Privacy Policy

1. Introduction

FundTensor Ltd ("FundTensor", "we", "our", or "us") is committed to protecting your privacy and handling your personal data responsibly. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or engage with us in any capacity.

FundTensor provides lead generation, LP intelligence, and meeting facilitation services for fund managers seeking to connect with institutional allocators. This policy applies to our website visitors, prospective clients, current clients, and the institutional allocators whose professional contact information we process as part of our services.

2. Information We Collect

We collect and process different categories of information depending on your relationship with us:

2.1 Information from Website Visitors and Prospective Clients

• Contact Information: Name, email address, phone number, company name, job title, and other details you provide when contacting us or submitting enquiries.
• Fund Information: Details about your fund, investment strategy, target fundraise, and related information you share during consultations.
• Communication Records: Records of correspondence, call notes, and meeting summaries.

2.2 Information from Clients

• Engagement Data: Information necessary to deliver our services, including fund documentation, marketing materials, and target criteria.
• Campaign Performance Data: Metrics relating to outreach campaigns, including response rates, meeting outcomes, and pipeline progression.
• Billing Information: Payment details, invoicing information, and transaction records.

2.3 LP and Allocator Data

• Professional Contact Information: Business names, job titles, business email addresses, and business phone numbers of individuals in their professional capacity at institutional allocators.
• Institutional Information: Organisation names, AUM, investment mandates, geographic focus, asset class preferences, and other publicly available institutional data.
• Engagement History: Records of communications, meeting history, and expressed preferences regarding investment opportunities.

2.4 Technical and Usage Data

• Device Information: IP address, browser type and version, operating system, device identifiers, and screen resolution.
• Usage Data: Pages visited, time spent on pages, click patterns, and navigation paths through our website.
• Referral Data: Information about how you arrived at our website, including referral URLs and marketing campaign identifiers.

3. How We Collect Information

• Directly from you: When you submit enquiries, request information, enter into a service agreement, or communicate with us.
• Publicly available sources: Company websites, regulatory filings, press releases, LinkedIn, industry publications, and public databases.
• Third-party data providers: Licensed data providers who supply verified professional contact information.
• Automatically: Through cookies, analytics tools, and similar technologies when you visit our website.

4. How We Use Your Information

We use the information we collect for the following purposes:

4.1 Service Delivery

• To identify and map relevant institutional allocators for our clients
• To execute outreach campaigns on behalf of fund managers
• To facilitate introductions and meetings between fund managers and allocators
• To provide reporting and analytics on campaign performance

4.2 Business Operations

• To respond to enquiries and provide customer support
• To process payments and manage billing
• To maintain and improve our database accuracy and deliverability standards
• To comply with legal and regulatory obligations

4.3 Marketing and Communications

• To send service-related communications
• To send marketing communications (where you have opted in or where we have a legitimate interest)
• To personalise your experience on our website

5. Legal Basis for Processing (GDPR)

Under the UK GDPR and EU GDPR, we process personal data on the following legal bases:

• Contract: Processing necessary for the performance of a contract with you, or to take steps at your request prior to entering a contract.
• Legitimate Interests: Processing necessary for our legitimate business interests, including maintaining our LP database, conducting B2B marketing, and improving our services—balanced against your rights and interests.
• Consent: Where you have given clear consent for us to process your data for specific purposes.
• Legal Obligation: Processing necessary for compliance with legal obligations to which we are subject.

6. Data Sharing and Disclosure

We may share your information in the following circumstances:

• With Clients: LP contact information and engagement data is shared with our fund manager clients as part of service delivery.
• Service Providers: Third parties who assist us in operating our business, including email delivery providers, cloud hosting services, and analytics tools—all bound by appropriate data processing agreements.
• Legal Requirements: When required by law, regulation, legal process, or governmental request.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, where your data may be transferred as part of the transaction.

We do not sell personal data to third parties for their own marketing purposes.

7. International Data Transfers

As we serve clients and contact allocators globally, your data may be transferred to and processed in countries outside the UK and European Economic Area. When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Transfers to countries with adequate data protection laws as determined by the UK or EU
• Standard Contractual Clauses approved by the UK or European Commission
• Other appropriate transfer mechanisms as permitted by applicable law

8. Data Retention

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

• Client Data: For the duration of the client relationship and for up to 7 years thereafter for legal and accounting purposes.
• LP Database: Professional contact information is retained and regularly verified for accuracy. Data is removed upon valid opt-out requests.
• Marketing Data: Until you withdraw consent or opt out, or until the data is no longer relevant.
• Website Analytics: Typically retained for up to 26 months.

9. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication requirements
• Regular security assessments and updates
• Staff training on data protection and security practices

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

10. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your experience and analyse website usage. Types of cookies we use include:

• Essential Cookies: Required for the website to function properly.
• Analytics Cookies: Help us understand how visitors interact with our website.
• Functional Cookies: Remember your preferences and settings.

You can control cookies through your browser settings. Disabling certain cookies may affect website functionality.

11. Your Rights

Under applicable data protection laws, you may have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your personal data in certain circumstances.
• Restriction: Request restriction of processing in certain circumstances.
• Data Portability: Request transfer of your data to another organisation in a structured, machine-readable format.
• Object: Object to processing based on legitimate interests, including direct marketing.
• Withdraw Consent: Where processing is based on consent, withdraw that consent at any time.

To exercise any of these rights, please contact us at privacy@fundtensor.com. We will respond to your request within one month.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) or your local supervisory authority.

12. Opt-Out and Unsubscribe

If you are an institutional allocator who has received communications facilitated by FundTensor and wish to opt out:

• Click the unsubscribe link in any email you receive
• Email us at unsubscribe@fundtensor.com

We process all opt-out requests immediately and permanently across our entire database. Your professional reputation is important to us, and we maintain strict compliance with opt-out preferences.

13. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

14. Children's Privacy

Our services are intended for business professionals and are not directed at individuals under 18 years of age. We do not knowingly collect personal data from children.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by updating the "Last updated" date and, where appropriate, through direct communication. Your continued use of our services after such changes constitutes acceptance of the updated policy.

16. Contact Us

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