Privacy Policy
Last Updated: JULY 2026
Introduction
GrowCFO is committed to protecting your privacy and handling your personal information responsibly, transparently and securely.
This Privacy Policy explains how Grow CFO Limited collects, uses, stores, shares and protects personal information when you use our websites, learning platform, products and services. It also explains your privacy rights and how you can exercise them.
This Privacy Policy applies to personal information collected through:
- www.growcfo.net
- www.growcfoacademy.com
- the GrowCFO Academy
- GrowCFO events, webinars and virtual conferences
- mentoring, coaching and advisory services
- professional development programmes
- competency assessments and learning pathways
- newsletters and marketing communications
- any other products or services provided by Grow CFO Limited.
Please read this Privacy Policy to understand how we process your personal information when you interact with GrowCFO.
1. Who We Are
Grow CFO Limited is the organisation responsible for collecting and processing the personal information described in this Privacy Policy.
For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Grow CFO Limited acts as the Data Controller for the personal information we collect through our websites, learning platform and services.
Registered Office
Grow CFO Limited
124 City Road
London
EC1V 2NX
United Kingdom
If you have any questions about this Privacy Policy or how we process your personal information, please contact our Privacy Lead:
Email: support@growcfo.net
If we are processing personal information on behalf of a corporate customer under a separate agreement, GrowCFO may act as a Data Processor for certain activities. Where this applies, the responsibilities of each party will be set out in the relevant contractual documentation.
2. Information We Collect
The personal information we collect depends on how you interact with GrowCFO and the services you use.
Some information is provided directly by you, some is generated through your use of our learning platform, and some is collected automatically to help us operate and improve our services.
We collect only the information that is necessary to provide our services, meet our legal obligations and improve your experience.
Information You Provide Directly
You may provide personal information when you:
- create a GrowCFO account
- register for a webinar, event or programme
- purchase a membership, course or other service
- subscribe to newsletters or marketing communications
- complete competency assessments or questionnaires
- participate in mentoring, coaching or advisory programmes
- contact our support team
- complete surveys or provide feedback
- participate in learning activities within GrowCFO Academy.
Depending on the services you use, this information may include:
- name
- email address
- telephone number
- company or organisation
- job title
- country or region
- billing and invoicing information
- account login credentials
- learning preferences
- career aspirations
- communications with GrowCFO
- survey responses
- customer support enquiries.
Payment card information is processed securely by our authorised payment providers. GrowCFO does not store your full payment card details.
Learning and Development Information
As you use GrowCFO Academy and participate in learning programmes, we create records that help deliver and personalise your learning experience.
These records may include:
- competency assessment responses
- self-assessments
- learning activity
- course enrolments
- course progress
- quiz and assessment results
- certificates and Continuing Professional Education (CPE) records
- competency profiles
- Growth Missions
- personalised learning recommendations
- learning pathway selections.
This information enables us to deliver your chosen programmes, personalise your learning journey and measure your progress over time.
AI-Powered Learning Information
Some GrowCFO services use Artificial Intelligence (AI) to provide personalised learning experiences and faster feedback.
Where you choose to use these services, we may process information such as:
- assessment responses
- competency ratings
- career aspirations
- learning activity
- written submissions
- audio recordings
- video recordings
- speech transcripts
- AI-generated summaries
- AI-generated feedback
- AI-generated competency scores
- AI-generated learning recommendations.
Core AI functionality forms part of certain GrowCFO learning services and is used to deliver personalised learning experiences.
Where AI features are optional—for example, submitting recordings for AI analysis or using enhanced AI feedback tools—we will make this clear within the relevant service.
AI-generated outputs are intended solely to support learning and professional development. They are not intended to replace human judgement or be used as the sole basis for employment, promotion, compensation, disciplinary or other decisions that produce legal or similarly significant effects.
Information Collected Automatically
When you visit our websites or use GrowCFO Academy, we automatically collect certain technical information to help operate, secure and improve our services.
This may include:
- IP address
- browser type and version
- device type
- operating system
- language settings
- approximate geographic location
- pages visited
- features used
- time spent using our services
- referral source
- dates and times of access
- cookie and similar technology information.
We use this information to maintain the security and performance of our platforms, understand how our services are used and improve the user experience.
Information We Receive from Third Parties
In some circumstances, we receive personal information from trusted third parties where this is necessary to provide our services.
This may include information provided by:
- your employer or organisation where they purchase GrowCFO services on your behalf
- payment providers confirming successful transactions
- event partners administering joint webinars or conferences
- identity and authentication providers used to access our services
- other service providers where necessary to deliver the services you have requested.
