Privacy Policy

1. Who this policy covers

• Investment professionals in our database — personnel of institutional investors (such as pension funds, endowments, foundations, insurers, and funds of funds) whose professional details we hold (section 2).
• Client users — people who use the FundTensor platform on behalf of a client (section 3).
• Website visitors and business contacts — people who visit fundtensor.com, book a call, or correspond with us (section 4).

2. Our investor database

What we hold and where it comes from. We maintain a database of institutional investors and their personnel to help fund managers identify investors relevant to their funds. For individuals, we hold professional data only: name, job title and role, employer and employer type, business email address and business telephone number, professional LinkedIn profile URL, professional background, and information about the investment activity and mandate of the organisation you work for. Sources include: your employer's website and publications; regulatory and statutory filings and other public disclosures; professional networking platforms and business directories; reputable media; and, where campaigns are run on their behalf, information our clients or you yourself provide (for example, a reply indicating a change of role or investment timing).

We do not collect special-category data (such as health, political opinions, or biometric data) or data about criminal convictions, and we do not hold data about your private life. Our database concerns your professional role only.

Why we hold it, and our legal basis. We process this data for: maintaining and verifying an accurate database of institutional investment professionals; assessing which investors may be relevant to a particular fund manager's mandate; enabling clients to send relevant, individually approved introductions from their own accounts; recording engagement outcomes (such as a request not to be contacted, a change of role, or an indication of investment timing) so that future contact is more relevant or ceases; and operating suppression lists.

Our legal basis is legitimate interests (Article 6(1)(f) UK GDPR / EU GDPR): our and our clients' interest in connecting fund managers with professionally relevant institutional investors, in a business-to-business context, using professional contact data, with contact volumes deliberately limited and every recipient individually reviewed and approved before outreach. We have carried out a legitimate-interests assessment, and we balance these interests against your rights — in particular through the safeguards below.

Safeguards.

• Outreach through our platform is low-volume, individually approved, and professional in nature — not bulk marketing.
• If you decline a particular fund manager's approach, you will not be contacted again on that manager's behalf. If you object to our processing or ask for your details to be removed — whether by contacting us or our EU representative, or by saying so in a reply — we add you to a permanent suppression list applied across our platform.
• We periodically re-verify data against public sources and correct or remove stale records.
• We do not sell personal data to data brokers. Access to our database is licensed to clients under contract, subject to restrictions on export and reuse.

How long we keep it. We retain database records for as long as the individual holds a relevant professional role and the data remains accurate, reviewing records periodically. Records of suppression requests are kept indefinitely (in minimal form) so that the suppression is effective.

3. Client users of the platform

When you use the platform on behalf of a client, we process: your name, business email, role, and login records; the configuration of your workspace; and, where you connect a LinkedIn or similar account, the technical credentials needed to operate the connection, and the content of campaign communications sent and received.

Legal bases: performance of our contract with the client (Article 6(1)(b)) and legitimate interests in operating, securing, and improving the platform (Article 6(1)(f)). Campaign content is processed on the client's behalf under our DPA.

4. Website visitors and business contacts

When you visit fundtensor.com, book a call, or correspond with us, we process the data you provide (name, email, company, message content), booking details, and technical data (IP address, browser type, pages visited). Legal bases: legitimate interests in operating our website and responding to enquiries, and steps taken at your request prior to entering a contract. Our website uses cookies necessary for it to function.

5. Who we share personal data with

We share personal data with service providers who process it on our instructions: payment processing (Stripe), outreach infrastructure, cloud hosting, AI model providers used for research and qualification, productivity and communications tools, and our CRM. A current list of sub-processors relevant to client processing is available on request. We may also disclose personal data where required by law or in connection with a corporate transaction (in which case protections equivalent to this policy will apply).

We do not sell personal data to data brokers.

6. International transfers

We are a UK company. Where personal data is transferred outside the UK or EEA (for example, to service providers in the United States, or where a client is established outside the UK/EEA), we rely on adequacy regulations where available and otherwise on appropriate safeguards such as the UK International Data Transfer Agreement or Addendum, or the EU Standard Contractual Clauses.

7. Your rights

You have the right to: request access to your personal data; ask us to correct or delete it; object to processing based on legitimate interests (including, at any time, to processing for the purpose of being contacted — which we will honour by suppressing your record); ask us to restrict processing; and data portability where applicable.

To exercise any right, contact privacy@fundtensor.com or, in the EU/EEA, our representative DP-Dock GmbH at fundtensor@gdpr-rep.com. We respond within one month. To stop contact on behalf of a particular fund manager, simply reply to their message saying so. To have your details removed from our database entirely, say so in a reply or contact us at the addresses above — removal is applied permanently across our platform.

You also have the right to complain to a supervisory authority: in the UK, the Information Commissioner's Office (ico.org.uk); in the EU/EEA, the supervisory authority of your member state.

8. Changes to this policy

We will post any changes on this page and update the date at the top. Material changes affecting client processing will be notified to clients directly.