Privacy Policy

1. Information We Collect

1.1 Personal Information

We may collect the following types of personal information:

• Contact Information: Name, email address, phone number, postal address
• Professional Information: Job title, company name, industry, investment experience
• Financial Information: Investment capacity, accredited investor status (where applicable)
• Communication Data: Records of communications with us, including emails and meeting notes

1.2 Technical Information

When you visit our website, we automatically collect:

• IP address and location data
• Browser type and version
• Operating system
• Website usage patterns and analytics
• Cookies and similar tracking technologies

1.3 Information from Third Parties

We may receive information about you from:

• Business partners and referral sources
• Publicly available sources
• Social media platforms
• Professional networks and databases

2. How We Use Your Information

2.1 Service Provision

We use your personal information to:

• Provide investment advisory services and support
• Process and manage your subscriptions and requests
• Conduct due diligence and compliance checks
• Facilitate investment opportunities and transactions
• Provide customer support and respond to inquiries

2.2 Marketing and Communications

With your consent, we may use your information to:

• Send newsletters and investment insights
• Notify you of relevant investment opportunities
• Invite you to events and webinars
• Conduct market research and surveys

2.3 Legal and Regulatory Compliance

We may process your information to:

• Comply with legal obligations and regulatory requirements
• Prevent fraud and ensure platform security
• Enforce our terms of service
• Respond to legal requests and proceedings

3. Legal Basis for Processing

Under UK GDPR, we process your personal data based on:

• Consent: Where you have given clear consent for specific processing activities
• Contract: Where processing is necessary for performing our services
• Legal Obligation: Where we must process data to comply with legal requirements
• Legitimate Interest: Where we have a legitimate business interest that doesn't override your rights

4. Information Sharing and Disclosure

4.1 Service Providers

We may share your information with trusted third parties who provide services on our behalf:

• Technology and hosting providers
• Legal and professional advisors
• Marketing and communications platforms
• Analytics and research services

4.2 Business Partners

With your consent, we may share relevant information with:

• Co-investors in specific opportunities
• Portfolio companies (for investor introductions)
• Professional networks and industry contacts

4.3 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes and court orders
• Respond to regulatory investigations
• Protect our rights and property
• Ensure user safety and prevent harm

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information:

• Encryption: Data is encrypted in transit and at rest
• Access Controls: Strict access controls and authentication procedures
• Regular Audits: Regular security assessments and vulnerability testing
• Staff Training: Regular privacy and security training for all employees
• Incident Response: Procedures for detecting and responding to security incidents

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services and maintain our relationship with you
• Comply with legal and regulatory requirements
• Resolve disputes and enforce our agreements
• Pursue legitimate business purposes

Generally, we retain client data for a minimum of 7 years after the end of our business relationship, in line with financial services regulations.

7. Your Rights

Under UK data protection law, you have the following rights:

7.1 Right of Access

You can request a copy of the personal information we hold about you.

7.2 Right to Rectification

You can ask us to correct any inaccurate or incomplete personal information.

7.3 Right to Erasure

You can request deletion of your personal information in certain circumstances.

7.4 Right to Restrict Processing

You can ask us to limit how we use your personal information.

7.5 Right to Data Portability

You can request your personal information in a portable format.

7.6 Right to Object

You can object to certain types of processing, including marketing communications.

7.7 Right to Withdraw Consent

Where we rely on consent, you can withdraw it at any time.

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

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Ensure our website functions properly
• Remember your preferences and settings
• Analyze website usage and performance
• Provide personalized content and advertising

You can manage your cookie preferences through our cookie consent banner or your browser settings. For detailed information, see our Cookie Policy.

9. International Transfers

We may transfer your personal information outside the UK to:

• Service providers in other countries
• International business partners
• Cloud storage and processing facilities

When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by the UK government
• Standard contractual clauses
• Binding corporate rules
• Other approved transfer mechanisms

10. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make significant changes, we will:

• Post the updated policy on our website
• Update the "last modified" date
• Notify you via email for material changes
• Provide notice through our website

12. Contact Information

If you have questions about this Privacy Policy or our data practices, please contact us:

Supervisory Authority

You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO):

Website: ico.org.uk
Phone: 0303 123 1113

13. Specific Provisions for Investment Services

As a provider of investment advisory services, we may process additional categories of personal information:

13.1 Financial Information

• Investment history and portfolio information
• Risk tolerance and investment objectives
• Financial statements and tax information
• Source of funds verification

13.2 Regulatory Compliance

We process this information to:

• Comply with FCA regulations and guidance
• Conduct appropriate suitability assessments
• Meet anti-money laundering requirements
• Maintain accurate client records