Privacy Policy

1. Who We Are

Investinova Ltd ("Investinova") is a company registered in England and Wales (Company No. 11223344) with its registered office at 1 Investment House, London, EC2A 1AA.

We are the data controller for the personal information we collect through this website and in connection with our investment management services. You can contact us about data protection matters at privacy@investinova.co.uk.

2. Data We Collect

We may collect and process the following categories of personal data:

• Identity data: name, title
• Contact data: email address, telephone number, postal address
• Financial data: investment amount ranges and interests (where provided voluntarily)
• Communication data: the content of messages and enquiries you send us
• Technical data: IP address, browser type, operating system, referring URL, pages visited, and session duration — collected automatically when you visit our website
• Marketing preferences: your preferences in receiving communications from us

We do not collect sensitive personal data (special category data) and we do not collect data from persons under the age of 18.

3. How We Use Your Data

We use your personal data for the following purposes:

• To respond to enquiries submitted through our contact form or by email
• To assess your suitability as a prospective investor in accordance with FCA regulatory requirements (including appropriate investor categorisation)
• To provide information about our investment funds, strategies, and services
• To fulfil our legal and regulatory obligations (including anti-money laundering checks where required)
• To improve the performance, security, and usability of our website
• To send you marketing communications where you have given consent or where we have a legitimate interest to do so

4. Legal Basis for Processing

We process your personal data on the following legal bases under UK GDPR:

• Legitimate interests (Article 6(1)(f)) — responding to your enquiries, improving our website, and communicating about our services where you have initiated contact
• Legal obligation (Article 6(1)(c)) — complying with FCA rules, anti-money laundering regulations, and other applicable law
• Consent (Article 6(1)(a)) — where you have explicitly agreed to receive marketing communications; you may withdraw consent at any time
• Performance of a contract (Article 6(1)(b)) — where we are taking steps at your request prior to entering into an investment agreement

5. Sharing Your Data

We do not sell your personal data. We may share it in the following limited circumstances:

• Service providers: third-party suppliers who support our operations (e.g. email delivery, hosting, IT security), under data processing agreements that bind them to equivalent data protection standards
• Regulators and authorities: the FCA, HMRC, law enforcement, or other government bodies where required by law
• Professional advisers: lawyers, accountants, and auditors acting under professional confidentiality obligations
• Business transfers: in the event of a merger, acquisition, or sale of all or part of our business, personal data may be transferred as part of that transaction

All data sharing is subject to appropriate safeguards, and we only share what is necessary for the relevant purpose.

6. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, subject to the following:

• Enquiry and contact records: up to 3 years from last contact, unless a client relationship develops
• Client and investor records: 6 years from the end of the business relationship, in line with FCA COBS rules and the Limitation Act 1980
• Website technical logs: up to 12 months
• Marketing consent records: for the duration of the consent and up to 1 year after withdrawal

When data is no longer needed, we delete or anonymise it securely.

7. Your Rights

Under UK GDPR, you have the following rights in relation to your personal data:

• Right of access — to obtain a copy of the personal data we hold about you
• Right to rectification — to correct inaccurate or incomplete data
• Right to erasure — to request deletion of your data, subject to legal and regulatory retention obligations
• Right to restrict processing — to ask us to limit how we use your data in certain circumstances
• Right to data portability — to receive your data in a structured, commonly-used, machine-readable format where technically feasible
• Right to object — to processing based on legitimate interests or for direct marketing purposes
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, contact us at privacy@investinova.co.uk. We will respond within one calendar month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

8. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These include encrypted data transmission (TLS), access controls, and regular security reviews.

Whilst we take reasonable precautions, no method of electronic transmission or storage is entirely secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately at privacy@investinova.co.uk.

9. Cookies

Our website uses cookies and similar tracking technologies to enable essential site functionality and to understand how visitors use the site. These include:

• Essential cookies: required for secure sessions and correct site operation
• Analytics cookies: anonymous data on page visits and referral sources, used to improve site performance

You may control or disable cookies through your browser settings. Disabling essential cookies may affect site functionality. We do not use cookies for advertising or cross-site tracking.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites and encourage you to review their privacy policies independently.

11. Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices, technology, or legal requirements. When we do, we will revise the "last updated" date at the top of this page. We encourage you to review this policy periodically.

12. Contact Us

For any questions, requests, or concerns regarding this privacy policy or our data practices, please contact us: