Privacy and Data Protection Policy
Welcome to the Miri Growth Ltd Privacy and Data Protection Policy (“Privacy Policy”).

At Miri Growth Ltd (“Miri”, “we”, “us”, or “our”), we are committed to protecting and respecting your privacy and personal data in compliance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and other relevant UK data privacy laws.

This Privacy Policy explains how we collect, use, store, and protect your data, as well as your privacy rights and how the law protects you. It also outlines the data responsibilities of Miri employees and staff members.

This Privacy Policy applies to personal data processed by us when you visit our website, contact us, or engage with our communications and marketing activities.

Who is your Data Controller
Miri Growth Ltd is the Data Controller and determines the purposes and means of processing your personal data.

• Company name: Miri Growth Ltd.
• Address: 34 Bow Street, London, WC2E 7AU.
• Email contact for privacy matters: info@mirigrowth.com.
• ICO Registration Number: ZA711024.

You have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at www.ico.org.uk. However, we encourage you to contact us first to resolve any concerns.

Our use of data processors and HubSpot
To support our operations, we use trusted third-party service providers (known as “Processors”) who handle data on our behalf under contract. These include:

• HubSpot, a customer relationship management (CRM) platform we use for marketing automation, email communications, lead capture, and sales pipeline management. HubSpot collects and processes data such as IP addresses, email engagement, form submissions, and website usage (via cookies and tracking technologies). This helps us understand and serve our website visitors, improve our marketing and sales efforts, and communicate more effectively with potential and existing clients.

All our Processors, including HubSpot, are contractually bound to maintain appropriate data security standards and are only permitted to process your data under our instruction and for specified purposes.

Legal basis for data collection
We may collect, use, store, and transfer different kinds of personal data about you. This includes:

• Contact Data: Such as name, email address, phone number, company name, and any details you provide in a contact or enquiry form.
  Legal basis: Legitimate interest (to respond to your query and follow up).

• Marketing and Communication Data: Preferences for receiving communications from us, including newsletters, updates, or event invites.
  Legal basis: Consent.

• Job Application Data: Including CVs, cover letters, and associated contact information submitted when applying for a role with Miri.
  Legal basis: Contract (pre-contractual steps), Legal obligation (e.g. under the Equality Act 2010), and where applicable, Article 9(2)(b) for processing sensitive data.

• Technical and Usage Data: IP address, browser type, device information, pages visited, and other analytics data. This may be collected via cookies and tracking tools such as those embedded through HubSpot.
  Legal basis: Consent (where required), Legitimate interest (e.g. to ensure website functionality, performance, and security).

Miri will only process your personal data for the purposes for which you provided it—such as responding to enquiries, supporting recruitment, or communicating with you (if you have opted in). We do not sell your data or use it for unrelated purposes.

Legal bases explained
Under the UK GDPR, we rely on the following legal bases:

• Consent – where you have clearly agreed to us processing your data (e.g. signing up to newsletters).

• Contract – where processing is necessary to deliver a service you requested.

• Legal Obligation – where required by law (e.g. employment regulations).

• Legitimate Interests – where processing is necessary for our business operations, and does not override your rights or interests. A Legitimate Interest Assessment (LIA) is conducted in these cases.

How we use HubSpot data
When you submit a form on our website or engage with our emails, HubSpot may collect associated data, including:

• pages you visit before and after submitting a form\your IP address and device information
• email opens, clicks, and bounces
• source/referral data (e.g. which channel led you to us).

This information helps us:

• understand what services you’re interested in
• follow up with you more effectively
• tailor our communications to be more relevant
• measure the effectiveness of our marketing activity

You can opt out of marketing emails or cookie tracking at any time using the unsubscribe links or cookie settings banner.

Your rights
You have rights under data protection laws in relation to your personal data. These include:

• the right to access your data
• the right to correct your data
• the right to request erasure
• the right to object to processing
• the right to withdraw consent
• the right to data portability

To exercise any of these rights, please email us at info@mirigrowth.com.

Retention and security
We only retain personal data for as long as necessary to fulfil the purposes we collected it for, including legal, accounting, or reporting requirements.

Data is stored securely and protected using appropriate technical and organisational measures to prevent unauthorised access, disclosure, alteration, or loss.

Updates to this Privacy Policy
We may update this Privacy Policy from time to time. Any significant changes will be communicated via our website or by direct communication where appropriate.

Last updated: 14/05/2025