Privacy Policy

Notion Capital (“we”, “us”, “our”) are committed to protecting and respecting your privacy in accordance with applicable data protection laws from time to time. 

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, that you provide to us, or we receive from others will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. This website is not intended for children, and we do not knowingly collect data relating to children. Notion Capital is made up of different legal entities. This policy is issued on behalf of the Notion Capital Group, which includes any Notion Capital entity that directly or indirectly controls, is controlled by, or is under common control with another Notion Capital entity. So, when we mention “Notion Capital”, “we”, “us” or “our” in this policy, we are referring to the relevant Notion Capital entity responsible for controlling your personal data. 

Notion Capital Managers LLP is the controller and responsible for this website. We have appointed a representative who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise any of your legal rights or any complaint about how we use your personal data, please contact us using the details set out below. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

Information we collect from you

Whether you are an individual investor or a director/shareholder of a company that we are thinking of investing in, or someone from within our network who wishes to have a relationship with us, we may collect and process different kinds of personal data about you, which we have grouped together as follows:

•Identity Data includes your first name, last name, full name, current job title, seniority, function, and a
unique internal identifier we assign to you in our relationship management system.

•Contact Data includes your email address (including any historical or alternative addresses),
telephone number, and your business or general location (street address, city, state or region, and country).

•Professional and Background Data includes your current and previous employers, job titles and start dates, professional seniority, function, years of experience, educational background, notable investments or board positions, your LinkedIn profile URL and headline, and other publicly available professional information enriched from third-party data providers (such as LinkedIn, Crunchbase, and Dealroom).

•Relationship and Interaction Data includes information about your interactions with us, such as the date and subject of our first and most recent email exchanges, the dates of our first, last and upcoming meetings, who at Notion Capital is the relationship owner, who introduced you to us (and who you have introduced to us), and the channel through which we were connected. This includes the metadata of emails and calendar invitations exchanged between you and members of the Notion Capital team where you appear as a sender, recipient, or attendee.

•Financial Data includes investor bank details.

•Investment and Transaction Data (where you are a founder, director or shareholder of a company we are evaluating, have invested in, or are tracking) includes details about your company such as funding rounds, amounts raised, investment stage, instrument and round size, investors on the cap table, exit status, and similar financial information relating to potential or actual investments. Where you are an individual investor or LP, this includes details of the investments and SPVs you participate in alongside us.

•Technical Data includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.

•Profile and Network Data includes information that helps us understand your relevance to our work, such as the industries, sectors, business models, themes and keywords associated with you or your company, your geography and coverage region, internal ratings or scores (for example our RISTA score and Ideal Deal Profile assessment), priority or tier classifications, and free-text notes recorded by members of the Notion Capital team about meetings, calls, and observations involving you.

•Communications Content includes the content of emails, meeting notes, and other written communications between you and the Notion Capital team that are stored in our relationship intelligence platform, together with the names of attendees and any individuals or organisations tagged in those communications.

•Usage Data includes information about how you use our website, the pages you visit, the frequency of your visits, first and last seen timestamps, the length of visits of certain pages, the number of form submissions and the number of unique forms submitted.

‍•Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences, original and latest traffic sources, engagement metrics (such as marketing email open and click dates), and a record of marketing communications sent to you and your interactions with them.

How we collect your personal data

Personal data you give us

This may include Identity Data, Contact Data, Professional and Background Data, Investment and Transaction Data, Financial Data, Communications Content and Marketing and Communications Data about you that you give us by filling in forms on our site (our site) or by corresponding with us by phone, e-mail or otherwise. It includes personal data you provide when you register to receive Notion Capital’s news and updates, subscribe to any of our services, attend our events, pitch your company to us, participate in discussion boards or other social media functions on our site and when you report a problem with our site.

Personal data we collect about you

As you interact with our website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. As you interact with us by email, calendar and other channels, we may also automatically collect Relationship and Interaction Data and Communications Content through our relationship intelligence and customer relationship management platforms, which record the metadata and content of emails and calendar invitations between you and members of the Notion Capital team. We may also collect your Identity Data, Contact Data and Professional and Background Data from publicly available sources, to send you communications which make suggestions and recommendations to you about services or investments that may be of interest to you. You will always be provided with the opportunity to opt-out of receiving these communications (see “Marketing” below).