We only receive the information that is necessary for the relevant purpose and process it in accordance with this Privacy Policy.
3. How We Use Your Information
We use your personal information to deliver our services, personalise your learning experience, improve our products, maintain the security of our platforms and meet our legal and contractual obligations.
The ways we use your information include the following.
Delivering Our Services
We use your information to:
- create and manage your GrowCFO account
- provide access to GrowCFO Academy, courses and memberships
- deliver mentoring, coaching, advisory and professional development programmes
- register you for webinars, events and virtual conferences
- administer purchases, subscriptions and renewals
- process payments and maintain billing records
- issue certificates and Continuing Professional Education (CPE) records
- respond to enquiries and provide customer support.
Personalising Your Learning Experience
We use information about your learning activity to tailor your experience and recommend relevant development opportunities.
This may include:
- generating competency profiles
- creating personalised Growth Missions
- recommending courses, programmes and learning pathways
- tracking learning progress
- providing personalised dashboards and development insights
- helping you monitor your professional development over time.
Where AI forms part of the service, it may also be used to generate learning recommendations, summaries and feedback designed to support your professional development.
Improving Our Products and Services
We continually review how our websites, Academy and services are used to improve functionality, content and user experience.
This may include using information to:
- understand how users interact with our websites and learning platform
- improve course content and learning journeys
- develop new features and services
- identify technical issues
- monitor system performance
- improve accessibility, usability and reliability.
Where possible, we use aggregated or anonymised information for analysis and reporting.
Communicating With You
We use your information to:
- send important service announcements
- notify you about programme updates
- respond to support requests
- provide administrative communications relating to your account
- send newsletters, marketing communications and event invitations where permitted by law or where you have chosen to receive them.
You can unsubscribe from marketing communications at any time by using the unsubscribe link included in our emails or by contacting us.
Protecting Our Platform
We process information to help maintain the security, integrity and availability of our systems.
This includes:
- detecting and preventing fraud
- monitoring for unauthorised access
- investigating security incidents
- maintaining audit logs
- protecting the rights, property and safety of GrowCFO, our customers and other users.
Meeting Legal and Regulatory Obligations
We may process personal information where necessary to:
- comply with applicable laws and regulations
- maintain financial and tax records
- respond to lawful requests from regulatory authorities
- establish, exercise or defend legal claims
- meet our contractual obligations.
Our Commitment to Responsible AI
Where GrowCFO uses Artificial Intelligence to support learning, the technology is designed to enhance—not replace—human judgement.
We do not use personal information to make automated decisions that produce legal or similarly significant effects, such as decisions relating to employment, promotion, compensation or disciplinary action.
AI-generated assessments, recommendations and competency insights are intended solely to support learning and professional development and should not be used as the sole basis for employment or other significant decisions.
4. Legal Basis for Processing
I would rewrite Section 4 to make it more transparent and better aligned with the ICO’s expectations. Rather than just listing legal bases, explain why each applies. This is easier for users to understand and gives enterprise customers more confidence that GrowCFO has thought through its GDPR obligations.
- Our Legal Basis for Processing Personal Information
Under the UK General Data Protection Regulation (UK GDPR), GrowCFO must have a lawful basis for processing personal information.
The lawful basis we rely on depends on the purpose for which we use your information.
Purpose | Lawful Basis |
Creating and managing your GrowCFO account | Performance of a contract |
Delivering courses, memberships, mentoring and professional development programmes | Performance of a contract |
Providing personalised learning pathways, competency profiles and Growth Missions | Performance of a contract |
Registering you for webinars, events and conferences | Performance of a contract |
Processing payments and managing subscriptions | Performance of a contract |
Responding to enquiries and providing customer support | Performance of a contract and, where appropriate, our legitimate interests in providing effective customer service |
Maintaining platform security, preventing fraud and protecting our systems | Legitimate interests |
Monitoring, maintaining and improving our websites, Academy and services | Legitimate interests |
Analysing platform usage and service performance | Legitimate interests (using aggregated or pseudonymised information where appropriate) |
Sending marketing communications | Consent, or where permitted by law, our legitimate interests (for example, where the soft opt-in applies) |
Optional AI features, optional recordings or optional sharing of AI-generated outputs | Consent where required |
Complying with legal, regulatory and tax obligations | Legal obligation |
Establishing, exercising or defending legal claims | Legitimate interests |
AI Processing
Some GrowCFO services use Artificial Intelligence as part of the learning experience.
Where AI functionality is an integral part of a service you have chosen to use—such as generating personalised learning recommendations, competency insights or Growth Missions—we process the information necessary to provide that service as part of our contractual obligations to you.
