Personal data we collect by category
| Who | What we collect |
|---|---|
| All website visitors | Technical data (IP address, browser and device type, pages viewed), collected via cookies and similar technologies — see our Cookie Policy. |
| Newsletter subscribers | Email address, and engagement data (opens/clicks) from our email platform. |
| Board Programme applicants and participants | Full name, work email, company, job title, LinkedIn profile, years of senior experience, board CV/biography and any supporting documents you provide, coaching session notes, payment/billing details, and information arising from your participation (for example, attendance at cohort sessions). |
| Pop-Up Board participants | Name, organisation, role, and any business information discussed during the session (see confidentiality terms in our Terms and Conditions). |
| Startup applicants and members | Company details, founder/representative name, work email, funding stage and revenue information, pitch materials, and any information submitted through the Startup Members directory. |
| Investor Network applicants | Full name, work email, LinkedIn profile, investor type (angel, family office, institutional), and, if you proceed, your signed statutory investor eligibility statement and related eligibility information (see section 4 and our Terms and Conditions, Schedule 2). |
| Event and webinar attendees | Name, organisation, contact details, dietary or accessibility requirements (in-person events only), and, where sessions are recorded, your image and voice. |
| Executive search firm and other partners | Business contact details of individuals at partner organisations, for the purposes of facilitating introductions. |
1. Who we are
1.1 This Privacy Policy explains how FINTECH CIRCLE LTD, a company registered in England and Wales under company number 09141483, whose registered office is at 167-169 Great Portland Street, 5th Floor, London, W1W 5PF (“FINTECH Circle”, “we”, “us”, “our”), collects and uses personal data when you visit fintechcircle.com and its connected platforms (including boards.fintechcircle.com and webinar.fintechcircle.com), apply for or use any of our Services (as defined in our Terms and Conditions), attend an event or webinar, or otherwise interact with us.
1.2 For the purposes of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, FINTECH Circle is the controller of the personal data described in this Policy, except where we say otherwise (for example, where an executive search firm, investor, or prospective portfolio company becomes an independent controller of data you share with them directly — see section 6). Our registration with the Information Commissioner’s Office (ICO) is ZB538212.
1.3 Data protection contact: Glenn Burgess, Marketing Director, email info@fintechcircle.com, or by post to the registered office address above.
2. Scope of this Policy
2.1 This Policy covers the FINTECH Circle website and the connected platforms and services listed at section 1.1, reflecting your confirmation that the legal documents should cover the wider FINTECH Circle digital ecosystem rather than only the new marketing pages.
2.2 Because FINTECH Circle’s community includes members and applicants outside the United Kingdom (the Site describes a global network of 260,000+ professionals), this Policy is written to be compatible with both the UK GDPR and, where it applies to our processing, the EU General Data Protection Regulation (“EU GDPR”).
3. Personal data we collect
3.1 We do not intentionally collect special category data (such as data about health, race, religion or sexual orientation) except where you volunteer it (for example, accessibility requirements for an event), or financial data beyond what is necessary to process payment. Where you do provide accessibility or health-related information for an event, we use it only for that purpose.
3.2 Our Services are directed at business professionals and are not intended for, and we do not knowingly collect personal data from, children.
4. How we use your personal data, and our lawful basis
Under UK GDPR, we must have a lawful basis for each use of your personal data. The table below sets out our main purposes and the lawful basis we rely on for each.
| Purpose | Lawful basis |
|---|---|
| Operating the Site and keeping it secure | Legitimate interests (running and securing our business). |
| Processing applications for the Board Programme, Startup Membership, funding introductions and the Investor Network, and delivering the relevant Service | Performance of a contract with you (or steps taken at your request before entering into one), and, where you apply on behalf of an organisation, our legitimate interests in assessing that application. |
| Facilitating introductions to executive search firms, investors, prospective portfolio companies and commercial contacts | Legitimate interests (operating our introduction and networking model, which is the core purpose you sign up for), performed with appropriate transparency about onward sharing (see section 6). |
| Sending you the Board Programme, funding or investor-related communications, including the risk warnings and eligibility statements described in Schedule 2 to our Terms | Performance of a contract, and, for the Investor Network specifically, compliance with our legal obligations. |
| Sending marketing emails and the FINTECH Insights newsletter | Consent (where you actively subscribe), or our legitimate interests together with the “soft opt-in” under the Privacy and Electronic Communications Regulations 2003 (“PECR”) where you are an existing customer or applicant and we market similar services to you. You can opt out at any time — see section 9. |
| Cookies and similar technologies for analytics and advertising (e.g. Google Analytics/GA4, LinkedIn Insight Tag, Meta Pixel) | Consent, obtained through our cookie banner, except for strictly necessary cookies. See our Cookie Policy. |
| Processing payments (e.g. via Stripe) for membership or paid events | Performance of a contract, and compliance with our legal obligations (for example, accounting and tax record-keeping). |
| Photography and recording at events, webinars and Pop-Up Boards | Legitimate interests (promoting FINTECH Circle and its community) and, for in-person events, consent obtained on the day where practicable. See section 9 for your right to object. |
| Preventing fraud, complying with sanctions and anti-money-laundering obligations | Compliance with a legal obligation, and legitimate interests in protecting our business and community. |
| Improving our Services, including our startup and investment shortlisting methodology | Legitimate interests. See section 5 on automated decision-making. |
5. Automated decision-making
5.1 We use a structured evaluation methodology to shortlist startup funding applicants and to assess Investor Network and Board Programme applications. This involves a scoring or triage step, but final decisions on shortlisting, acceptance and introductions are made or reviewed by a member of our team, not by an algorithm acting alone.