Personal data we receive from other sources

Sometimes we will receive personal data about you if you use any of the other websites we operate or the other services we provide. In this case, we will have informed you when we collected that data if we intend to share that data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data.

We also collect personal data from third parties in certain circumstances, including, for example: (i) business partners such as accountants and lawyers, located both inside and outside the UK and EEA; (ii) portfolio companies, investors and suppliers, located both inside and outside the UK and EEA; (iii) analytics, marketing and customer relationship management providers (such as Google) based both inside and outside the UK and EEA; and (iv) third-party data enrichment providers (such as LinkedIn, Crunchbase and Dealroom) which provide Professional and Background Data and Profile and Network Data about you from publicly available sources; (v) publicly available sources such as LinkedIn, Companies House and the Electoral Register based inside the UK and EEA; and (vi) TransUnion, our KYC check provider.  Information about how TransUnion process your personal data can be found here: https://www.transunion.com/privacy/transunion.

In addition, we may have received your personal data from our initiative, known as “Included” or “Included VC”. This is an initiative which allows both us and other investment venture funds, partners and sponsors across Europe to have access to potential fellows’ data.  For further information about how Included VC will collect and process fellows’ personal data, please visit the Included privacy policy here: https://www.included.vc/privacypolicy.

Uses made of the personal data

‍Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.  

You can manage your cookie preferences and withdraw your consent to cookies requiring consent at any time by using the cookie settings tool on our website. You may also be able to change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some functionality of our website.

For further information on cookies and our use of them, please see our Cookie Policy here: https://www.notioncapital.com/cookies

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

•Where we need to perform the contract we are about to enter into or have entered into with you.

•Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

•Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, other than in relation to (i) sending third-party direct marketing communications to you via email; (ii) certain introductions within our network; and (iii) using non-essential cookies on our website.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Automated decision-making and profiling

We may use internal scoring, matching, prioritisation and relationship intelligence tools to help us assess potential investment opportunities, professional relationships, network relevance and communications. These tools support our team’s decision-making but, unless we tell you otherwise, we do not make decisions about you based solely on automated processing which produce legal or similarly significant effects.

Where we make a significant decision about you based solely on automated processing, we will provide you with information about that decision and will give you the opportunity to make representations, obtain human intervention and contest the decision.

Investment Evaluation

Notion Capital is likely to receive and store personal information as part of its investment evaluation process. If you are involved in a transaction that Notion Capital and/or the funds that it manages or advises enters into, or a potential transaction that Notion Capital considers, we may store personal information relating to you. This might include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out. We collect and store this information for the purposes of:

•Evaluating a transaction and your role in it;

•Executing transactions;

•Managing an investment once made;

•Maintaining records of investments;

•Meeting regulatory and legal obligations e.g. KYC checks;

•Safeguarding our legal rights and interests;

•Seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants; and

•Providing periodic business updates, as described below.

We store and process information in this way because it is necessary to:

•perform a contract to which you are likely to be a party;

•comply with a legal or regulatory obligation; and/or

•protect our legitimate interests in running and promoting our business.

Marketing

We aim to give you control over the marketing you receive from us. We may use your Identity Data, Contact Data, Professional and Background Data, Technical Data, Usage Data, Profile and Network Data, and Marketing and Communications Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

If you are an individual, you will receive marketing communications from us where you have specifically consented to receive them, or where you have entered into a contract with us and we are therefore permitted to send you marketing without consent (in these situations our basis for contacting you is that it is in our legitimate interests, to develop and grow our business). In each case, you have the right to opt out at any time.

If we are contacting you as a business, we do so where we are entitled to contact you with marketing information on the basis of our legitimate interests (to develop and grow our business), provided that you have not previously opted out of receiving such communications.

In some circumstances, you may receive marketing communications from us where we have obtained your Identity Data, Contact Data and Professional and Background Data from publicly available sources. We rely on our legitimate interests as the basis for this where it is lawful to do so, and you will always be given the opportunity to opt out of receiving these communications.

Third-party marketing

We will obtain your express opt-in consent before we share your personal data with any company outside the Notion Capital group of companies for marketing purposes. You can withdraw this consent at any time by contacting us using the details below.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by clicking the 'unsubscribe' button at the bottom of any marketing email, or by contacting us at 91 Wimpole Street, London W1G 0EF or info@notioncapital.com at any time.