Where AI functionality is optional—for example, submitting recordings for AI analysis or using optional AI-powered feedback tools—we will rely on consent where required by applicable law.
Legitimate Interests
Where we rely on legitimate interests as our lawful basis, we carefully balance our interests against your rights and freedoms.
Our legitimate interests include:
- improving our products and services
- maintaining the security and integrity of our systems
- preventing fraud and misuse
- providing effective customer support
- understanding how our services are used
- developing new features and learning experiences.
We only rely on legitimate interests where we believe that our processing is proportionate and does not override your rights and freedoms.
Consent
Where we rely on your consent, you are free to withdraw it at any time.
Withdrawing consent will not affect the lawfulness of any processing carried out before your consent was withdrawn.
Please note that if you withdraw consent for certain optional features, those features may no longer be available to you. However, withdrawing consent for optional processing will not affect your access to the core services you have purchased, unless that processing is essential to delivering those services.
5. Artificial Intelligence (AI)
GrowCFO uses Artificial Intelligence (AI) to enhance learning, personalise professional development and provide timely, relevant feedback to learners.
Our AI capabilities are designed to support learning and development by helping users identify strengths, explore development opportunities and access personalised learning experiences. AI is intended to assist users—not replace human judgement or professional expertise.
How We Use AI
Depending on the GrowCFO services you use, AI may be used to:
- analyse competency assessment responses
- generate personalised competency profiles
- recommend courses, programmes and learning pathways
- create personalised Growth Missions
- generate learning recommendations and development insights
- provide coaching suggestions
- summarise learning progress
- analyse written responses submitted as part of learning activities
- transcribe audio or video recordings
- analyse communication exercises where these features are available.
Not every GrowCFO service uses AI, and some AI-powered features are optional. Where optional AI features are available, this will be made clear within the relevant service.
Information Processed by AI
Depending on the features you choose to use, AI may process information such as:
- assessment responses
- competency ratings
- self-assessments
- career aspirations
- learning activity
- written submissions
- audio recordings
- video recordings
- speech transcripts
- AI-generated summaries
- AI-generated feedback
- AI-generated competency scores
- personalised learning recommendations.
We only process the information necessary to deliver the AI-enabled features you choose to use.
AI Service Providers
To deliver AI-powered functionality, GrowCFO works with carefully selected third-party technology providers.
These may include:
- OpenAI
- Amazon Web Services (AWS), including services such as Amazon Transcribe and Amazon Rekognition
- other specialist AI service providers that support the GrowCFO platform.
These providers process personal information only on GrowCFO’s documented instructions and under contractual agreements designed to protect personal information and comply with applicable data protection legislation.
Where applicable, we implement appropriate safeguards for international transfers of personal information as described in Section 7 of this Privacy Policy.
Automated Profiling
Some GrowCFO services generate competency profiles using information such as:
- assessment responses
- learning activity
- self-assessments
- career aspirations
- manager or peer feedback (where applicable).
These competency profiles help personalise learning by identifying strengths, highlighting development opportunities and recommending relevant learning content.
The profiling carried out by GrowCFO is intended solely to support learning and professional development.
Responsible Use of AI
GrowCFO believes AI should be used responsibly, transparently and with appropriate human oversight.
We do not use AI to make decisions that produce legal or similarly significant effects for individuals.
In particular, GrowCFO does not use AI to make decisions relating to:
- recruitment
- employment
- promotion
- compensation
- disciplinary action
- redundancy
- financial decisions
- any other decisions with legal or similarly significant effects.
AI-generated competency scores, recommendations and learning insights are intended solely to support learning and professional development.
For corporate programmes, GrowCFO expects organisations to use AI-generated outputs as one source of development information alongside human judgement. They should not be used as the sole basis for employment or talent management decisions.
Human Review
AI-generated feedback may occasionally be incomplete or inaccurate.
If you believe an AI-generated assessment, recommendation or competency profile is inaccurate, or you would like additional context, you may request that a member of the GrowCFO team reviews the output.
To request a review, please contact:
6. Sharing Your Information
GrowCFO respects the confidentiality of your personal information. We do not sell your personal information and only share it where necessary to deliver our services, comply with legal obligations or protect our legitimate business interests.
The information we share, and the recipients with whom we share it, depends on the services you use.
Service Providers
We work with carefully selected third-party service providers who help us deliver and support our websites, Academy and professional development services.
Depending on the services you use, these providers may assist with:
- cloud hosting and infrastructure
- learning management
- artificial intelligence services
- payment processing
- customer relationship management (CRM)
- email delivery
- video conferencing and virtual events
- customer support
- website analytics
- authentication and security monitoring.
