Privacy Policy

 

1. Introduction

This Privacy Policy outlines how Growth Mode Ltd (trading as Revenue Funnel) collects, uses, discloses, and protects your personal data. We are committed to safeguarding your privacy and ensuring compliance with the UK General Data Protection Regulation (UK GDPR).

Growth Mode Ltd is a private limited company registered in England and Wales.

  • Company Number: 12325507
  • Registered Office: 203 West Street, Fareham, Hampshire, England, PO16 0EN

This policy applies to data collected through our website (revenuefunnel.co.uk), our client and partner portals, and all related services.

2. Data Protection Contact

For any questions regarding this policy or to exercise your data protection rights, please contact us at:

While we are not required to appoint a statutory Data Protection Officer (DPO), we have designated a data protection lead to oversee our compliance.

3. The Data We Collect

We collect and process personal data in several ways:

  • Information You Provide Directly: This includes your name, email address, phone number, job title, and company information when you fill out contact forms, subscribe to our newsletter, or communicate with us directly.
  • Information We Process on Behalf of Our Clients: When providing our services, particularly through our AI-powered client portal, we process customer data that our clients provide. In this capacity, we act as a data processor.
  • Information from Your Use of Our Website and Portals: We automatically collect technical information, including your IP address, browser type, and operating system, as well as information about your visit, such as pages viewed and interaction data. This is collected via cookies and similar technologies.
  • Information from Third Parties: We may occasionally receive information about you from other sources, such as public databases or business directories, for marketing and business development purposes.

4. How and Why We Use Your Data (Purposes and Lawful Bases)

We only use your personal data when the law allows us to. Each of our processing activities is justified by a “lawful basis” under the UK GDPR. The table below explains the main purposes for which we process your data and the corresponding lawful basis.

Purpose of Processing

Type of Data

Lawful Basis for Processing

To provide and manage our services (consulting, client portal, partner portal)

Contact details, business information, client customer data

Contractual Necessity (to fulfil our contract with you or your employer)

To manage our relationship with you (responding to enquiries, providing support)

Contact details, communication history

Legitimate Interests (to provide good customer service and manage our business)

For marketing and business development (sending newsletters and promotional materials)

Contact details, company information

Consent (where you have opted in) or Legitimate Interests (for certain business-to-business marketing)

To operate and improve our website and services (analytics, security monitoring)

Usage data, technical data

Legitimate Interests (to ensure our services are secure and effective)

To comply with legal and regulatory obligations

Transactional data, identity information

Legal Obligation

Where we rely on legitimate interests, we have carried out a balancing test to ensure our interests do not override your rights and freedoms.

5. Data Sharing and Our Processors

We do not sell your personal data. We only share it with trusted third-party service providers (data processors) who perform services on our behalf. We have written contracts in place with all processors to ensure they protect your data in line with UK GDPR requirements.

Our key data processors include:

Processor

Service Provided

Location

Data Processing Agreement

Manus

AI platform for our client portal

USA

View DPA

OpenAI

AI models for data analysis within our services

USA

View DPA

Replit

Hosting for our partner ecosystem portal

USA

View DPA

Google Workspace

Internal email, cloud storage, and collaboration tools

Global

View DPA

HubSpot

Customer Relationship Management (CRM)

USA

View DPA

ConvertKit

Email marketing and newsletter delivery

USA

View DPA

Resend

Transactional email delivery

USA

View DPA

Productive.io

Project management and business operations

Croatia (EU)

View DPA

6. International Data Transfers

Some of our data processors are based outside the United Kingdom (UK). When we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • The transfer is to a country that has been deemed to provide an adequate level of protection for personal data by the UK Government.
  • We use specific contracts approved by the UK which give personal data the same protection it has in the UK. These are known as the UK’s International Data Transfer Agreement (IDTA) or Standard Contractual Clauses (SCCs).

7. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means.

8. Your Data Protection Rights

Under the UK GDPR, you have the following rights in relation to your personal data:

  • Right of Access: You have the right to request a copy of the personal data we hold about you.
  • Right to Rectification: You have the right to have inaccurate personal data rectified, or completed if it is incomplete.
  • Right to Erasure: You have the right to request that we delete your personal data, under certain conditions.
  • Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
  • Right to Object to Processing: You have the right to object to our processing of your personal data, where we are relying on legitimate interests.
  • Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
  • Right to Withdraw Consent: Where we rely on your consent to process your data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us at info@revenuefunnel.co.uk.

9. Cookies and Tracking Technologies

Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. We use cookies for analytics, website functionality, and to remember your preferences. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

10. How to Complain

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

11. Changes to This Privacy Policy

We keep our privacy policy under regular review. This version was last updated on 27 February 2026. Any changes will be posted on this page.