This policy explains how Multiplier collects and uses personal data when you visit our website, request access, subscribe to updates or use our platform. It describes your rights and the purposes and legal bases for processing. The controller is identified below.
1. Who is responsible.
[Legal entity name], [address], is the controller of your personal data. You can contact us, or our data protection contact [name/role], at [email address].
2. The data we collect.
- Request details: your name, work email, firm or organisation, country, the type of participant you are, and anything you tell us in the request form.
- Verification and onboarding details, when you move forward: identity and contact details, evidence of your status as an eligible investor, adviser or sponsor, and information needed for legal and compliance checks. [Verification providers: to be confirmed.]
- Visit records: when you first enter the website we record the status you confirm, your country, the date and time, the version of the wording you saw, the page you were on, your browser's user agent and an anonymous visitor identifier. We do not store your IP address in this record.
- Cookie choices: whether you accepted essential cookies only, all cookies, or a custom selection.
- Subscriptions: your email address, your consent to email updates and your selected participant status (investor, sponsor or adviser), including the status reused from entry confirmation or selected if that record is unavailable.
- Communications: messages you send us and our replies.
- Technical data: browser and device information accompanying visits and submissions, and information necessary to operate and secure the site. Optional app analytics is enabled only after an explicit analytics grant; the site does not currently add its own analytics tracker.
Request information may also include role-specific responses, investment interests, organisation or licence details and optional notes that you choose to provide. Do not send unnecessary sensitive personal data. Entry confirmation is held in a first-party cookie and local storage; an unsuccessful recording attempt may be queued locally for retry. These browser records are separate from server retention periods. See the Cookie policy for their actual lifetimes.
3. How and why we use it.
We use personal data to: review and respond to your request; verify that you are eligible and give you access to the platform; keep records that show you confirmed your status and accepted our terms; run, secure and improve the website; send updates you asked for; and meet our legal and regulatory duties, including checks required to prevent financial crime. Where the law requires a legal basis, we rely on: your consent (for analytics cookies and optional updates, which you can withdraw at any time); steps you ask us to take before entering an agreement; our legitimate interests in running and securing a professional platform and keeping records; and compliance with legal obligations.
For UK and EU-style data protection purposes, our bases are applied by purpose: consent for optional email updates and any optional analytics; necessary pre-contractual steps for an access request made at your initiative; legitimate interests for ordinary enquiries, site security, administration, record keeping and prevention of misuse; and a legal obligation where a specific applicable law requires processing. Eligibility and onboarding processing may rely on pre-contractual steps, performance of a contract or an applicable legal obligation depending on the relationship and requirement. We consider your interests and rights when relying on legitimate interests. You may object to that processing.
Providing information needed to review a request or establish eligibility may be necessary to progress it; without it we may be unable to respond or provide access. Optional updates and analytics are not required. We do not use solely automated decision-making, including profiling, that produces legal or similarly significant effects. Reusing your selected status to tailor updates is not an automated eligibility or investment decision.
4. Who we share it with.
We share personal data only where needed with: service providers that host the website, store data, send email, provide analytics (only if you consented) or carry out verification, who act on our instructions; professional advisers, auditors and insurers; regulators, courts and law enforcement where required; and, as you direct, the adviser, sponsor or investor you choose to deal with on the platform. When you request access or subscribe to updates, we use Brevo as our email delivery processor to send request details to our team or to store your email address for updates; we use the status you selected when entering the site to send you relevant updates. We do not sell personal data. If our business is reorganised, data may transfer to the new owner under this policy.
For subscriptions, only your email address is sent to the Brevo list corresponding to your selected status; no additional personal attributes are sent for segmentation. Request-alert delivery is separate and includes request information for our team. Access to records is restricted to the people and providers who need it for their role. Provider categories are described here without assuming that an unconfirmed verification or analytics provider has been appointed.
5. International transfers.
Your data may be processed outside your country, including in countries with different data protection laws. Where required, we use appropriate safeguards, such as contractual clauses approved for that purpose. [Hosting location and transfer mechanisms: to be confirmed.]
