PRIVACY POLICY
A legal disclaimer
This Privacy Notice explains how Infundly Limited collects, uses, shares and protects personal information when you visit www.infundly.co.uk, register for professional access, subscribe to updates, purchase or use a service, upload material to a digital tool, make an enquiry or otherwise interact with us.
Who we are
Infundly Limited is a company registered in England and Wales. It provides independent fund research, research-conviction views and ratings, due-diligence context, fund-discovery resources, professional publications and research-support tools for professional investment decision-makers.
Infundly Limited is not authorised or regulated by the Financial Conduct Authority. Its content and tools provide research and due-diligence context, not personal financial advice, investment management, arranging services or a regulated recommendation to invest.
For UK data-protection law, Infundly Limited is normally the controller of the personal information described in this notice.
**Company number: [INSERT INFUNDLY LIMITED COMPANY NUMBER] **Registered office: Hoxton Mix, 3rd Floor, 86–90 Paul Street, London, EC2A 4NE **Website: www.infundly.co.uk
Privacy email: privacy@infundly.co.uk
ICO registration number: [INSERT IF APPLICABLE]
Who our services are for
Infundly is intended principally for professional fund selectors and allocators, including advisers, regulated firms, discretionary fund managers, MPS teams, wealth managers, platforms, banks, family offices, institutional investors, charity trustees operating through appropriate governance processes, investment committees and asset-management professionals.
We may process information about employees, directors, partners, trustees, consultants, committee members, subscribers, prospective clients, licensed users and other people acting for these organisations.
Our website, research and tools are not intended for children or for retail investors seeking personal financial advice.
Personal information we may collect
Depending on how you interact with us, we may collect: -
**Identity and contact information: name, business email, telephone number, employer, professional role and postal address. -
**Professional-access information: firm type, role, professional capacity, regulatory status, investment-governance responsibilities and the reason access is requested. - **Account information: login credentials, account preferences, access level, membership or plan information, authentication and service-access history. - **Enquiry and communication information: forms, meeting requests, correspondence, surveys, feedback and support requests. -
**Subscription, licensing and transaction information: services or licences purchased, billing contacts, invoices, payment status and VAT information. Card information is generally handled by a secure payment provider rather than by us directly. -
**Research interests and engagement information:** content preferences, areas of research interest, pages or publications viewed, downloads, event attendance and engagement with communications. -
**Tool inputs and uploaded material: prompts, fund names, stated research purposes, concerns, factsheets, prospectuses, due-diligence questionnaires, meeting notes, committee papers and other documents submitted to an Infundly tool. -
**Tool outputs and operational records: generated drafts, processing status, error and audit logs, user feedback and records needed to operate, secure and improve the tool. -
**Website and technical information: IP address, device and browser information, approximate location, referral source, cookie identifiers, pages visited, and analytics and security information. -
**Marketing information: subscriptions, consent records, communication choices, opt-outs and engagement with professional updates.
Uploaded documents may contain personal information about fund managers, professional contacts or other individuals. We do not intentionally seek special-category information or information about criminal convictions. Please remove unnecessary personal or sensitive information before uploading material.
How we obtain personal information
We obtain information:
- directly from you when you register, subscribe, enquire, purchase, correspond or use a tool;
- from the organisation you represent or another authorised user;
- from public professional sources, such as regulatory registers, company websites, Companies House, LinkedIn, fund documents and published material;
- from referrals, events and professional contacts; and
- through Wix and other website, authentication, payment, analytics, email, booking, cloud and technology providers.
If you upload or provide information about another person, you should ensure that you are authorised and have a lawful basis to do so, and that the information is relevant and not excessive.
Why we use personal information and our lawful bases
We use personal information to:
- operate, secure and improve the Infundly website, professional-access areas and digital tools;
- assess, approve, administer or restrict professional access;
- provide research content, subscriptions, licences, tools and related support;
- process supplied prompts and documents and generate user-requested research drafts;
- respond to enquiries and administer meetings, accounts, contracts, payments and invoices;
- understand use of our content and services and improve relevance, navigation and functionality;
- maintain research, business, legal, tax, accounting, security and compliance records;
- send professional research updates or information about services where permitted; and
- detect and prevent misuse, unauthorised access, scraping, fraud and unlawful activity and protect our content and intellectual property.
Depending on the activity, we rely on: -
**Contract: where processing is necessary to provide an account, subscription, licence, tool or other service you have requested, or to take pre-contract steps. **Legitimate interests: including operating a professional research business, verifying the intended audience, responding to business enquiries, improving and securing services, understanding professional use, protecting content and maintaining appropriate records—provided those interests are not overridden by your rights.
**Consent: where required, including for certain cookies or electronic marketing. You may withdraw consent at any time.
**Legal obligation: where processing is needed to meet an applicable legal, tax or accounting requirement.
**Legal claims: where necessary to establish, exercise or defend legal rights.
Where our contract is with your organisation rather than with you personally, we will generally rely on legitimate interests to process your business contact, account and service-use information.
Professional-only access
Some content and services are limited to professional investment decision-makers, approved members or regulated firms. We may use organisation, role, regulatory and professional-responsibility information to assess access and protect the intended professional context of our content.
This screening is not a credit check and is not intended to determine an individual’s suitability for an investment. If access is refused or restricted, you may contact us to ask for a review.
