Last updated 12 November 2026
This policy explains how Swell Growth Marketing Inc. (“Swell”, “we”) handles personal data when we reach out to businesses, work with clients and run this website.
Who we are
Swell Growth Marketing Inc. is a company incorporated in British Columbia, Canada. We are the controller of the personal data described here.
Questions or requests about your data: hello@swellgrowthmarketing.com
People we reach out to
We contact marketing and growth leaders at companies we think we can help. For that we process:
your name, job title and employer
your work email address and work phone number
your public LinkedIn profile
notes on our conversations with you
We collect this from public sources such as LinkedIn, company websites and job postings, and from business contact data providers (FullEnrich and Lusha).
In the EU and the UK, our legal basis is legitimate interest (Article 6(1)(f) GDPR and UK GDPR): telling people about our services when their role makes them relevant. In Canada, we use business contact information only to reach you about your work.
Every first email we send names this policy. You can tell us to stop at any time, and we will.
Clients and website visitors
For clients, we process contact details and project communications to deliver our work and invoice it. Our legal basis is the contract with you and our accounting obligations.
On this website we use Google Analytics to understand how people find and use our pages. If you sign up for our newsletter, we use your email address to send it, and you can unsubscribe from any issue.
Who we share it with
We use service providers that process data for us under their data processing terms:
Close, our CRM
Google Workspace, for email and documents
Railway, which hosts our internal tools
Anthropic, whose AI models help us research companies and draft messages
FullEnrich and Lusha, for business contact details
We do not sell personal data, and we do not share it with anyone for their own marketing.
International transfers
Swell is based in Canada, and some of our providers are in the United States. The European Commission and the UK recognise Canada as providing adequate protection for commercial data. For transfers to the United States we rely on our providers’ data processing terms, including standard contractual clauses where they apply.
How long we keep it
We keep data on the people we contact for up to 24 months after our last contact, then delete it, unless we start working together.
If you ask us not to contact you, we keep your name and email address on a do not contact list so we can respect that.
We keep client records for as long as the work and Canadian tax law require.
Your rights
You can ask us to give you a copy of your data, correct it, delete it or restrict how we use it. You can object to direct marketing at any time: reply “unsubscribe” to any email from us, or write to hello@swellgrowthmarketing.com.
You can also complain to a data protection authority: the Information Commissioner’s Office in the UK, your local authority in the EU, or the Office of the Privacy Commissioner of Canada.
Changes
We update this page when our practices change. The date at the top shows the latest version.