Who is responsible for your data
This website, stephenellul.co, is run by Stephen Ellul, based in Malta. Stephen Ellul is the controller of the personal data collected through this website. To ask anything about your data, use any form on this site or write to stephen@thegrowthbully.com.
What I collect
- What you send me. Your name, email, phone number, business name, website and anything you write in a form, plus the details you give when you book a call.
- How you found the site. The page you sent the form from, campaign tags in the link (UTM parameters) and ad click identifiers (gclid, fbclid).
- How you use the site. Pages viewed, device and browser type, approximate location and cookie identifiers, collected by the analytics and advertising tools listed below.
Why I use it, and the legal basis
- To reply to you and send what you asked for, such as the checklist, the audit or a booked call. Basis: steps taken at your request before any contract, and my legitimate interest in answering enquiries.
- To follow up about working together by email, phone or message. Basis: legitimate interest. You can ask me to stop at any time and I will.
- To measure the site and the ads that bring people to it. Basis: your consent, where the law requires it, and legitimate interest in knowing which ads work.
- To keep records the law requires. Basis: legal obligation.
Who processes it for me
I use trusted service providers who process data on my instructions:
- HighLevel (GoHighLevel): the CRM where form entries and bookings are stored, and the booking calendar.
- Cloudflare: hosting, security and the service that receives the website forms.
- Google Analytics 4 (Google Ireland Ltd): site analytics.
- Meta Pixel and Conversions API (Meta Platforms Ireland Ltd): measuring and improving Facebook and Instagram ads. When you send a form, a hashed (scrambled) copy of your email and phone, and the event, may be shared with Meta so it can match the result to an ad.
- Email and calendar providers used to reply to you and run the call.
Some of these providers process data outside the European Economic Area. Where they do, the transfer is covered by the EU Standard Contractual Clauses or the EU-US Data Privacy Framework. I never sell your data.
Cookies
Analytics and advertising cookies (Google Analytics and the Meta Pixel) are set only if you choose "Accept" on the cookie bar. If you choose "Essential only", Google Analytics runs in cookieless mode and the Meta Pixel does not load. You can change your choice at any time with "Cookie settings" at the bottom of every page, or block and delete cookies in your browser; the site still works without them.
How long I keep it
Enquiries and contact details: up to 3 years after our last contact, then deleted. If we work together, records needed for tax and accounting are kept as long as Maltese law requires. Analytics data: as set in each tool, up to 14 months for Google Analytics.
Your rights
Under the GDPR you can ask to see the data I hold on you, correct it, delete it, limit how it is used, receive a copy to move elsewhere, and object to its use, including for direct marketing. Where I rely on consent, you can withdraw it at any time. Write to me through any form on this site or at the email above and I will reply within one month.
If you are not happy with how I handle your data, you can complain to the Information and Data Protection Commissioner in Malta (idpc.org.mt).
Changes
If this policy changes, the new version goes on this page with a new date at the top.