Where UK or EU transfer rules apply, transfers requiring safeguards will be subject to an applicable adequacy decision or appropriate contractual safeguards, as relevant to the actual arrangement. Contact us using the details below for information about applicable safeguards and how to obtain a copy, subject to necessary redactions. The placeholder above identifies details that remain to be supplied; no particular hosting country or transfer mechanism is asserted here.
6. How long we keep it.
We keep personal data only as long as needed for the purposes above. [Retention periods to be confirmed: for example, request details for [period] if no relationship follows; visit and consent records for [period]; verification and onboarding records for the period required by law.] We then delete or anonymise it.
Retention depends on the purpose, the relationship, applicable legal requirements, dispute or audit needs and the time required to respond to an enquiry. Withdrawing update consent stops future optional sends; a limited record of withdrawal may be retained where necessary to respect the choice or establish compliance. Browser storage lifetimes are described in the Cookie policy and must not be treated as the retention periods for server records.
7. Security.
We use appropriate technical and organisational measures to protect personal data, including access controls, encryption in transit and restricted access to records. No system is completely secure, so please protect your own login details.
Access is limited according to purpose and role and we take proportionate steps to prevent unauthorised disclosure, loss and misuse. No internet transmission or storage method is completely secure. If a personal data breach occurs, we will assess and make notifications required by applicable law. Do not include sensitive information in an ordinary website enquiry unless requested through an appropriate process.
8. Your rights.
Depending on where you live, you may have the right to: be informed about how we use your data; access it; correct it; have it deleted; restrict or object to some uses; receive a copy in a portable format; withdraw consent; and complain to a data protection authority. To exercise a right, contact us at [email address]. We may need to verify your identity first. Some rights are limited where we must keep records by law.
Under applicable UK or EU rules, rights include access, rectification, erasure, restriction, portability where processing is automated and based on consent or contract, and objection to processing based on legitimate interests. You may object to direct marketing at any time. You can withdraw consent through an unsubscribe option, cookie preferences or by contacting us; withdrawal does not affect processing that was lawful before it.
We respond within applicable statutory time limits and ordinarily without charge, subject to lawful exceptions for manifestly unfounded or excessive requests. We may ask only for information reasonably needed to establish identity and process the request. Exceptions may apply to protect others’ rights or comply with legal obligations. You may complain to the supervisory authority where you habitually reside, work or consider an infringement occurred, including the UK Information Commissioner where relevant, without first contacting us.
9. Regional information.
- United Arab Emirates: we process personal data in line with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and, where they apply, the data protection laws of the Dubai International Financial Centre and the Abu Dhabi Global Market. [Data protection position in the UAE]
- Malaysia: we process personal data in line with the Personal Data Protection Act 2010, as amended. [Data protection position in Malaysia]
- Mexico: we process personal data in line with the Ley Federal de Protección de Datos Personales en Posesión de los Particulares. You can exercise your rights of access, rectification, cancellation and opposition (ARCO) by contacting us at [email address]. [Privacy notice (aviso de privacidad) wording]
References to regional law describe potentially applicable requirements and do not assert that Multiplier holds any regulatory authorisation. Applicable local rights and mandatory rules prevail. Regulatory status is described in the Regional notices.
10. Children.
The website is for professional and eligible users and is not directed at anyone under 18. We do not knowingly collect data from children.
If we become aware that a child has supplied personal data inappropriately, we will take proportionate steps to remove it, subject to any legal requirement to retain a record. Contact us if you believe this has happened.
11. Cookies.
We use essential first-party cookies and local storage to remember entry confirmation and cookie choices and retry unsaved visitor records. Optional app tracking requires explicit consent; the site does not currently add its own analytics tracker. See our Cookie policy for the storage inventory and how to change your choices.
12. Changes.
We may update this policy. The version on this page applies from the date shown, and we will take reasonable steps to tell registered users of material changes.
13. Contact and complaints.
Contact: [email address], [postal address]. You also have the right to complain to your local data protection authority.
