Privacy Policy

EmPower Growth Ltd (EmPower, we, us, our) is committed to respecting and protecting the security and protection
of the personal information that we process and to provide a compliant and consistent approach to data protection
to ensure compliance with the General Data Protection Regulations, 2018.

This privacy notice tells you what to expect us to do with your personal information.

Our contact details

Post: Inchnacardoch Lodge Hotel, Fort Augustus, Inverness-shire, PH32 4BL, Scotland
Email: connection@em-po.com
Phone: 0113 403 5580

What information we collect, use, and why

We collect or use the following information to provide services and goods including:

  • Names and contact details
  • Addresses
  • Date of birth
  • Payment details (including card or bank information for booking processing)
  • Health information (including dietary requirements, allergies and health conditions)
  • Website user information (including user journeys and cookie tracking)
  • Records of meetings and decisions
  • Schwartz Survey inputs
  • Programme questionnaires
  • Personal app information and inputs – to read our EmPower App privacy policy, visit the EmPower App policy

We collect or use the following information for service updates or marketing purposes:

  • Names and contact details
  • Marketing preferences
  • Website and app user journey information
  • Records of consent, where appropriate

Lawful bases

Our lawful bases for collecting or using personal information to provide services and goods are:

  • Consent

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

  • Legitimate Interest

Where we get personal information from

EmPower collects personal data through various channels, primarily through the application process, programme
administration, and associated activities, including relevant notifications. Individuals directly provide this
information through multiple means, including phone, email, verbal and input of information into our website forms,
questionnaires, trackers and surveys.

How personal data is stored

Personal data collected by EmPower is stored electronically in a secure manner. We utilise cloud-based,
fully encrypted software to ensure the confidentiality, integrity, and availability of personal data. Access to
personal data is restricted to authorised personnel who have a legitimate need to access such information for the
purposes outlined in our privacy policy.

Purpose of processing

EmPower processes personal data to deliver our programme to people/organisation employees.
We will not use any form of automated decision making to process programme applications.

EmPower will, on some occasions, process data for internal reporting and research purposes such as reviewing the
number of clients who have successfully completed a programme, collation of Schwartz survey scores and tracker data
analysis. These reports will not be shared with third parties but anonymised reports may be discussed and shared,
including our marketing purposes exclusively (not including any specific personal data).

We will also use the testimonials and case studies for marketing purposes only with written consent by the
individual/organisation concerned.

How long we keep information

EmPower will retain your personal data only as long as is necessary to fulfill the above objectives.

Who we share information with

EmPower will not share your data with any third parties other than those with whom we have signed a formal
data-sharing agreement. These parties include extended personnel who are part of the EmPower team or those who host
or manage the software/platforms used to securely store your electronic data – our third-party data processors.

Third-party processors: We utilise various third-party supplier plug-ins and applications including but not limited to
PayPal for payment processing, Zoom for online seminar hosting, Squarespace for website management, and WhatsApp for
communication purposes. By accepting our terms, you agree to abide by the terms and conditions of these third-party
suppliers as applicable to your interactions with them.

We are not responsible for their privacy statements nor liable for any issues or disputes arising from your use of these
third-party services.

Security of your personal information

EmPower stores your electronic data on secured platforms. Encrypted database backups are held off-site in a secure
location and are subject to a regular cleardown schedule. All the software used to process and store your data is
password protected and accessible only by authorised personnel.

Sharing information outside the UK

Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR by ensuring
appropriate safeguards are in place. Please contact us for more information.

Your data protection rights

Under data protection law, you have rights including:

  • Your right of access – You have the right to ask us for copies of your personal data.
  • Your right to rectification – You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure – You have the right to ask us to erase your personal data in certain circumstances.
  • Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal data in certain circumstances.
  • Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
  • Your right to data portability – You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.
  • Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent.

You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.

To make a data protection rights request or contact us about any issues relating to your data please email us at
connection@em-po.com.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us by contacting
connection@em-po.com. This will be reviewed by our leadership team and we will respond within 48 hours.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the
Information Commissioner’s Office complaints helpline on 0303 123 1113.