5.2 You will not be subject to a decision based solely on automated processing, including profiling, that produces a legal or similarly significant effect on you, without the safeguards required by Article 22 UK GDPR (including the right to request human review). If you believe a decision affecting your application was made without appropriate human involvement, please contact us using the details in section 1.3.
6. Who we share your personal data with
6.1 We share personal data with the following categories of recipient:
- Executive search firms named on the Site, where you are introduced to them as part of the Board Programme. Once introduced, the search firm acts as an independent controller of your data, and its own privacy notice applies to its subsequent processing;
- Investors, portfolio companies, commercial contacts and funding or client introductions, where you are introduced to them as part of Startup Membership or the Investor Network. These third parties act as independent controllers in the same way;
- Service providers who process personal data on our behalf as processors, under contract, including: our member portal provider (boards.fintechcircle.com), our webinar platform (currently WebinarGeek and Google Meet), our CRM/email marketing platform (currently GHL), analytics and advertising platforms (Google Analytics/GA4, LinkedIn Insight Tag, Meta Pixel), and our payment processor (currently Stripe);
- Professional advisers, including lawyers, accountants and insurers, where necessary for us to obtain advice or manage risk;
- Regulators, law enforcement or other authorities, where we are required to do so by law, or to establish, exercise or defend legal claims; and
- A buyer or successor, if we sell, merge or reorganise our business, subject to appropriate safeguards.
6.2 We do not sell your personal data to third parties for their own marketing purposes.
7. International transfers
7.1 Some of the service providers listed in section 6 (for example, US-headquartered analytics, advertising and CRM providers) may process personal data outside the UK, including in the United States or India/Asia.
7.2 Where we or our processors transfer personal data outside the UK, we put in place appropriate safeguards required by UK GDPR, which may include the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, or reliance on a UK adequacy regulation (for example, the UK-US Data Bridge, where the receiving organisation is certified under it).
8. How long we keep your data
| Category | Retention approach |
|---|---|
| Unsuccessful Board Programme, funding, or Investor Network applications | 24 months from the decision, to allow you to be considered for a future cohort or opportunity, unless you ask us to delete it sooner. |
| Active Board Programme participants, Startup Members and Investor Network participants | For the duration of your participation/membership, and for 6 years afterwards to meet our legal, accounting and tax obligations and to deal with any dispute. |
| Investor eligibility statements (Schedule 2 to our Terms) | For as long as you remain an active Investor Network member, and for 5 years after your last engagement with us, unless you ask us to delete it sooner. |
| Marketing/newsletter data | Until you unsubscribe or ask us to stop, plus a short suppression-list period to record that you opted out. |
| Website analytics data | As set out in our Cookie Policy. |
| Payment records | As required by UK tax law (currently at least 6 years from the end of the relevant accounting period). |
9. Your rights
9.1 Under UK GDPR, you have the right to:
- be informed about how we use your personal data (this Policy);
- access a copy of your personal data;
- have inaccurate personal data corrected, or incomplete data completed;
- ask us to erase your personal data in certain circumstances;
- restrict our use of your personal data in certain circumstances;
- receive your personal data in a portable format, or ask us to transmit it to another organisation, in certain circumstances;
- object to our use of your personal data where we rely on legitimate interests, including for direct marketing (which you can stop at any time); and
- not be subject to a decision based solely on automated processing that has a legal or similarly significant effect on you, without appropriate safeguards (see section 5).
9.2 To exercise any of these rights, contact us using the details in section 1.3. We will normally respond within one month. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk, or, if the EU GDPR applies to the processing in question, to your local EU supervisory authority, although we would welcome the chance to address your concern directly first.
9.3 You can unsubscribe from marketing emails, including the FINTECH Insights newsletter, at any time using the unsubscribe link in any email, or by contacting us directly. Opting out of marketing does not affect service communications (for example, updates about a Board Programme cohort you have joined).
9.4 If you attended an event or webinar and do not want to appear in resulting photographs, recordings or marketing materials, please contact us and we will take reasonable steps to accommodate this, consistent with clause 7.4 of our Terms and Conditions.
10. Security
10.1 We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or disclosure, including access controls.
10.2 No system is completely secure, and we cannot guarantee the absolute security of information transmitted to us. If we become aware of a personal data breach that poses a risk to your rights and freedoms, we will notify the ICO within 72 hours where required, and will notify affected individuals where the breach is likely to result in a high risk to them, in each case as required by UK GDPR.
11. Children
Our Services are intended for business professionals and organisations, and are not directed at, or intended to be used by children. We do not knowingly collect personal data from anyone under 18.
12. Changes to this Policy
We may update this Policy from time to time to reflect changes in our processing activities or legal requirements. The current version, showing the date it was last updated, will always be available on the Site. Where changes are material, we will take reasonable steps to notify active Members.
13. How to contact us
13.1 Questions, requests or concerns about this Policy or our use of your personal data can be sent to info@fintechcircle.com, or by post to FINTECH CIRCLE LTD, 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, marked for the attention of the CEO.
13.2 You have the right to lodge a complaint with the Information Commissioner’s Office at any time: ico.org.uk, or by telephone on 0303 123 1113. Our ICO registration reference is ZB538212.