Privacy Policy.

1.1 Newton Ventures Ltd (“Newton Ventures”, “we”, “us”, “our”) is committed to protecting and respecting your privacy.

1.2 This Privacy and Cookies Policy explains how we collect, use, store, share and protect your personal data when you access and use this website, contact us, make an enquiry, or engage with us in connection with our services.

1.3 This Policy is prepared in accordance with applicable data protection laws in England and Wales, including the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and, where applicable, the Privacy and Electronic Communications Regulations 2003.

1.4 For the purposes of applicable data protection laws, Newton Ventures Ltd, a company registered in England and Wales under company number 12375978, with its registered office at 18, 6 Riverlight Quay, London, SW11 8EA, United Kingdom, is the data controller of the personal data we process in connection with this website and our business activities.

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

(a) information you provide directly to us, including through website forms, enquiries, telephone calls, meetings, email communications, document submissions or other correspondence;

(b) business and professional information, including your name, role, company, organisation, project details, contact details, location, funding requirements and information relating to your business or transaction;

(c) information provided as part of our review, onboarding, compliance, due diligence or funding-related processes, which may include identification documents, corporate documents, ownership information, financial information, proof of funds or proof of capability to pay relevant fees;

(d) technical and usage data collected automatically when you use our website, including IP address, browser type, device information, operating system, referral source, pages visited, time spent on pages and browsing activity;

(e) information collected through cookies and similar technologies, as explained in section 7 below.

3.1 We process personal data for the following purposes:

(a) to operate, maintain, secure and improve our website;

(b) to respond to enquiries, messages, funding requests and other communications;

(c) to assess whether we or our funding partners, lenders, investors, professional advisers or other counterparties may be able to assist with a funding request or commercial opportunity;

(d) to provide our services and facilitate funding-related, advisory, brokerage, structuring, due diligence, compliance and transaction-management activities;

(e) to prepare, review and manage documentation, data rooms, credit files, funding submissions, engagement materials and related business records;

(f) to carry out identity, anti-money laundering, know-your-client, sanctions, fraud prevention and other compliance checks where required;

(g) to manage our business relationships with clients, introducers, funding channels, lenders, investors, advisers and counterparties;

(h) to comply with legal, regulatory, accounting, tax, compliance and reporting obligations;

(i) to protect, establish, exercise or defend our legal rights;

(j) to analyse website usage and improve website performance, functionality and user experience.

4.1 We process personal data only where we have a lawful basis to do so under applicable data protection laws. These lawful bases may include:

(a) consent, where you have given us clear permission to process your personal data for a specific purpose;

(b) contract, where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract;

(c) legal obligation, where processing is necessary for us to comply with a legal or regulatory obligation;

(d) legitimate interests, where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights, freedoms or interests.

4.2 Our legitimate interests may include managing and developing our business, responding to enquiries, assessing potential transactions, conducting appropriate due diligence, communicating with clients and counterparties, protecting our business, preventing fraud, keeping business records, and improving our website and services.

5.1 We do not sell your personal data.

5.2 We may share personal data where necessary and appropriate with:

(a) service providers who support our website, technology systems, document management, cloud storage, communications, administration and business operations;

(b) funding channels, lenders, investors, family offices, institutions, counterparties and professional advisers where necessary to assess, progress or manage a funding request, transaction or commercial opportunity;

(c) lawyers, accountants, consultants, compliance advisers, auditors and other professional advisers;

(d) regulators, courts, law enforcement authorities, government bodies or other public authorities where required by law or where necessary to protect our legal rights;

(e) other parties where you have instructed us to share information or where sharing is necessary to provide our services.

5.3 Where we share personal data, we will take reasonable steps to ensure that the recipient handles the data appropriately and only for the relevant purpose.

6.1 Where we require supporting documents, proof of capability to pay fees, anti-money laundering information, know-your-client documents, corporate documents, financial information or transaction materials, we may request that these are provided through a secure document-sharing folder or data room.

6.2 Access to such materials will be limited to authorised persons who require access for the relevant purpose.

6.3 We will only share such materials with third parties where necessary for the purposes described in this Policy, where required by law or regulation, or where you have instructed or authorised us to do so.

6.4 We will not use such information for unrelated purposes.

7.1 This website may use cookies and similar technologies to support website functionality, improve user experience, understand website performance and, where applicable, support analytics or marketing.

7.2 Cookies may include:

(a) strictly necessary cookies required for the website to function properly;

(b) performance or analytics cookies used to understand how visitors use the website and to improve performance;

(c) functionality cookies used to remember preferences or improve user experience;

(d) targeting or advertising cookies, where applicable.

7.3 Where required by applicable law, we will request your consent before placing non-essential cookies on your device.

7.4 You can manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect how the website functions.

8.1 Due to the international nature of our business, personal data may be transferred to, accessed from or processed in countries outside the United Kingdom.

8.2 Where personal data is transferred internationally, we will take reasonable steps to ensure that appropriate safeguards are in place in accordance with applicable data protection laws.

8.3 Such safeguards may include using appropriate contractual protections, transferring data to jurisdictions recognised as providing adequate protection, or implementing other lawful transfer mechanisms where required.

9.1 We retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, including for business, legal, regulatory, compliance, accounting, reporting and record-keeping purposes.

9.2 Retention periods may vary depending on the nature of the data, the purpose for which it is processed, our legal or regulatory obligations, and whether the data is required in connection with a current or potential dispute, claim, transaction or business relationship.

9.3 When personal data is no longer required, we will delete, anonymise or securely archive it, as appropriate.

10.1 We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, disclosure or destruction.

10.2 These measures may include access controls, secure document-sharing processes, restricted permissions, internal policies, system protections and appropriate data-handling procedures.

10.3 However, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we take reasonable steps to protect the personal data we process.

11.1 Subject to applicable law and any relevant exemptions, you may have the following rights in relation to your personal data:

(a) the right to be informed about how your personal data is used;

(b) the right to access the personal data we hold about you;

(c) the right to request correction of inaccurate or incomplete personal data;

(d) the right to request deletion of your personal data in certain circumstances;

(e) the right to restrict processing of your personal data in certain circumstances;

(f) the right to object to certain processing activities;

(g) the right to data portability in certain circumstances;

(h) the right to withdraw consent where processing is based on consent;

(i) rights in relation to automated decision-making and profiling, where applicable.

11.2 If you wish to exercise any of your rights, please contact us using the contact form on our website.

11.3 We may need to verify your identity before responding to a request.

12.1 If you have concerns about how we handle your personal data, please contact us first using the contact form on our website so that we can try to resolve the matter.

12.2 You also have the right to lodge a complaint with the UK Information Commissioner’s Office, which is the UK regulator for data protection matters.

13.1 This website may contain links to third-party websites, platforms or resources.

13.2 We are not responsible for the privacy practices, policies, security or content of third-party websites.

13.3 You should review the privacy policy of any third-party website before providing personal data to that website.

14.1 We may update this Privacy and Cookies Policy from time to time.

14.2 Any changes will be published on this page and will take effect upon posting.

14.3 The date of the latest update should be shown at the top or bottom of this page.

15.1 For any queries regarding this Privacy and Cookies Policy or the handling of your personal data, please contact Newton Ventures Ltd using the contact form on our website.