Privacy

Last updated September 10, 2026

This policy explains what personal information Signals at Scale Ltd. (“Signals at Scale”, “we” or “us”) collects about you, why we collect it, who we share it with, how we protect it, and the choices you can make about how we use it.

It applies to anyone who deals with us — as an investor, as a stakeholder, or as a member of the public. It covers our websites, the social media accounts we sponsor, and any other online activity we own where personal information is handled.

Unless the law in your country requires us to ask for your express consent, using our platforms means you agree to us collecting and using your personal information as described here. If you would rather not give us your information, we will usually not be able to send you information about Signals at Scale.

This policy sits on top of data protection law; it does not replace it. If anything in it conflicts with the data protection laws and regulations that apply to you, those laws and regulations take priority. We may change this policy at any time. The current version is published on our website, and you can also request a copy by emailing us at the address on our Contacts page.

We value the personal information you trust us with, and we are committed to handling it fairly, openly and securely. We collect personal information only by fair, lawful and transparent means, and we limit what we collect to what is directly relevant and necessary for the purposes described below. We use it only for those specified, explicit and legitimate purposes, and never in a way that is incompatible with them. We take care to keep it accurate and up to date, and we do not keep it for longer than those purposes require.

We put appropriate technical and organisational measures in place to keep it secure, matched to the risks involved and to the nature of the information being protected; those measures guard against unauthorised disclosure or access, accidental or unlawful destruction, accidental loss, alteration and any other unlawful handling. We handle your information in line with your privacy rights, including your rights to see it and to have it corrected. Where personal information is transferred outside the EU/EEA, we make sure it is adequately protected. Any access to, or transfer of, personal information to third parties is carried out in line with the applicable laws and regulations and under suitable contractual safeguards. And where we send you promotional material or place cookies on your device, we do so in accordance with the applicable laws.

1. What we collect, and where it comes from

We collect information directly from you — for example when you enter into a contract with us, subscribe to one of our newsletters, call or email us, give us information directly in some other way, or interact with us on social media. Depending on how and why you deal with us, what you give us may include:

  • who you are: your name, title, home and work address, previous addresses, home and business telephone numbers, email address and nationality;
  • your personal characteristics: age, gender, date of birth, place of birth, marital status and nationality;
  • your occupation;
  • proof of identity, where we need to verify who you are: reference numbers we have assigned to you, identification issued by public services, an identity card, passport or driving licence number, or a copy of an identity document such as a passport, driving licence or comparable document. We use this only to verify your identity for the purpose it was requested for;
  • online identifiers, when you deal with us through online channels such as our website and in line with our cookie policy: IP addresses, cookies and the times you connect;
  • location data, for travel services only: GSM and GPS data;
  • housing information, when you receive or apply for investments. This is handled under local banking legislation and is not shared with any other Signals at Scale entity. It covers the address of the property, the type of housing, whether you own or rent it, how long you have lived there, rent and charges, the classification of the property, valuation details and the names of key holders;
  • photographs and film, taken at special events such as new initiatives and only with your permission: films, photographs, video recordings and digital photos.

We may obtain the same categories of personal information about you from third parties. These include our network of authorised third parties, carefully selected business partners who provide services on our behalf, and any other third party who may lawfully pass information about you to us.

We may also collect certain information by automated means — such as cookies, log files or web beacons — when you visit our websites, digital applications and services. We use cookies on our websites. For more about the cookies we use and how to avoid them, please see the privacy statement on our website.

2. Why we use it

We may use your personal information to:

