Website Privacy Notice

How Execution Capital uses personal data before platform registration or membership

*Scope: This notice covers public Website visitors, people who contact us, and people who express interest or apply before becoming Registered Users or Members.*

Who we are

Execution Capital Ltd is a company incorporated in England and Wales under company number 16801359. Its registered office is at Flat 32 Admiral Court, 34 The Waldrons, Croydon, England, CR0 4GF. In these documents, references to “Execution Capital”, “we”, “us” or “our” mean Execution Capital Ltd.

For the processing described in this notice, Execution Capital Ltd is normally the controller. You can contact us about privacy at privacy@execution.capital or at our registered office.

Scope of this notice

This notice applies when you browse the public Website, contact us, subscribe to updates, register for a public event, or express interest in or apply to become a Registered User, Founder, Expert, Investor, Operator or Member before platform onboarding is complete.

It does not replace privacy information that applies after registration or in connection with a specific Ecosystem Platform, VCI or transaction. Additional terms and notices may accompany the General Terms, Ecosystem Terms, Information Memorandum, Supplement, Deed Poll and transaction documents. Where a more specific privacy notice applies to a particular processing activity, that notice takes priority for that activity.

Personal data we collect

Depending on how you interact with us, we may collect:

• identity and contact data, such as your name, email address, telephone number, country and preferred method of contact;
• professional and organisation data, such as employer or business, role, biography, expertise, experience, professional profile and sector;
• enquiry and application data, including information supplied in public forms, correspondence, event registrations and pre-Member applications;
• company and opportunity data supplied by a Founder, Operator or other applicant, to the extent relevant to assessing an enquiry or invitation to onboarding;
• marketing and communications data, including subscriptions, preferences, campaign interactions and our contact history;
• technical and usage data, such as IP address, device and browser information, pages visited, referral information, approximate location derived from IP address, diagnostic information and security logs; and
• cookie or similar-technology data described in our Cookie Policy.

The public Website is not intended for special-category personal data, criminal-offence data, medical information or confidential proprietary material. Please do not provide it unless we expressly request it and explain the applicable safeguards and legal basis.

How we obtain personal data

We obtain personal data:

• directly from you when you browse, complete a form, apply, subscribe, attend an event or communicate with us;
• automatically from your device and browser when you use the Website;
• from a colleague, referrer, Ecosystem, adviser or organisation where they introduce you or submit information with appropriate authority; and
• from public professional sources, company websites and registers where relevant to evaluating or responding to a business enquiry or application.

If you provide personal data about another person, you should ensure you are authorised to do so and, where appropriate, direct them to this notice.

Purposes and lawful bases

Operating and securing the Website. We use technical and usage data to deliver pages, maintain security, prevent misuse, diagnose faults and improve reliability. We rely on our legitimate interests in operating a secure and effective public Website and, where applicable, compliance with legal obligations.

Responding to enquiries. We use contact, professional and enquiry data to respond, arrange discussions and manage our relationship. We rely on legitimate interests in communicating with prospective participants and partners, or on steps requested before entering into a contract.

Assessing expressions of interest and pre-Member applications. We use application, professional and organisation data to assess fit, eligibility and whether to invite a person or organisation into onboarding. We rely on steps requested before entering into a contract and our legitimate interests in selecting appropriate prospective participants and protecting the quality of our ecosystem.

Events and communications. We use registration and contact data to administer events and send requested information. We rely on steps requested by you, legitimate interests in administering business events, and consent where required.

Marketing. We use contact details and preferences to send relevant updates about Execution Capital. We rely on consent where required by the Privacy and Electronic Communications Regulations and, where permitted, legitimate interests in business-to-business marketing. Every electronic marketing message will provide an unsubscribe method.

Analytics and improvement. Where non-essential analytics technologies are used, we rely on your consent to store or access information on your device and, where appropriate, to process resulting personal data. Our Cookie Policy identifies the technologies currently used on the public Website.

Legal, regulatory and corporate purposes. We may use data to establish, exercise or defend legal claims, comply with law, respond to regulators, conduct audits, protect rights and safety, and support a financing, reorganisation or business transfer. We rely on legal obligations and legitimate interests in protecting and administering our business.

Where we rely on legitimate interests, we consider whether those interests are outweighed by your rights and reasonable expectations. You may ask for further information about that assessment.

