Your Privacy, Our Priority

We are Global Purpose Enterprise (referred to as “we” or “us” or “our” or “GPE”) and operate a mobile application software called “Prgrss” (the “App”), enabling users of the app (“you”) to connect with senior professionals for career mentorship. We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you use our services via our App or visit our website (the “Website”). This Privacy Policy also tells you about your privacy rights and how the law protects you. Please see our Glossary for further information on some of the terms used in this Privacy Policy.

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process your personal data through your use of the App and/or Website, including any data you may provide when you arrange mentoring sessions through our website and mobile application. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This Privacy Policy (together with our Terms of Use) applies to your use of the Website and App as hosted on the Apple Inc. App Store and the Google LLC Google Play Store (“App Store Provider”), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (“Device"). It is important that you also read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices, terms and privacy policies and is not intended to override them.

The App and Website are not intended for individuals under the age of 18 and we do not knowingly collect data relating to minors. By using the Website and/or the App, you confirm that you are 18 years or older.

The App and Website, as well as this Privacy Policy, are provided by us, a company registered in England and Wales with company number 12513334 with our registered office located at Soho Works, 180 Strand, London, England, WC2R 1EA.

How to consent and withdraw consent

Before installation of this App, please indicate your consent to our processing of your personal data as described in our Privacy Policy by selecting ‘Accept and Finish’.

How you can withdraw consent: once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us [info@globalpurposeenterprise.com] but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Our Role

We are a data controller under the applicable data protection laws, of:

• any information you share with us via the App and/or Website, such as identity and contact information;
• any information you provide to our customer services, for example when requesting support with any technical issues.

Important Information and Who We Are

We have appointed a Data Protection Officer ("DPO") who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights as a data subject, please contact us using the details set out below.

You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK regulator for data protection issues (www.ico.org.uk) or any other competent data protection authority in the relevant jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the other relevant authority so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review.

This version was last updated on 17/10/24. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the App.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third-party links

Our App, websites of our third-party service providers, partner networks, advertisers and/or affiliates may, from time to time, contain third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Special Categories of Personal Data

In certain cases, we may also collect special categories of personal data as defined under the UK General Data Protection Regulation (GDPR). Specifically, we may collect and process data related to:

• Ethnicity (to support diversity, equity, and inclusion initiatives)
• Neurodiversity status (to tailor mentorship opportunities and provide relevant support services)

We will only collect this data with your explicit consent and will process it in accordance with applicable data protection laws. You may withdraw your consent at any time by contacting us at info@globalpurposeenterprise.com.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you access to the App and/or Website). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you, including through:

• Direct interactions. You may give us your personal data (including Identity, Contact, and Marketing and Communications Data) by filling in forms on the App, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • download or register to use the App;
  • register to use a particular feature of the App;
  • you report a problem with the App; or
  • give us feedback or contact us (if you contact us, we will keep a record of that correspondence).
• Automated technologies or interactions. As you interact with our App and Website, we will automatically collect Device, Content and Usage Data about your device, browsing actions and patterns. We collect this data using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
• Third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
  • Device Data from the following parties: (a) analytics providers; (b) advertising networks; and (c) search information providers.
  • Contact Data from technical services providers including Identity and Contact Data from: (a) data brokers or aggregators; and (b) publicly available sources

How We Use Your Personal Data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• With your explicit consent, where we collect personal data shared by means of video recordings or other direct interactions via our App and/or Website where we have your consent for marketing purposes.
• Where we need to perform a contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Please see our Glossary for further information on the types of lawful basis that we will rely on to process your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

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Disclosures of Your Personal Data

When you consent to provide us with your personal data, we will also ask you for your consent to share your personal data with parties set out below for the purposes set out in the table 1.1 "Purposes for which we will use your personal data" above:

• Third Parties as set out in the Glossary
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and data protection legislation.

International Transfers

We do not transfer your personal data outside the UK.

Data Security

Data Retention

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain features to you. We will advise you if this is the case at the time you withdraw your consent.

Glossary