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 submit a Funding Request, take part in a call with us, or engage with us in connection with our services. It also explains the cookies and similar technologies this website uses.

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 20 Wenlock Road, London, England, N1 7GU, United Kingdom, is the data controller of the personal data we process in connection with this website and our business activities. We are registered with the Information Commissioner’s Office under registration number ZC271143. We have not appointed a Data Protection Officer, as the law does not require us to; data protection matters are handled by our Director, Jake Newton, who can be contacted at jake@newtonventures.ltd.

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

(a) information you provide directly to us, including through website forms, the Initial and Full Funding Request Forms, enquiries, telephone and video 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;

(f) recordings, transcripts, AI-generated summaries and notes of calls and video meetings you take part in with us, which we make with notice at the start of the call;

(g) information about you that we receive from others or hold in our own records: from an Introducer who refers you to us, from your colleagues or advisers acting for you, from Companies House and other public registers, from the Funding Channels and Capital Providers we work with, from identity-verification, sanctions and fraud-prevention services, and from our own business correspondence — the business contact details (name, email address, telephone number, company and role) of people who have corresponded with us or our staff about our business, which we identify by reviewing the email held in our staff mailboxes, including past correspondence (see section 2.3);

(h) publicly available professional information about Introducers, prospective Clients and Clients — from company websites, public professional-network profiles and other public search results — limited to your business role, employer and business contact details. We do not log in to any platform to obtain it, and anything obtained this way is marked unconfirmed until a member of our team has checked it.

2.2 Where we obtain your personal data other than from you, we tell you how we use it — by giving you this Policy — within one month of obtaining it or when we first communicate with you, whichever is sooner. Where we hold only business contact details drawn from past correspondence and are not otherwise in contact with you, giving you this Policy individually would involve disproportionate effort; we make it publicly available on this website instead, and we give it to you when we next communicate with you.

2.3 To keep our relationship records complete and accurate, we review the email held in our staff business mailboxes, including past correspondence, to identify the people who have corresponded with us about our business. For this review we use only the names and email addresses of senders and recipients, the dates and subject lines of emails and, where you have written to us, the signature block of your most recent email, from which an AI-assisted tool proposes your company and role (section 11.1(i)). Automated and mailing-list senders are left out. A member of our team checks each proposed contact before it is added to our records, we do not copy the content of your emails into those records, and the working index used for the review is deleted once the review is complete.

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, our Dubai group company, the Funding Channels and Capital Providers we work with, professional parties or other counterparties may be able to assist with a Funding Request or commercial opportunity;

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

(e) to prepare, review and manage documentation, data rooms, Capital Request 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, Capital Providers, professional parties and counterparties — including keeping a record of the people and businesses we deal with, built from our correspondence and from public professional sources, and noting each contact’s role in a Funding Request — and to keep in touch with Clients and Introducers about our services and our Introducer terms (see section 4A);

(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 the UK GDPR. The lawful basis for each purpose in section 3 is:

(a) purposes 3.1(b), (c), (d), (e) and (g): contract — the processing is necessary to take steps at your request before entering into an agreement with you, or to perform one; where you are not yourself our contracting party (for example, you are a director, shareholder, adviser or Introducer), our legitimate interest in assessing and progressing the Funding Request you are connected with;

(b) purposes 3.1(f) and (h): legal obligation — identity, anti-money laundering, sanctions and fraud-prevention checks and our accounting, tax and record-keeping duties; where no legal obligation strictly applies to us, our legitimate interest in meeting the standards expected of us by the Funding Channels and Capital Providers we work with;

(c) purposes 3.1(a), (i) and (j), and purpose 3.1(g) so far as it concerns people with whom we have no contract — Introducers, prospective Clients and the staff of Funding Channels, Capital Providers and counterparties: legitimate interests — running and securing our website, understanding how it is used, keeping accurate records of the people and businesses we deal with, developing our business, and protecting our legal position;

(d) non-essential cookies (section 7) and any marketing to an individual’s personal email address (section 4A): consent, which you may withdraw at any time.