Uploaded documents and AI-assisted tools
Some Infundly tools may use automated and artificial-intelligence technology to extract, organise, summarise or draft content from material supplied by a user. This may involve sending relevant prompts, document extracts and technical information to contracted technology providers, which may include OpenAI, solely to provide and support the requested functionality.
Tool outputs are research-structuring aids for professional review. They are not personal financial advice or recommendations, and Infundly does not use them to make decisions that produce legal or similarly significant effects about individuals. Users remain responsible for checking source material, reviewing outputs and removing unnecessary personal or confidential information before upload.
We apply access and provider controls intended to protect uploaded content. We do not sell uploaded information. Provider processing, retention and any international access are governed by applicable contracts, settings and lawful transfer arrangements.
**Operational confirmation required before publication: state the actual retention period for uploaded files and generated outputs, for example: “Uploaded files are deleted immediately, while generated drafts and essential service logs are not presently retained.”
Marketing and communications
We may send newsletters, research alerts, publication updates, event invitations or service information where you have requested them, consented or where we have a lawful legitimate interest in contacting a relevant business contact. Electronic marketing is also handled in accordance with the Privacy and Electronic Communications Regulations.
You may unsubscribe at any time using the link in an email or by contacting privacy@infundly.co.uk. We may still send necessary account, transaction, legal, security or service messages.
Cookies and analytics
We use necessary cookies to operate accounts, protect the website and provide requested functionality. With your consent where required, we may use analytics and preference cookies to understand website use and improve content and services. Further information and controls should be provided in our Cookie Policy and cookie banner.
Sharing personal information
We do not sell personal information. Where necessary, we may share it with:
- website, hosting, authentication and infrastructure providers, including Wix;
- AI-processing and document-processing providers used to operate requested tools;
- email, newsletter, CRM, analytics, booking, video-conferencing and communication providers;
- cloud-storage, IT and cyber-security providers;
- payment, invoicing, accounting and business-administration providers;
- professional advisers, including legal, tax, insurance, compliance and accounting advisers;
- another party involved in a proposed restructuring, investment, sale or transfer of the business, subject to appropriate safeguards; and
- regulators, courts, law-enforcement bodies and public authorities where required by law or necessary to protect legal rights.
Service providers acting for us are required to protect information and use it only for authorised purposes. Asset managers or other organisations featured in our research do not receive subscriber or user-identifying information merely because a user views their research, unless we clearly explain otherwise and have a lawful basis.
International transfers
Some providers may store or access personal information outside the UK. Where a restricted transfer occurs, we use a lawful mechanism as appropriate, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another permitted safeguard. Information about relevant safeguards may be requested at privacy@infundly.co.uk.
Retention
We retain personal information only for as long as reasonably necessary. In general:
- unsuccessful enquiry and prospect records are normally kept for up to **24 months** after the last meaningful contact;
- account and professional-verification records are kept while an account is active and normally for up to **24 months** after closure, unless needed for security, contractual or legal purposes;
- subscription, licence, contract, invoice and material business records are normally kept for **six years** after the relationship or relevant financial period;
- marketing information is kept until you opt out or it is no longer reasonably useful, with a minimal suppression record retained to respect an opt-out;
- uploaded documents, generated drafts and tool logs are kept in accordance with the specific period stated in section 7 once confirmed; and
- website, analytics and security records are kept in line with relevant provider settings and operational needs.
We may delete, anonymise or retain information for longer where necessary to resolve a dispute, investigate misuse, protect legal rights or comply with law.
Security
We use appropriate technical and organisational measures designed to protect personal information, including access controls, password protection, secure service providers, limited permissions, encryption where appropriate, and monitoring intended to detect misuse. No website, email or online tool can be guaranteed completely secure. Users are responsible for protecting their login credentials.
Your rights
Subject to applicable law and exemptions, you may have rights to:
- obtain access to your personal information; - correct inaccurate or incomplete information;
- request erasure or restriction in certain circumstances;
- object to processing based on legitimate interests;
- object at any time to direct marketing;
- receive certain information in a portable format; and
- withdraw consent where we rely on it.
You may exercise a right by emailing privacy@infundly.co.uk. We may need to verify your identity. We normally respond within one month, although the law permits an extension in some circumstances.
Children and retail enquiries
Infundly is not directed at children, and we do not knowingly collect their personal information. If you believe a child has supplied information, please contact us.
If a retail investor contacts us seeking personal financial advice, we may use limited contact and enquiry information to respond, explain the limits of our service and maintain an appropriate record.
Third-party websites
Our website may link to third-party websites, publications, tools or resources. Those organisations control their own privacy practices, and their notices should be read separately.
Complaints
Please contact us first at privacy@infundly.co.uk if you have concerns so that we can try to resolve them. You also have the right to complain to the Information Commissioner’s Office:
**Information Commissioner’s Office**
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Website: https://ico.org.uk/
Changes to this notice
We may update this notice to reflect changes in our activities, tools, suppliers or legal obligations. The current version will be published on www.infundly.co.uk with its effective date. We will highlight material changes where appropriate.
Contact us
Questions, requests and complaints about personal information should be sent to:
Email: privacy@infundly.co.uk
Post: Infundly Limited, Hoxton Mix, 3rd Floor, 86–90 Paul Street, London, EC2A 4NE