Our Privacy Policy

1. Introduction

Surgeflow Growth Ltd ("we," "us," or "our") is committed to safeguarding your privacy. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you interact with us.

Our Role: When working with client-provided data, Surgeflow Growth Ltd acts as a Data Processor on behalf of the client, who remains the Data Controller. We process personal data strictly in accordance with the client’s instructions and applicable data protection laws, including the UK GDPR and the Privacy and Electronic Communications Regulations (PECR).

2. Information We Collect

We may collect the following personal information:

Personal Identification Information: Name, email address, and phone number.

Usage Data: Information on how you interact with our communications and services.

3. How We Collect Information

We collect personal information through:

Direct Interactions: When you provide data by filling in forms, subscribing to our services, or corresponding with us via email or phone.

Third-Party Sources: Clients may share their customer databases with us for marketing and service delivery purposes.

4. How We Use Your Information

We use your personal information for:

Service Delivery: To provide and manage our services.

Marketing: To send promotional materials and updates, only to individuals who have previously consented to receive such communications, or who meet the soft opt-in criteria under PECR, as provided by our clients. All recipients are given the opportunity to opt out in every message.

Legal Basis for Processing - We process personal data on the basis of:

Legitimate Interests, where those interests are not overridden by the rights and freedoms of the data subject.

Consent, where required, particularly in the context of electronic marketing. We rely on either direct consent obtained during previous interactions, or consent provided by the Data

Controller (our client).

Use of Data: We do not use any personal data for purposes outside of the client’s instructions. All processing is conducted solely to support the intended campaign or service delivery as specified by the Data Controller.

5. Sharing Your Information

We share your information with:

Service Providers: We use GoHighLevel to process and store data. Please refer to their privacy policy for more details: GoHighLevel

6. Data Security

We implement appropriate security measures to protect your personal information. All data is stored securely within GoHighLevel's platform, which complies with industry-standard security protocols.

Data Transfers: Data may be stored in the United States or other jurisdictions, subject to appropriate safeguards under UK GDPR, such as Standard Contractual Clauses or other equivalent legal mechanisms provided by our processors to ensure a lawful and secure transfer of data outside the UK or EU.

7. Data Retention

We retain personal data for as long as it is deemed necessary to fulfill the purposes for which it was collected, including to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. Where appropriate, we may retain data for analytical purposes or to improve future campaign performance.

Once personal data is no longer required, we will securely delete or anonymize it in accordance with applicable laws and best practices.

8. Your Data Protection Rights

Depending on your location, you may have the following rights regarding your personal data:

Access: Request a copy of the personal data we hold about you.

Rectification: Request correction of inaccurate or incomplete data.

Erasure: Request deletion of your personal data under certain conditions.

Restriction: Request restriction of processing your data under certain conditions.

Objection: Object to processing your data under certain conditions.

Data Portability: Request transfer of your data to another organization or directly to you under certain conditions.

To exercise these rights, please contact us at:[email protected]

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this Privacy Policy periodically.

10. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at: Email:[email protected]