Privacy Policy for Sustainable Wealth Group Limited

1. Introduction

Sustainable Wealth Group Limited ("Sustainable Wealth Group", "we", "us", or "our") is committed to safeguarding the privacy and confidentiality of personal and financial information we collect from individuals, family offices, and corporate entities in the course of our operations. We operate in compliance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and in accordance with best practices outlined by the Financial Conduct Authority (FCA) where applicable, including the FCA's Conduct of Business Sourcebook (COBS) and the Financial Services and Markets Act 2000 (FSMA).

Please read this policy carefully to understand how we collect, use, protect and share your personal data.

2. Who We Are

Sustainable Wealth Group Limited is a private company registered in England and Wales, providing marketing, administration and technology services to corporate clients in the venture capital and private equity sectors. Sustainable Wealth Group is not FCA regulated and does not provide financial advice, recommendations or portfolio management services.

We work in partnership with FCA-regulated SPV hosting platforms, which act as appointed representatives or hold relevant permissions to manage client money, custody assets and handle investor applications. Sustainable Wealth Group and its affiliates do not hold or manage client funds and act strictly within the permissions allowed under FSMA and COBS.

3. What Data We Collect

We collect the following types of personal and financial data:

• Full name, email address, phone number
• Employment and professional background
• Net asset value and income declarations (for investor categorisation purposes)
• Investment history in unlisted companies
• IP address and digital identifiers (for website interactions)
• Company or entity name (for corporate prospects)
• Any supporting documents voluntarily provided (such as self-certification forms)

This information is typically collected through:

• Online forms (e.g., Typeform)
• Website and event registrations
• Email, phone or in-person interactions

4. Purpose and Legal Basis for Processing

We process your data based on the following lawful grounds:

• Consent: Where you have actively given us permission to process your data (e.g., opting in to receive our EIS guide)
• Legitimate Interests: For the purpose of marketing our services to appropriate professional or high-net-worth audiences
• Legal Obligation: To comply with applicable laws and demonstrate adherence to investor categorisation obligations under COBS

We use your data to:

• Determine whether you meet the criteria for high-net-worth or sophisticated investor categories
• Share information, brochures or updates about our services
• Administer event registrations or requests for further information
• Assign contacts in our CRM (HubSpot) for follow-up by investment consultants
• Facilitate introductions to FCA-regulated partners where applicable

5. Sharing Your Data

We may share your data with the following categories of third parties:

• FCA-regulated SPV platforms and investment managers
• Our approved third-party service providers (CRM, form providers, email platforms)
• Legal, regulatory or compliance professionals (where required)

We will never sell your personal data to third parties.

6. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes we collected it for, including satisfying legal, regulatory, tax, and reporting requirements. If you request deletion of your data, we will comply unless retention is required by law.

7. Your Rights

Under data protection law, you have the following rights:

• Access to your data
• Correction of inaccurate data
• Deletion of your data ("right to be forgotten")
• Objection to or restriction of processing
• Data portability

Please contact us at dataprotection@sustainablewealthgroup.com to exercise your rights.

8. International Data Transfers

Where your data is transferred outside the UK or European Economic Area (EEA), we ensure appropriate safeguards are in place such as standard contractual clauses approved by the UK Information Commissioner's Office (ICO).

9. Data Security

We employ a range of security measures including encryption, access control and secure hosting environments to protect your personal and financial data.

10. Updates to This Policy

We may update this Privacy Policy from time to time. The most recent version will always be available on our website and the effective date will be updated accordingly.

11. Contact

If you have any questions or concerns about this policy or how we handle your data, please contact:

Data Protection Officer
Sustainable Wealth Group Limited
7 Harp Lane, London, EC3R 6DP
dataprotection@sustainablewealthgroup.com

Disclaimer: Sustainable Wealth Group is not authorised or regulated by the Financial Conduct Authority. All investments introduced or facilitated by our network are managed by FCA-regulated third parties. Investors are strongly encouraged to seek independent financial advice. Investing in early-stage companies is high-risk and capital is at risk.