Last updated: 24th July 2017
The website and stepup2grow.co.uk (the “Website”) is operated by StepUp2Grow Consulting. (“StepUp2Grow”, “we”, “our”, and “us”).
Collection and use of your information
We may collect your personal data directly from you or when you access and interact with the Website, by telephone, letter or email or from other sources. We may also collect personal data from persons acting on your behalf such as your agent or broker.
The personal data we collect from you includes your name, address, telephone number, email address and other details submitted by you in relation to any financial products or services you propose to acquire from Lime and is necessary for us to provide you with financial products or services.
You acknowledge that:
• if you choose not to provide us with your personal data, or choose to use a pseudonym, we may not be able to contract with you or provide you with the information or financial products or services you may require; and
• if you submit incorrect information to Lime, this may adversely affect any financial products or services you acquire from Lime.
You acknowledge and consent that by providing your personal data to us that we may collect and use your personal data for the purposes of supplying and/or delivering services to you, communicating with you, providing you with marketing and updates on our products and services, better understanding your needs or complying with our legal obligations.
We may also collect information about you with regard to each of your visits to the Website that is not personal data. This includes technical information relating to your activity on the Website (including IP addresses, your login information, your browser type) collected by way of tracking technologies such as cookies, or we may collect information from you in response to a survey.
We use this information to record statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our products and services. To the extent this information does not constitute personal data, the UK Data Protection Act 1998 does not apply in respect of the processing of such information and we may use this information for any purpose and by any means whatsoever.
Disclosure of your personal data
We may disclose your personal data to other Lime group companies from time to time.
We may also share your personal data with selected third parties including:
• third parties engaged by us to provide you with goods or services on our behalf. In that circumstance, we may disclose your personal data to third parties in order to meet your request for goods or services, however such disclosure will only be made to the extent necessary to supply goods or services to you (such as provision of information to an insurer for the purpose of providing financial products or services to you);
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
We may disclose your personal data to third parties:
• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if we are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
• if substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers may be one of the transferred assets;
• to protect our rights, property or safety, or that of our customers, users or other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection, credit risk reduction and law enforcement.
You represent to us that where you provide personal data to us about another person, you are authorised to provide that data to us, and that you will inform that person who we are, how we use and disclose their data, and that they can gain access to that data.
Transfer and storage of your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing.
We take all reasonable technical and organisational measures to safeguard your personal data and ensure it is treated securely and in accordance with this policy. We review and update our security measures in light of current technologies. However, you acknowledge that transmission of information via the internet is not completely secure. For this reason, we cannot guarantee the security of your personal data transmitted to the Website. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Our employees and agents are responsible for handling your personal data and educated about the requirements of the UK Data Protection Act 1998. Personal data that we hold on our systems is protected through the use of secure passwords and other security procedures including physical, network and computer security. Access to your personal data is limited to those who specifically need it to conduct their responsibilities. We take reasonable steps to destroy or permanently de-identify your personal data where it is no longer required and to protect your personal data from unauthorised access, disclosure, loss, misuse and alteration.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
In order to improve the Website, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (referred to in this policy as a ‘device’) from the Website and is stored on your device’s hard drive.
A cookie records on your device information relating to your internet activity (such as whether you have visited the Website before). Cookies, which are industry standard and are used by most websites, including the Website, can facilitate a user’s ongoing access to and use of a site. They allow us to customise the Website to your needs.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
We currently set the following cookies:
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage data.
Place of processing: US
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your personal data to any third party for such purposes.
You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
The Website may contain links to websites which are owned or operated by third parties. If you choose to follow such links, you should make your own enquiries as to the privacy policies of those third parties. We do not accept any responsibility or liability for information on, or the privacy practices of, such websites.
Right of access
The Data Protection Act 1998 gives you the right to access personal data held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the personal data we hold about you.
We will take reasonable steps to ensure that the personal data we hold about you is accurate, complete and up-to-date and ask that you let us know if you believe the personal data to be otherwise.
Changes to this policy
Any changes we may make to this policy in the future will be posted on this page and, where appropriate, notified to you by email. Please visit this page frequently to see any updates or changes to this policy. You can determine when this policy was last updated by checking the “Last updated” date of this policy.
If you would like a copy of this policy or you have a query or you would like to make a complaint, please contact us at:
Address: The Data Controller, StepUp2Grow Consulting, 1 Derby Street, Edinburgh, EH6 4SQ