Privacy Policy

Last updated: [Insert Date]

1. Introduction Velocity Growth Partners ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you interact with us, including when you visit our website, communicate with us, or use our investment-related services.

We process your personal data in accordance with applicable data protection laws in England, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

By using our services or providing your personal data to us, you acknowledge that you have read and understood this Privacy Policy.

2. Who we are (Data Controller) Velocity Growth Partners is the data controller for the personal data we process in connection with our investment activities in England.

If you have any questions about this Privacy Policy or how we handle your data, please contact us using the contact details provided to you in our client documentation or through our website.

3. What personal data we collect The type of personal data we collect depends on your relationship with us (for example, investor, prospective investor, business partner, website visitor). We may collect and process the following categories of personal data:

• Identification data: name, title, date of birth, nationality, and similar identifiers.
• Contact details: postal address, email address, telephone number, and other contact information.
• Professional details: job title, employer, business contact details, professional history.
• Financial and investment information: bank details, investment history, source of funds, risk profile, transaction records, tax-related information, and other information necessary to assess and manage investments.
• Regulatory and compliance data: information for anti-money laundering (AML), know-your-customer (KYC), sanctions screening, fraud prevention, and other regulatory checks (which may include copies of identification documents and information obtained from public sources or third‑party databases).
• Technical and usage data: IP address, browser type and version, device identifiers, time zone setting, operating system, information about how you use our website and services (including page interaction and navigation data), cookies and similar technologies.
• Communication data: records of communications with you, including emails, call notes, and correspondence.
• Marketing preferences: your preferences in receiving marketing from us and your communication preferences.

We will only collect special categories of personal data (for example, health data or data about criminal convictions) where strictly necessary, lawful, and subject to appropriate safeguards.

4. How we collect your personal data We may obtain your personal data from various sources, including:

• Directly from you: when you contact us, complete forms, enter into agreements with us, subscribe to our communications, attend our events, or otherwise interact with us.
• From your organisation: if you are an employee, officer, or representative of a corporate client, investor, or partner.
• From third parties: such as business partners, intermediaries, introducers, financial institutions, credit reference agencies, AML/KYC service providers, analytics providers, and publicly available sources (e.g. Companies House, professional networking sites, public registries).
• Automatically: when you visit our website or use our online services, through cookies, server logs, and similar technologies.

5. Purposes and legal bases for processing We use your personal data only when we have a lawful basis to do so under the UK GDPR. Depending on the context, we may process your data for the following purposes and legal bases:

5.1 To provide and manage our investment services

• To establish and manage client and investor relationships.
• To assess investment suitability and risk.
• To execute transactions and manage portfolios.
• To provide reports, statements, and other information relating to your investments.

Legal bases: performance of a contract; taking steps at your request before entering into a contract; our legitimate interests in operating and improving our business.

5.2 To comply with legal and regulatory obligations

• To carry out AML, KYC, sanctions, fraud, and other regulatory checks.
• To comply with obligations under financial services, tax, and company laws.
• To respond to requests from regulators, law enforcement, or other authorities.

Legal basis: compliance with legal obligations; legitimate interests in protecting our business and the financial system from misuse.

5.3 To manage our business and communications

• To manage and develop our business relationships.
• To respond to enquiries and provide customer support.
• To maintain internal records, accounting, and administrative functions.

Legal bases: our legitimate interests in running and developing our business; performance of a contract where relevant.

5.4 Marketing and business development

• To send you information about our services, investment insights, and events.
• To manage your marketing preferences and ensure you only receive relevant communications.

Legal bases: your consent where required by law; our legitimate interests in promoting and developing our services where consent is not legally required. You may opt out of marketing at any time (see Section 10).

5.5 Website operation, security, and analytics

• To operate, maintain, and improve our website and online services.
• To ensure the security of our systems, data, and premises.
• To analyse usage patterns to enhance user experience.

Legal bases: our legitimate interests in maintaining secure and efficient systems and understanding how our services are used; your consent for certain cookies where required.

6. Cookies and similar technologies We may use cookies and similar technologies on our website to:
   • Enable core site functionality.
   • Remember your preferences.
   • Improve website performance and user experience.
   • Perform analytics and measure the effectiveness of our content.

Where required by law, we will obtain your consent before placing non-essential cookies on your device. You can manage your cookie preferences through your browser settings or via tools provided on our website. Disabling certain cookies may affect the functionality of the site.

7. Disclosure of your personal data We may share your personal data with the following categories of recipients, always on a need‑to‑know basis and subject to appropriate safeguards:

• Service providers: including IT and system providers, hosting providers, cloud services, analytics providers, professional advisors (lawyers, auditors, consultants), AML/KYC service providers, and other vendors who process data on our behalf.
• Business partners and intermediaries: where necessary in connection with our investment activities and services.
• Financial institutions and payment providers: to facilitate transactions.
• Regulatory, governmental, and law enforcement authorities: where required by law or to protect our rights, property, clients, or the public.
• Corporate transactions: in the event of a merger, acquisition, restructuring, or sale of all or part of our business, in which case personal data may be transferred as part of the transaction, subject to confidentiality obligations.

We do not sell your personal data.

8. International transfers Your personal data may be transferred to, and processed in, countries outside the United Kingdom that may not provide the same level of data protection as in the UK.

Where we transfer personal data outside the UK, we will ensure that appropriate safeguards are in place, such as:

• Adequacy regulations issued by the UK government; or
• Standard contractual clauses or other approved safeguards, together with additional measures where necessary.

You can contact us for more information about international transfers and the safeguards we use.

9. Data retention We will retain your personal data for as long as reasonably necessary to fulfil the purposes for which it was collected and to meet legal, regulatory, tax, accounting, or reporting requirements.

In determining retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means.

When personal data is no longer required, we will delete or anonymise it in a secure manner.

10. Your rights Under the UK GDPR, you have various rights in relation to your personal data, subject to certain conditions and exemptions:

• Right of access: to obtain confirmation as to whether we process your personal data and to request a copy of that data.
• Right to rectification: to have inaccurate or incomplete personal data corrected.
• Right to erasure: to request deletion of your personal data where there is no compelling reason for its continued processing.
• Right to restriction: to request that we limit the processing of your personal data in certain circumstances.
• Right to data portability: to receive personal data you have provided to us in a structured, commonly used, and machine‑readable format and to transmit it to another controller where technically feasible and lawful.
• Right to object: to object to processing based on our legitimate interests, including profiling, and to object to processing for direct marketing at any time.
• Rights related to automated decision‑making: to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless certain conditions are met.

To exercise any of these rights, please contact us using the contact details made available to you in our communications or on our website. We may need to verify your identity before responding to your request.

You also have the right to lodge a complaint with the UK data protection authority, the Information Commissioner’s Office (ICO), if you believe your data protection rights have been infringed. You can find details on how to contact the ICO at www.ico.org.uk.

11. Security of your personal data We implement appropriate technical and organisational measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or damage. These measures include access controls, encryption where appropriate, regular monitoring, and staff training.

However, no transmission of information over the internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee its absolute security.

12. Third‑party websites Our website and communications may contain links to third‑party websites or services that are not controlled or operated by Velocity Growth Partners. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy notices of any third‑party sites or services you visit.

13. Children’s data Our services are not directed at children, and we do not knowingly collect personal data from individuals under the age of 18 in connection with our investment activities. If you believe we have collected personal data about a child, please contact us so that we can delete such data.

14. Changes to this Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. The updated version will be posted on our website with a revised "Last updated" date.

We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

15. Contact If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, please contact us using the contact information provided on our website or in your client documentation.