Privacy Policy

The Good Growing Club website is a brand owned by UPL Europe Ltd.

UPL Europe Ltd (“we“, “us”, “UPL” or “our“) takes data protection seriously. We recognise the trust that individuals place in us when they provide us with Personal Data and we are committed to protecting the privacy and security of Personal Data.

In this policy, the term “you” refers to any natural person whose personal data we collect and process in the course of operating this website.

This Privacy Policy is intended to help you understand our practices regarding the collection, use and disclosure of Personal Data. To do this, we explain the following:

Who is controller for the processing of your Personal Data
What Personal Data we collect from you
How we obtain your Personal Data
How we use cookies on this website
How we use your Personal Data
With whom we share your Personal Data
To which countries we transfer your Personal Data
How long we store your Personal Data
How we protect your Personal Data
What rights you have in relation to your Personal Data
How you can contact us
How we will update this Privacy Policy

By providing us with your Personal Data on this website, you agree to the processing set out in this Privacy Policy. Further notices highlighting specific uses of your Personal Data and the ability to opt in or out of selected uses may also be provided to you when we collect Personal Data from you.

This Privacy Policy is intended to help you understand our practices regarding the collection, use and disclosure of Personal Data. To do this, we explain the following:

Who is controller for processing your Personal Data

The controller responsible for the processing of your personal data is

UPL Europe Ltd

The Centre, 1st Floor

Birchwood Park

Warrington

Cheshire

United Kingdom

WA3 6YN

What Personal Data we collect from you

Personal Data (hereinafter referred to as “Personal Data“) is information (in any format) that relates to a living individual who can be identified from that information, either alone or when combined with other information held by us.

We may collect and process various types of Personal Data in the course of operating this website. These include:

Technical data about your end device or internet connection such as IP address, browser information, language settings, information about the operating system;
Cookies and other identifiers that we store or read on your end device (see also section 4);
basic Personal Data such as your name and contact details, such as your e-mail address, telephone number, country and state, if you provide us with this information via our contact form;
Information about your business, such as your company name and partner type, if you provide us with this information via the contact form;
Information about our products that you are interested in when you provide us with this information via the contact form;
All contents of messages that you send us via the contact form.

How we obtain your Personal Data

We may collect or receive your Personal Data in various ways:

We receive technical data automatically when you visit our website; we set and read cookies according to the settings you have made in the cookie settings (see section 4);
We receive data that you enter via the contact form when you send it.

How we use cookies on this website

To find out more about our use of cookies, visit our Cookie Policy .

How we use your Personal Data

We only use your Personal Data if we are authorised to do so under applicable law.

Under EU and UK data protection law, the use of Personal Data must be justified on a number of legal grounds. The main legal bases that justify our use of your Personal Data are:

Contract Fulfillment: If your data is required for the conclusion or fulfillment of our contract with you.
Legal Obligation: If we need to use your data to fulfill our legal obligations.
Legitimate Interests: Where we use your data to achieve a legitimate interest and our reasons for doing so outweigh any prejudice to your data protection rights.
Legal Claims: If your information is required for the defense, prosecution, or assertion of a claim against you, us, or a third party.
Consent: Where you have consented to our use of your data (you have been provided with a consent form or a consent notice in relation to such use and can withdraw your consent at any time).

We may use your Personal Data in the following ways. In each case, we note the legal basis we rely on when using your Personal Data.

Purposes of the processing	Processing details	Type of Personal Data	Legal bases of processing
Displaying the contents of the website	To be able to display the information on this website on your device and to enable your interaction on the website	Technical data; cookies (in accordance with the more detailed provisions under section 4)	– Legitimate interests in operating our website
Security and fraud prevention	To prevent attacks on our website and combat fraud	Technical data without permanent storage	– Legitimate interests in protecting our website and IT infrastructure
Analysis and development purposes	To improve the content and user experience of our website	Cookies (in accordance with the more detailed provisions under section 4)	– Consent (for more details on Cookies see section 4)
For communication purposes	To answer your enquiries that you send us via our contact form	Basic Personal Data; contact details; information about our products; information about your business; content of your messages to us	– Legitimate interests to get in touch with you and answer your questions

With whom we share your Personal Data

UPL is a global organisation. As such, any Personal Data that we collect or that you provide to us may be shared and processed with any UPL entity in our global network.