Where you have given consent for us to use non-essential cookies, you can withdraw that consent at any time by adjusting your preferences through our cookie banner or by following the instructions in our Cookie Policy.

Please note that opting out of marketing communications will not affect personal data we process in connection with a contract, a legal obligation, or any other lawful basis. We may still need to send you service-related or transactional communications (for example, in relation to investments, contractual notices, or required regulatory disclosures).

Disclosure of your personal data

We may have to share your personal data with the parties set out below for the purposes set out above:

•Any member of the Notion Capital Group, which includes any Notion Capital entity that directly or indirectly controls, is controlled by, or is under common control with another Notion Capital entity acting as both controllers and processors (depending on the circumstances) based inside and outside the UK and EEA.

Selected third parties including:

•Business partners, including portfolio companies and investors, acting as processors or joint controllers based inside and outside the UK and EEA.

•Suppliers and sub-contractors acting as processors based inside and outside the UK and EU who provide IT and systems and administration services.

•TransUnion to perform KYC checks.  Information about how TransUnion process your personal data can be found here: https://www.transunion.com/privacy/transunion.

•Professional advisers acting as processors or independent controllers including lawyers, bankers, auditors and insurers based in the UK, the US and other jurisdictions outside the EEA who provide consultancy, banking, legal, insurance and accounting services.

•Regulators and other authorities, including HMRC acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

•Analytics and search engine providers based in jurisdictions both inside and outside of the UK and EU that assist us in the improvement and optimisation of our site.

Please contact us at 91 Wimpole Street, London W1G 0EF or info@notioncapital.com if you want further information on the Notion Capital Group or any third party with whom we share your personal data.

We will disclose your personal data to third parties:

•In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

•If Notion Capital or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

•If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Notion Capital, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

International transfers

We share your personal data within the Notion Capital Group. This may involve transferring your data outside the UK and European Economic Area (EEA). Many of our external third parties are based outside the UK and EEA so their processing of your personal data will involve a transfer of data outside the UK and EEA. Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

•We will transfer your personal data to countries, territories or recipients that have been deemed to provide an adequate level of protection for personal data.

•Where we use certain service providers, we may use standard contractual clauses and the UK addendum or international data transfer agreement, provided that these are sufficient to safeguard the transfer of your personal data outside of the UK and EEA.

Please contact us at 91 Wimpole Street, London W1G 0EF or info@notioncapital.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Where third parties process personal data on our behalf as processors, they will only process it on our instructions and will be subject to appropriate contractual obligations. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our Data Retention Register which you can request by contacting us.

Your rights

You have certain rights under data protection law, which we have set out below. You can exercise your rights at any time by contacting us at 91 Wimpole Street, London W1G 0EF or info@notioncapital.com.

You have the right to complain to us, and also the ICO (the UK's data protection regulator) about the processing of your personal data. Please see the 'How to make a data protection complaint to us' section below for further details.

Under certain circumstances, by law you also have the right to:

•Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

•Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.

•Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).

•Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.

•Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

•Request the transfer of your personal data to another party. If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us.

No fee usually required

You will not have to pay a fee to exercise any of your rights as set out above. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity to ensure that you do have a right to exercise any of your rights as set out above. This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

Other than for direct marketing, we will not usually rely on your consent as the legal basis for processing your personal data.  In the limited circumstances where we have requested you to consent to the processing of your personal data for a specific purpose, and you have provided such consent, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at 91 Wimpole Street, London W1G 0EF or info@notioncapital.com. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

How to make a data protection complaint to us

If you have a complaint about how we use your personal data, you can contact us using the details set out below. We will acknowledge receipt of your complaint within 30 days and will take appropriate steps to investigate and respond to your complaint without undue delay. We will keep you informed where appropriate and will tell you the outcome of our investigation.

You also have the right to complain to the ICO, the UK data protection regulator, or any other relevant data protection regulator, at any time. You can make a complaint to the ICO here: https://ico.org.uk/make-a-complaint/data-protection-complaints/. However we would appreciate the chance to deal with your concerns first.

Third party sites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

We use a CRA, TransUnion, to provide KYC checks.  Information about how TransUnion process your personal data can be found here: https://www.transunion.com/privacy/transunion.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to us at 91 Wimpole Street, London W1G 0EF or info@notioncapital.com.

This version was last updated in August 2026.

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