4.2 Where we rely on legitimate interests we have balanced them against your rights and interests. Our legitimate interests are managing and developing our business, responding to enquiries, assessing potential transactions, conducting appropriate due diligence, communicating with Clients, Introducers and counterparties, keeping accurate relationship records, protecting our business, preventing fraud, keeping business records, and improving our website and services. We have recorded a legitimate interests assessment for our relationship records and our business-to-business marketing, which you may ask to see. You may object to processing based on legitimate interests at any time (section 11).

4A.1 We may contact Clients, Introducers and prospective Clients and Introducers about our services, and Introducers about our Introducer terms, by email and telephone. Where we write to a corporate email address we do so on the basis of our legitimate interest in promoting our services to businesses. Where we write to an individual’s personal email address, or to a sole trader or partnership, we do so only where you have asked about our services, given us your consent, or where the message is about an arrangement you already have with us.

4A.2 Every marketing email we send tells you how to opt out, and you can ask us to stop at any time by replying “unsubscribe” or by emailing jake@newtonventures.ltd. A reply containing “unsubscribe” is recorded automatically and we will not contact you about our services again, including if your details reach us again later, for example through a new introduction (section 9.2(i)). You have an absolute right to object to direct marketing (section 11). Opting out of marketing does not affect emails we send you about a live Funding Request.

4A.3 We do not buy marketing lists and we do not share your details with third parties for their own marketing.

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, customer-relationship management, call recording and transcription, administration and business operations — including Google (Workspace, Drive and Google Cloud, in which our internal contact and deal records are held, and the Gemini AI service, used under Google’s business terms, which do not permit our data to be used to train its models), Zoom (video calls, recording, transcription and AI meeting summaries), our website host and our other AI-assisted drafting and transcription tools — each acting on our instructions under a written contract;

(b) our Dubai group company, which contracts with Clients and manages Funding Requests after the initial review, and the Funding Channels, Capital Providers, family offices, institutions, counterparties and professional parties engaged where necessary to assess, progress or manage a Funding Request, transaction or commercial opportunity;

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

(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. Our service providers process personal data only on our instructions under written contracts that meet UK GDPR requirements.

5.4 Providing personal data to us is voluntary. However, we cannot assess or progress a Funding Request without the information described in section 2(b) and (c), and we cannot carry out the compliance checks in section 3.1(f) without identification documents. If you do not provide that information we will not be able to take a Funding Request forward.

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.

6.5 Calls and video meetings with us are recorded, transcribed and summarised — using Zoom’s recording and AI features and our AI-assisted tools — so that there is an accurate record of what was discussed and agreed. We tell you at the start of every call, through Zoom’s recording notice, that it is being recorded. Recordings, transcripts and notes are stored with the record they belong to under section 9.2 and are shared only as set out in section 5.

7.1 This website uses cookies and similar technologies. Strictly necessary cookies are set without consent because the website cannot function without them. All other cookies — analytics, functionality and marketing — are set only if you consent through the cookie banner shown when you first visit, and you can change or withdraw your choice at any time through the cookie settings link in the website footer.

7.2 The cookies and similar technologies this website uses, or may use, are:

(a) strictly necessary cookies required for the website to function and to remember your cookie choices (set by our website host, Vercel, and by this website);

(b) analytics cookies that help us understand how visitors use the website (Vercel Analytics and Google Analytics), set only with your consent;

(c) functionality cookies that remember preferences or support embedded services such as our scheduling and video-call tools (for example Zoom or Calendly), set only with your consent;

(d) marketing and customer-relationship cookies that let us recognise a returning visitor who has enquired with us (set by our CRM platform, for example HubSpot), set only with your consent. We do not use third-party advertising networks.

7.3 A full list of the cookies in use, who sets them and how long they last is available through the cookie settings link in the website footer and is updated whenever the website changes.

7.4 You can also manage or delete cookies through your browser settings. Disabling strictly necessary cookies may affect how the website functions.

8.1 Personal data relating to a Funding Request is transferred to our Dubai group company in the United Arab Emirates, which manages Funding Requests after the initial review, and may be shared with Funding Channels and Capital Providers located outside the United Kingdom according to the funding sources suited to the Funding Request. Some of our service providers also store or access data outside the United Kingdom.

8.2 The United Arab Emirates is not covered by UK adequacy regulations. Our transfers to our Dubai group company are made under the Information Commissioner’s International Data Transfer Agreement, which contractually binds it to UK-standard protections, together with a transfer risk assessment.