Marketing choices

You can opt out of marketing at any time by using the unsubscribe link in an email or contacting privacy@execution.capital. We may retain limited suppression information, such as your email address and opt-out status, so that we can respect your choice. Opting out of marketing does not prevent service or enquiry communications that you request or that are otherwise necessary.

Cookies and similar technologies

The public Website uses cookies and similar storage or access technologies as described in our Cookie Policy. We do not set or access non-essential technologies unless you have made the required choice or another lawful exception applies. You can decline non-essential technologies through the consent banner and can reset the stored choice as explained in the Cookie Policy.

Who we share personal data with

We may share personal data, where necessary and proportionate, with:

• hosting, cloud, website, security, communications, customer-relationship, event and professional-service providers acting for us;
• other Execution Capital group or associated entities, including an issuer or segregated portfolio company, where needed to evaluate an application or prepare onboarding and where the recipient has an appropriate legal basis;
• Ecosystems or other prospective transaction participants where you ask us to make an introduction or we clearly tell you that sharing is part of the next onboarding step;
• professional advisers, auditors, insurers, banks and potential funders or acquirers subject to appropriate confidentiality arrangements; and
• courts, law-enforcement bodies, regulators, tax authorities and other public bodies where required or permitted by law.

*No visitor-directory sharing: We do not share your personal data with Members, Experts, Investors, Investee Companies or Ecosystems merely because you visit the public Website.*

International transfers

Some recipients or systems may be located outside the United Kingdom. Where UK data-protection law restricts a transfer, we use a permitted mechanism, such as UK adequacy regulations, the UK International Data Transfer Agreement or the UK Addendum to approve standard contractual clauses, together with supplementary measures where appropriate. You may contact us for information about the relevant safeguards.

Retention

We keep personal data only for as long as reasonably necessary for the purposes described above, taking account of the nature of the data, risk, legal obligations and potential claims. Our general working periods are:

• enquiries and unsuccessful or inactive pre-Member applications: normally up to 24 months after the last meaningful interaction;
• marketing records: while you remain subscribed, with minimal suppression information retained afterwards to honour an opt-out; -routine Website security and diagnostic logs: normally up to 12 months, unless needed for an incident, investigation or legal claim;
• cookie consent choice: stored on your device until you clear it or we replace the consent mechanism; and
• legal, accounting and corporate records: generally up to six years after the relevant relationship or event, or longer where law or an actual dispute requires.

If you progress to registration, Membership, VCI participation or a transaction, the applicable platform or transaction retention periods may replace or extend these periods for the relevant data.

Security

We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful loss, misuse, alteration, access or disclosure. Access is limited to people and providers who need it for authorised purposes. No internet service is completely secure, so please use care when sending information online

Your rights

Subject to legal conditions and exceptions, you may have rights to:

• request access to your personal data and information about its use;
• request correction of inaccurate or incomplete data;
• request deletion or restriction of processing;
• receive certain data in a portable format;
• withdraw consent at any time, without affecting earlier lawful processing; and
• complain to a supervisory authority.

*Your right to object: You may object to processing based on legitimate interests. You have an absolute right to object to the use of your personal data for direct marketing.*

To exercise a right, contact privacy@execution.capital. We may ask for information needed to verify your identity. Rights are not absolute, and we will explain if an exemption applies.

Automated decision-making

We do not use personal data covered by this public Website notice to make decisions based solely on automated processing that produce legal or similarly significant effects. If that changes, we will provide the information required by law before the processing begins.

Children

The Website and pre-Member application routes are intended for people aged 18 or over and are not directed to children. If you believe a child has provided personal data, contact us so that we can investigate and take appropriate action.

Complaints

Please contact privacy@execution.capital first if you have a concern. You also have the right to complain to the UK Information Commissioner's Office at https://ico.org.uk/make-a-complaint/ or by telephone on 0303 123 1113. If you are outside the United Kingdom, you may also be entitled to contact the supervisory authority where you live or work.

Changes to this notice and contact

We may update this notice to reflect changes in law, the Website or our processing. We will post the updated notice and revise the last-updated date. Material changes will be highlighted where appropriate. This notice does not amend Platform Documents or any more specific privacy notice.

Email: privacy@execution.capital

General Contact: contact@execution.capital