These providers process personal information only on our documented instructions and are contractually required to protect personal information, maintain appropriate security measures and comply with applicable data protection legislation.
A current list of our key subprocessors is available upon request.
Employer-Sponsored Programmes
Where your employer or organisation provides your GrowCFO membership or learning programme, we may share information necessary to administer that programme.
Depending on the programme, this may include:
- enrolment status
- course completion
- certification status
- Continuing Professional Education (CPE) records
- agreed learning progress reports
- high-level competency reporting where this forms part of the programme.
Unless participants have been clearly informed in advance and the relevant programme terms expressly provide for it, GrowCFO does not share the following with employers:
- individual assessment responses
- self-assessment answers
- audio or video recordings
- speech transcripts
- detailed AI-generated feedback
- detailed competency reports
- personalised learning recommendations.
Where aggregated or anonymised reporting is provided, individuals will not be identifiable.
Business Partners
Some GrowCFO webinars, conferences and events are delivered in partnership with other organisations.
Where you register for a jointly delivered event, we may share your registration details with the relevant event partner where this has been clearly communicated at the point of registration or is necessary to administer the event.
Business Transfers
If GrowCFO is involved in a merger, acquisition, investment, corporate restructuring or sale of assets, personal information may be transferred as part of that transaction.
If this happens, we will ensure appropriate safeguards remain in place and will notify affected individuals where required by law.
Legal Requirements
We may disclose personal information where necessary to:
- comply with applicable laws and regulations
- respond to lawful requests from courts, regulators or public authorities
- establish, exercise or defend legal claims
- protect the rights, property or safety of GrowCFO, our customers or others
- investigate or prevent fraud, security incidents or other unlawful activity.
7. International Transfers
GrowCFO is based in the United Kingdom. Some of the trusted service providers we use to deliver our services may process personal information outside the UK.
Where personal information is transferred internationally, we ensure appropriate safeguards are in place to protect it in accordance with UK data protection legislation.
Depending on the destination country, these safeguards may include:
- adequacy regulations recognised by the UK Government
- the UK International Data Transfer Agreement (IDTA)
- the UK Addendum to the EU Standard Contractual Clauses (SCCs)
- other transfer mechanisms permitted under applicable law.
Where required, we also assess the risks associated with international transfers and take additional technical or contractual measures to protect personal information.
Regardless of where personal information is processed, GrowCFO requires its service providers to maintain appropriate security standards and protect personal information in accordance with applicable data protection legislation.
8. Data Retention
We retain personal information only for as long as it is necessary to provide our services, fulfil our contractual and legal obligations, resolve disputes and protect our legitimate business interests.
Our typical retention periods are shown below.
Information | Typical Retention Period |
Account information | While your account remains active |
Learning records | While your account remains active |
Course completion history | While your account remains active |
Competency profiles and AI assessment results | While your account remains active |
Marketing contacts | Until you unsubscribe or request deletion |
Event registrations | Up to 2 years |
Customer support enquiries | Up to 3 years |
Financial and tax records | 6 years, or longer where required by law |
If you close your GrowCFO account, we will normally delete or anonymise your personal information from our active systems within 90 days unless we are legally required to retain it.
Certain information may remain in secure system backups for a limited period before being automatically overwritten in accordance with our backup retention procedures.
Where information has been permanently anonymised so that individuals can no longer be identified, we may retain it for statistical analysis, service improvement and research purposes.
Where legal proceedings, regulatory investigations or contractual obligations require us to retain information for longer, we may retain the relevant information until those obligations have been fulfilled.
9. Cookies and Similar Technologies
GrowCFO uses cookies and similar technologies to ensure our websites function correctly, improve user experience and understand how our services are used.
Some cookies are essential for our websites and Academy to operate. Others help us remember your preferences, analyse website usage or measure the effectiveness of our communications.
The types of cookies we use include:
Essential Cookies
These cookies are necessary for the operation, security and functionality of our websites and learning platform. They cannot be disabled through our cookie preference centre.
Functional Cookies
These cookies remember your preferences, such as login information and user settings, to improve your experience.
Analytics Cookies
With your consent where required, analytics cookies help us understand how visitors use our websites so we can improve performance, usability and content.
Where possible, analytics information is collected in aggregated or pseudonymised form.
Marketing Cookies
Where you have given your consent, marketing cookies help us understand the effectiveness of our marketing campaigns and deliver communications that are more relevant to your interests.
You can manage your cookie preferences at any time using our cookie preference centre or through your browser settings.
Please note that disabling certain cookies may affect the functionality of some parts of our websites or Academy
10. Information Security
Protecting personal information is fundamental to the way GrowCFO operates.
