Privacy Policy

Below are our Terms of Service, which outline a lot of legal goodies, but the bottom line is it’s our aim to always take care of both you, and your data.

Policy version: September 2024

www.founderandlightning.com (our website) is provided by ucreate Limited, trading as Founder + Lightning (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).

Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.

This privacy policy is divided into the following sections:

•                 What this policy applies to

•                 Personal data we collect about you

•                 How your personal data is collected

•                 How and why we use your personal data

•                 Marketing

•                 Who we share your personal data with

•                 How long your personal data will be kept

•                 Transferring your personal data out of the UK and EEA

•                 Cookies

•                 Your rights

•                 Keeping your personal data secure

•                 How to complain

•                 Changes to this privacy policy

•                 How to contact us

What this policy applies to

This privacy policy relates to your use of our website only.

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website. We may collect and use the following personal data about you:

  1. your name and contact information, including email address and telephone number
  2. location data (region, IP address) and full address, if you choose to give this to us via the contact form
  3. details of any information, feedback or other matters you give to us by phone, email, post or via social media
  4. your activities on, and use of, our website, for example your use of the website, duration of a visit and how often you visit
  5. your professional online presence, eg LinkedIn profile
  6. information about the services we provide to you
  7. your contact history
  8. information about how you use our website and technology systems

To complete the website contact form, you must provide the personal data detailed in a), c) and e). To browse our website, we will ask for your consent to collect the data detailed in b), d) and f) - g).

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We may collect personal data from you:

•                 directly, when you enter or send us information, such as when you contact us (including via email), send us feedback, and complete the contact form via our website;

•                 indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies’ below; and

•   via publicly available sources, such as your professional online presence eg LinkedIn

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

•                 where you have given consent

•                 to comply with our legal and regulatory obligations

•                 for the performance of a contract with you or to take steps at your request before entering into a contract, or

•                 for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

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What we use your personal data for
Our reasons
Creating and managing your relationship with us
To perform our contract with you or to take steps at your request before entering into a contract
Providing services to you
To perform our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us
For our legitimate interests, ie to minimise fraud that could be damaging for you and/or us
Enforcing legal rights or defend or undertake legal proceedings
Depending on the circumstances:—to comply with our legal and regulatory obligations—in other cases, for our legitimate interests, ie to protect our business, interests and rights
Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website
Depending on the circumstances:—your consent as gathered by the cookies tool on our website —see ‘Cookies’ below—where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to youIf you have provided such consent you may withdraw it at any time by changing your cookie settings (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended
Depending on the circumstances:—your consent as gathered by the separate cookies tool on our website —see ‘Cookies’ below
—where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to youIf you have provided such a consent you may withdraw it at any time by changing your cookie settings (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Communications with you not related to marketing, including about changes to our terms or policies or changes to services or other important notices
Depending on the circumstances:—to comply with our legal and regulatory obligations—in other cases, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you
Protecting the security of systems and data used to provide the services
To comply with our legal and regulatory obligationsWe may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Statistical analysis to help us understand our customer base
For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you
Updating and enhancing customer records
Depending on the circumstances:—to perform our contract with you or to take steps at your request before entering into a contract—to comply with our legal and regulatory obligations—where neither of the above apply, for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing and new service
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant
To comply with our legal and regulatory obligations
Marketing our services to existing and former customers
For our legitimate interests, i.e. to promote our business to existing and former customersSee ‘Marketing’ below for further information
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvencyIn such cases information will be anonymised where possible and only shared where necessary
Depending on the circumstances:—to comply with our legal and regulatory obligations—in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets

How and why we process your personal data—in more detail

More details about how we use your personal data and why are set out in the table below

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Purpose
Processing operation
Lawful basis relied on under the UK GDPR and EU GDPR
Relevant categories of personal data
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices
Addressing and sending communications to you as required by data protection laws, i.e.:—the UK GDPR or Data Protection Act 2018—the EU GDPR
Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))
—your name and contact information, including email address and telephone number and company details
Addressing and sending communications to you as required
Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))
—your name and contact information, including email address and telephone number and company details
Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above)
Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you
—your name and contact information, including email address and telephone number and company details
Completing the contact form on our website; contacting us via phone/email, post or social media; or registering to receive a newsletter
Addressing and sending communications to you, as required
Consent
—your name and contact information, including email address and telephone number and company details
—details of any information, feedback or other matters you give to us by phone, email, post or via social media
—your contact history
—location data, if you choose to give this to us
—information about the services we provide to you

How and why we use your personal data—sharing

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

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Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

•                 contacting us at legal@founderandlightning.com, or

•                 using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never share] it with other organisations outside the Founder + Lightning group for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

•                 third parties we use to help us run our business, e.g. website hosts and website analytics providers

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

•                 our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations

•                 law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations

•                 other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations

Who we share your personal data with—further information

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data.

Transferring your personal data out of the UK and EEA

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

We will transfer your personal data to:

•                 our subsidiaries located outside the UK

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

•                 in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers

•                 in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here. We rely on adequacy decisions for transfers

•                 there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or

•                 a specific exception applies under relevant data protection law

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

You may contact us for a copy of the safeguards which we have put in place to protect your data and privacy rights in these circumstances.

Transferring your personal data out of the UK and EEA —further information

If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).

Cookies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies, or when we will request your consent before placing them and how to disable them, please see our Cookie Policy [insert link to Cookie Policy].

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Your rights

You generally have the following rights, which you can usually exercise free of charge:

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Access to a copy of your personal data
The right to be provided with a copy of your personal dataA more detailed explanation of this right under UK law is available her
Correction (also known as rectification)
The right to require us to correct any mistakes in your personal dataA more detailed explanation of this right under UK law is available here
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data—in certain situationsA more detailed explanation of this right under UK law is available here
Restriction of use
The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the dataA more detailed explanation of this right under UK law is available here
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situationsA more detailed explanation of this right under UK law is available here
To object to use
The right to object:—at any time to your personal data being used for direct marketing (including profiling)—in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claimsA more detailed explanation of this right under UK law is available here
Not to be subject to decisions without human involvement
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects youWe do not make any such decisions based on data collected by our websiteA more detailed explanation of this right under UK law is available here
The right to withdraw consents
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any timeWithdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

 For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

• provide enough information to identify yourself (eg your full name, address and company name) and any additional identity information we may reasonably request from you, and

•  let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

•                 the Information Commissioner in the UK

•                 a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

For a list of EEA data protection supervisory authorities and their contact details see here.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.

How to contact us
Individuals in the UK

You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are: legal@founderandlightning.com

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UK

Aldgate Tower,
2 Leman St,
London E1 8FA

India

E-314, Second Floor
Industrial Area, Sector 75
Sahibzada Ajit Singh Nagar
Punjab
160055

Poland

ul. Krakusa 1130-535,
Kraków
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Investing in start-ups and early stage businesses involves risks, including illiquidity, lack of dividends, loss of investment and dilution. It should be done only as part of a diversified portfolio. Any investments are targeted exclusively at investors who understand the risks of investing in early stage businesses and can make their own investment decisions. Any pitches for investment are not offers to the public.Investments made in investee companies via funds managed by Sapphire Capital Partners LLP (FRN: 565716) may be covered by the Financial Services Compensation Scheme (FSCS). For more details, please contact us or refer to their website: https://www.fscs.org.uk