Privacy Policy

Effective date: 21 April 2020

We are Make and Grow Ltd, the provider of the Progression service. This is our Privacy Policy, which applies to personal data we process in the course of our business for our own purposes. Please read it carefully as it contains important information on how and why we collect, store, use and share personal information, your rights in relation to your personal information and who to contact in the event you have a complaint.

This Privacy Policy does not apply to personal data in the user accounts maintained by our customers – for example, data about members of a team administered by them using Progression. That is ‘their’ data, which we only store and process as a ‘data processor’ on their behalf. We do not use any personal data in user accounts for our own purposes. The customer is the ‘data controller’ of any personal data processed by them using the Progression service. If you believe that one of our customers is using Progression to process your personal data, please contact them direct with any questions about that processing.

We are happy to answer your questions about any of this – email us at help@progressionapp.com.

Information Collected

We collect several different types of information for various purposes to provide and improve our service to you.

Types of Data Collected

While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or by emailing at help@progressionapp.com.

Usage Data

We may also collect information that your browser sends whenever you visit our service or when you access our service by or through a mobile device (“Usage Data”). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access our service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.

Examples of Cookies we use:

• Session Cookies: We use Session Cookies to operate our service.
• Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
• Security Cookies: We use Security Cookies for security purposes.
• Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

Make and Grow Ltd uses the collected data for various purposes:

to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or by emailing at help@progressionapp.com;

• to provide and maintain our service;
• to notify you about changes to our service;
• to allow you to participate in interactive features of our service when you choose to do so;
• to provide customer support;
• to gather analysis or valuable information so that we can improve our service;
• to monitor the usage of our service;
• to detect, prevent and address technical issues;
• to fulfil any other purpose for which you provide it;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
• to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
• in any other way we may describe when you provide the information;
• for any other purpose with your consent.

The Legal Basis on which we Process Your Personal Data

Like all organisations that process personal data in the UK and Europe, we are obliged to have a “Lawful Basis” for doing so. The Lawful Bases on which we process your personal data are as follows:

Legitimate Interest: this means the legitimate interest of us, and our customers, in our conducting and managing our business to enable us to give you the best service and the best and most secure experience when using our services. The legitimate interests include provision of services that we are contractually obliged by our customer to deliver to you; to provide and improve Progression; to administer our relationship with you and our business; for marketing; and in order to exercise our rights and responsibilities under our customer terms and other contracts. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at help@progressionapp.com.

Performance of Contract: this means processing your data where it is necessary for the performance of a contract between us and our customer, or to take steps at your request before entering into such a contract.

Legal Obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent: this means your affirmative, explicit consent.

Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.

Disclosure of Data

We may disclose personal information that we collect, or you provide:

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

We may disclose your data to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data

We may disclose your information also:

• to other members of our group of companies;
• to contractors, service providers, and other third parties we use to support our business, set out here - https://progressionapp.com/data-subprocessors/;
• to fulfil the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information;
• to comply with applicable laws, regulations or any judicial order;
• to enforce our contractual rights under our customer terms of service or otherwise;
• to protect the security, rights, privacy, safety and property of Progression, of you, or of others.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our service.

Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

Customer Support

We may use third party software as part of providing live chat and customer support services.

Helpscout: Helpscout is a live chat and customer support service. You can find their privacy policy here: https://www.helpscout.com/company/legal/privacy/

Payments

We may provide paid products and/or services within Progression. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• Stripe: Stripe is a payment processor. Their Privacy Policy can be viewed at: stripe.com/us/privacy
• Chargebee: Chargebee is a payment processor and facilitator. Their Privacy Policy can be viewed at: chargebee.com/privacy

Security of Data

We have appropriate security measures in place intended to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Transfer of Data outside of Europe

Our list of service providers who process personal data for us is set out here - https://progressionapp.com/data-subprocessors/. We may transfer your personal information to certain of these service providers located outside the UK and European Economic Area (EEA).

Some of our service providers are based in the USA. The USA does not have the same data protection laws as the United Kingdom and EEA. Whilst the UK and European Commission have not given a formal decision that the USA provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to appropriate safeguard_s_ as permitted under the_ _General Data Protection Regulation, including under the certifications under the EU-US Privacy Shield of Stripe and Heroku. More information about the EU-US Privacy Shield is available here - https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.

Other service providers outside the UK and EEA use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/dataprotection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

For more details regarding the safeguards in place regarding transfers to any individual service provider, please ask us at help@progressionapp.com.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj. If you wish to exercise any of your rights in respect of our use of your data for our own purposes, please email us at help@progressionapp.com. Subject to certain exceptions, you have the following data protection rights:

• the right to access, update or to delete the information we have on you;
• the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
• the right to object. You have the right to object to our processing of your Personal Data;
• the right of restriction. You have the right to request that we restrict the processing of your personal information;
• the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
• the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113. For more information if you are in the European Economic Area, please contact your local data protection authority in the EEA.

If you would like to exercise any rights in respect of any of your personal data in a user account of a customer of the Progression service (e.g. your employer or ex-employer), please contact the customer.

Links to Other Sites

Our service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. Where the change is material, we will let you know via email and/or a prominent notice on the site, prior to the change becoming effective.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email: help@progressionapp.com.