We maintain an Information Security Management System (ISMS) and implement appropriate technical, organisational and administrative measures designed to protect the confidentiality, integrity and availability of the personal information we process.
Our security measures include, where appropriate:
- encryption of data in transit using HTTPS/TLS
- encryption of data at rest where appropriate
- role-based access controls
- multi-factor authentication
- secure password management
- audit logging and monitoring
- regular vulnerability management and security reviews
- backup and disaster recovery procedures
- supplier security assessments
- confidentiality obligations for employees and contractors
- security awareness training
- incident response and breach management procedures.
We regularly review and improve our security controls to respond to evolving threats and changes in technology.
While no online service can guarantee absolute security, we are committed to maintaining appropriate safeguards to protect the personal information entrusted to us.
If you believe your GrowCFO account has been compromised or you suspect a security incident involving your personal information, please contact us as soon as possible at support@growcfo.net.
11. Your Privacy Rights
Depending on where you live and the data protection laws that apply to you, you may have certain rights regarding the personal information GrowCFO holds about you.
If you are covered by the UK General Data Protection Regulation (UK GDPR), your rights include:
Right of Access
Right to Rectification
Right to Erasure
In certain circumstances, you may ask us to delete your personal information. This right is not absolute and may be limited where we are legally required to retain information or where we have another lawful basis for continuing to process it.
Right to Restrict Processing
Right to Object
Where we rely on our legitimate interests as the lawful basis for processing, you have the right to object to that processing.
You also have the right to object to receiving direct marketing communications at any time.
Right to Data Portability
Right to Withdraw Consent
Where we rely on your consent, you may withdraw that consent at any time.
Withdrawing consent will not affect any processing carried out before your consent was withdrawn.
AI-Assisted Learning
GrowCFO uses AI to support learning and professional development.
If you believe an AI-generated assessment, competency profile, recommendation or feedback is inaccurate, misleading or incomplete, you may request that a member of the GrowCFO team reviews the output.
Where appropriate, we will investigate your concerns and explain how the output was generated.
To request a review, please contact:
Making a Privacy Request
To exercise any of your privacy rights, please contact:
We may need to verify your identity before responding to your request.
We will respond within the timeframes required by applicable data protection legislation.
Complaints
If you have concerns about how we have handled your personal information, we encourage you to contact us first so that we have the opportunity to resolve your concerns.
If you remain dissatisfied, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).
Information Commissioner's Office
12. Member Directory
GrowCFO Academy includes an optional Member Directory designed to help members connect, collaborate and build professional relationships within the finance community.
Participation in the Member Directory is entirely optional.
You can choose whether your profile appears in the directory and may change your preference at any time through your account settings.
If you choose to participate, other members may be able to view information such as:
- your name
- job title
- organisation
- membership level
- professional profile information that you choose to share.
The following information is never displayed through the Member Directory:
- email address
- telephone number
- billing information
- assessment responses
- competency scores
- AI-generated feedback
- learning progress
- private account information.
GrowCFO does not make Member Directory information publicly available through internet search engines.
13. Additional Privacy Rights for California Residents
This section applies only to individuals who are residents of California.
Subject to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California residents may have additional privacy rights.
These rights may include:
- the right to know what personal information we collect
- the right to access personal information
- the right to request correction of inaccurate personal information
- the right to request deletion of personal information
- the right to limit the use of certain sensitive personal information where applicable
- the right to opt out of the sale or sharing of personal information where applicable.
GrowCFO does not sell personal information or share personal information for cross-context behavioural advertising.
We will not discriminate against anyone for exercising their privacy rights.
Requests may be submitted to:
14. Children's Privacy
GrowCFO’s products and services are designed for finance professionals, businesses and adult learners.
Our services are not intended for children under the age of 16, and we do not knowingly collect personal information from children.
If we become aware that personal information relating to a child has been collected without appropriate authorisation, we will take reasonable steps to delete that information promptly.
If you believe a child has provided personal information to GrowCFO, please contact us at:
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to:
- our products and services
- technology
- security practices
- legal or regulatory requirements
- business operations.
When we make changes, we will update the “Last Updated” date at the beginning of this Privacy Policy.
Where changes are significant, we may also notify users through our websites, GrowCFO Academy, email communications or other appropriate channels.
We encourage you to review this Privacy Policy periodically so that you remain informed about how we protect your personal information.
16. Contact Us
If you have any questions about this Privacy Policy or how GrowCFO processes personal information, please contact us.
Grow CFO Limited
124 City Road
London
EC1V 2NX
United Kingdom
Email: support@growcfo.net
Supervisory Authority
Information Commissioner's Office
Website: https://ico.org.uk