We may also share your Personal Data with third party service providers to whom we outsource certain functions such as information and document management, office support, technology and IT services, customer relationship management, word processing, photocopying and translation services. We have entered into agreements with these service providers to protect the confidentiality and security of the information (including Personal Data) shared with them.

We do not authorise our third-party providers to use your Personal Data for their own purposes, but only to process your Personal Data for specific purposes and in accordance with our instructions.

We may also process your Personal Data to comply with our regulatory requirements or as part of our dialogue with our regulators, which may include disclosing your Personal Data to governmental, regulatory or law enforcement authorities in connection with any request, proceeding or investigation by such parties anywhere in the world or where required. Where permitted or where it would not prejudice the prevention or detection of a criminal offence, we will make such a request to you or notify you before responding.

To which countries we transfer your Personal Data

As a global organisation, we cannot limit our processing of an individual’s Personal Data to the country in which that individual is located. In the course of providing our services, we may need to transfer Personal Data to locations outside of the jurisdiction in which you provide it or in which you visit our website. If you are a resident of the United Kingdom (UK) or the European Economic Area (EEA), this means that your Personal Data may be transferred to, accessed from, and/or stored at a destination outside the UK/EEA where data protection laws may not be as comprehensive as those in the UK/EEA.

Regardless of where we process your Personal Data, we will apply the same data protection measures that we apply within the UK/EEA and take appropriate steps to ensure that your Personal Data is protected in accordance with applicable data protection laws. Similarly, where a third-party provider processes the Personal Data of EEA or UK residents on our behalf, we will ensure that appropriate measures are in place to ensure an adequate level of protection for your Personal Data, typically by including standard contractual clauses in our agreements with those third-party providers.

In the event that there is no adequacy decision in relation to the country to which your Personal Data is transferred, appropriate safeguards will be implemented in addition to the standard contractual clauses to ensure the protection of your Personal Data. These measures may be of a contractual, organizational, or technical nature.

Please contact us as set out below if you would like to see a copy of the specific safeguards in place for the export of your Personal Data.

How long we store your Personal Data

We will retain your Personal Data for as long as necessary to fulfill the purpose for which it was collected and any other permitted associated purposes. If your Personal Data is used for two purposes, we will store it until the purpose with the last period expires. However, we will no longer use it after this period for the purpose with a shorter period. Our retention periods are also based on our business requirements and best practices.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

Technical data that we process automatically for the display and use of the website is only stored temporarily during your website visit and then deleted. Data that you provide to us via the contact form will be stored by us for up to three years after the end of the communication. Data may be processed for longer if you have given your consent.

How we protect your personal data

We recognize that information security is an integral part of data protection. Although no data transmission (including over the internet or a website) can be guaranteed against intrusion, we implement a range of commercially reasonable physical, technical, and procedural measures to protect Personal Data from unauthorized access, use, disclosure, alteration, or destruction in accordance with data protection requirements.

Information you provide to us will be stored on our or our service providers’ secure servers and accessed and used in accordance with our security policies and standards or the policies and standards agreed with our service providers.

Everyone at UPL and any third-party providers that we may engage to process Personal Data on our behalf (for the purposes listed above) are also contractually obliged to respect the confidentiality of Personal Data.

What rights you have in relation to your Personal Data

If you have any questions about our use of your Personal Data, you should contact us in the first instance using the contact details set out in section 11 below. In certain circumstances, and in accordance with UK/EU data protection laws, you may have the right to request that we:

provide you with further information about the use of your Personal Data;
provide them with a copy of the Personal Data we hold about you;
update any inaccuracies in the Personal Data we hold;
delete all Personal Data for which we no longer have a legitimate reason to use;
If the processing is based on consent, you have the right to withdraw your consent so that we stop this particular processing.
You may object to any processing based on legitimate interests, unless our reasons for carrying out this processing outweigh any limitation to your data protection rights;
restrict the way we use your Personal Data while a complaint is being investigated.

If you contact us to exercise one of these rights, we will review your claim and usually respond within one month.

If you are not satisfied with our use of your personal data or our response to the exercise of these rights, you have the right to lodge a complaint with the competent supervisory authority (data protection authority). You can find the competent data protection authorities in Europe through the European Data Protection Board (EDPB) website, which provides a comprehensive list of national data protection authorities along with their contact information. The EDPB website can be accessed at: https://edpb.europa.eu/about-edpb/board/members_en.

How you can contact us

If you have any questions about this Privacy Policy or the processing of your Personal Data, please contact our data protection officer by e-mail to: legal.europe@upl-ltd.com.