advertising account, we act as a processor: send your request to that client as the controller, and if you send it to us we will pass it on promptly and help them answer it.

12. Complaints

Please raise any concern with us first — we would rather fix it directly. You also have the right to complain to the UK supervisory authority, the Information Commissioner's Office: ico.org.uk, helpline 0303 123 1113, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

13. Age limit

Our services are for businesses. This website and our services are not directed at children, and we do not knowingly collect personal data from anyone under 16. If you believe a child has given us personal data, contact us and we will delete it.

14. Changes to this policy

We may update this policy as our services or the law change. The current version always appears on this page with the date it was last updated. If a change materially affects how we use your data, we will tell you directly where we can.

15. Contact us

For anything about this policy or your personal data, write to ROWE GROWTH LTD, 15-17 Middle Street, Brighton, England, BN1 1AL, email [email protected] or call +44 7700 900318.