8.3 Our service providers Google and Zoom process some personal data in the United States under the UK Extension to the EU-US Data Privacy Framework or the UK Addendum to the EU Standard Contractual Clauses. Other international transfers are made only to countries covered by UK adequacy regulations, under the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, or, in a specific case, with your explicit consent or because the transfer is necessary for a contract made at your request. You can ask us for details of the safeguards applied to any transfer.

9.1 We keep personal data only for as long as needed for the purposes it was collected for and to meet our legal and record-keeping duties. Our standard retention periods are:

9.2 (a) Funding Request records — the Funding Request Forms, correspondence, call transcripts and notes, Capital Request Files, agreements and transaction documents: 7 years after the Funding Request closes or the last transaction under it completes — the six-year limitation period for contractual claims under the Limitation Act 1980, with a further year for claims issued near the end of that period; (b) identity, anti-money laundering and know-your-client material: 5 years after the end of the business relationship, the period the UK money-laundering regulations set for regulated firms and which the Funding Channels and Capital Providers we work with expect; (c) enquiries and Funding Requests that do not proceed: 3 years after our last contact with you, so that we can pick up where we left off if you come back to us and deal with any later query, after which they are deleted or anonymised; (d) accounting and tax records, including invoices: 6 years after the end of the financial year they relate to; (e) marketing contact details: until you ask us to stop, and in any case reviewed every 24 months; (f) website analytics data: 14 months; website security logs: 90 days; (g) business contact records of Introducers, prospective Clients, the staff of Funding Channels, Capital Providers and counterparties, and other business contacts with no live Funding Request: for as long as we have a business relationship with you; where there has been no contact for 24 months and there is no live Funding Request, the record is reviewed and is deleted or anonymised unless there is a continuing business reason to keep it; (h) call audio and video: until 2 years after the call or, where the call relates to a Funding Request, until 2 years after that Funding Request closes, whichever is later; the transcript and notes are kept with the record they belong to under (a) or (g); (i) our suppression list — the name and email address of anyone who has asked us not to contact them, with the date and how the request reached us: kept for as long as we carry on our business, so that we continue to honour your request if your details reach us again.

9.3 We may keep data for longer where it is needed in connection with a current or reasonably anticipated complaint, dispute, claim or regulatory enquiry: once one is made or reasonably expected, we suspend the deletion of the records relating to it until it has been finally resolved. When personal data is no longer required, we delete it, anonymise it 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.

10.4 Our Dubai group company applies the same standards to personal data it receives from us under the transfer agreement described in section 8.2.

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 processing based on our legitimate interests, and an absolute right to object to direct marketing at any time;

(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. We do not make decisions about you based solely on automated processing. We use AI-assisted tools (currently Google’s Gemini) to read email signatures and public professional sources and to propose a contact’s company, role and category; to transcribe and summarise calls; and to help draft documents and correspondence. Every proposal is checked, and every email is sent, by a named member of our team, who remains responsible for it, and no decision about a Funding Request, or any decision with legal or similarly significant effects, is taken by an automated system.

11.2 To exercise any of these rights, email jake@newtonventures.ltd or write to us at our registered office. We will respond within one month, which we may extend by up to two further months for complex or numerous requests, telling you if so. There is no charge unless a request is manifestly unfounded or excessive.

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

11.4 If you ask us to delete your personal data or object to our contacting you, we keep only your name, email address, the date and how your request reached us on our suppression list (section 9.2(i)), so that we do not contact you again, for example if you are introduced to us again in future.

12.1 If you have concerns about how we handle your personal data, please contact us first at jake@newtonventures.ltd 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, the UK regulator for data protection matters: ico.org.uk, telephone 0303 123 1113, or Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

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.

13A.1 This website and our services are for businesses, business owners and the professionals who act for them. They are not directed at consumers or at anyone under 18, and we do not knowingly collect personal data from children.

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 is shown at the foot of this page. Where a change materially affects how we use your personal data, we will tell Clients and Introducers we are in contact with directly.

15.1 For any queries regarding this Privacy and Cookies Policy or the handling of your personal data, please contact Newton Ventures Ltd at jake@newtonventures.ltd, or by post at our registered office.