  • answer your questions or respond to your requests;
  • organise events, seminars and similar activities that you take part in;
  • send you our newsletters, if you have subscribed to one;
  • help us assess an investment opportunity;
  • contact current or potential donors, and potential limited partners in current programmes or in future Signals at Scale funds;
  • send you information about Signals at Scale, and other content we think may interest you, by email, post, telephone, social media or any other contact channel you have given us;
  • – advertise and market our business and activities, study what our audiences prefer, and carry out public relations connected with our business and activities;
  • keep the accounts for any business or activity we carry out, and keep records of purchases, sales and transactions;
  • protect our physical and intellectual property, our economic and financial interests, and the integrity of our directors, employees, investees and stakeholders, by any method, system or process we use for that purpose;
  • support, maintain and develop our systems;
  • meet our legal obligations, and establish, exercise or defend legal claims;
  • carry out financial and statistical research: collecting and using personal information for statistical surveys, or as needed to reach statistical results, analysing earlier events, and establishing patterns and rules of conduct;
  • report back to our donors and partners, and to potential limited partners in a Signals at Scale fund;
  • prepare for and carry out a merger, take-over, transfer of an undertaking, transfer of assets, or any other type of corporate transaction;
  • and for any other purpose we describe and communicate to you before we use your information for it.

We only use your personal information to the extent these purposes require, together with anything else the applicable data protection laws and regulations specifically permit. Where those laws and regulations require it, we notify the relevant authorities that we handle personal information.

3. Who we share it with

For the purposes above, we may disclose your personal information to authorised staff members of Signals at Scale, and to our corporate affiliates and subsidiary companies. We may also share it with trusted business partners: companies that may use it to provide you with the services or information you asked for, or to send you marketing material where you have agreed to receive it. We ask these companies to act in line with the applicable laws and with this policy at all times, and to treat the confidentiality of your information with great care.

We may share your personal information with other third parties where the law requires it, or where it is necessary to protect Signals at Scale: to comply with the law, regulatory requests, court orders, subpoenas or legal process; to verify or enforce compliance with our policies and agreements; and to protect the rights, property or safety of Signals at Scale and its customers. We may also share it with third parties you consent to, or ask us to share it with, and with any other third party we tell you about before we do so.

Your personal information may be transferred to any of these recipients. Some of them are outside the EU/EEA, and your information may be handled by us or by them in any country in the world. The countries it is transferred to may not offer an adequate level of protection. Where we transfer personal information to a country that does not offer the same level of protection as the EU/EEA, we put appropriate measures in place to make sure it is still adequately protected.

4. How we protect it, and how long we keep it

We put appropriate technical and organisational security measures in place. They guard against unlawful or unauthorised use of your personal information, and against its misuse, destruction, disclosure, acquisition, accidental loss or damage. Where a third party handles personal information on our behalf, we only allow it if they agree to comply with those same measures.

Keeping information secure means guaranteeing three things: confidentiality, so that your information is not disclosed to third parties; integrity, so that it is not changed by anyone who is not authorised to change it; and availability, so that authorised people can reach it when it is needed.

Our procedures cover the organisation and its people, through disciplinary measures where our rules are not followed and confidentiality clauses in contracts; our buildings and environment, through preventing, detecting and dealing with physical dangers such as fire and water damage, and through maintaining a backup system; our networks, through access control and an authentication system; access itself, which we record, track and analyse; and oversight, through monitoring, review and maintenance. We have appointed a Data Compliance Officer to help make sure personal information is handled lawfully.

We retain your personal information in a way that is consistent with the applicable data protection laws and regulations. We keep it only for as long as we need it to comply with those laws and regulations, or for the purposes set out above — whichever requires us to keep it longer. If you would like guidance on how long a particular kind of information is likely to be kept before it is destroyed, email us at the address on our Contacts page.

It matters to us that our records about you are accurate and up to date. Please tell us about any change or any mistake as soon as you can, using the same address. We will take reasonable steps to have anything inaccurate or out of date deleted, destroyed or corrected.

5. Your rights and your choices

We want to be as transparent as we can, so that you can make meaningful choices about how we use your information.

You have the right to see what we hold. You can contact us by post or email at any time to find out what personal information we hold about you and where it came from. If any of it is inaccurate or incomplete, you can ask us to correct or complete it. You can also ask us to erase personal information we hold about you, although there are exceptions — for example where we need to keep it as proof of a transaction, or where the law requires us to keep it.

You can choose how we contact you: through which channel (email, post, social media and so on), for which purpose, and how often. You can do this by adjusting the privacy settings on the relevant device, by updating your user or account profile, or by following the unsubscribe instructions in any message we send you. By default, if you do not tell us otherwise, you will receive our promotional communications.

You can object to us using your personal information for direct marketing, and to us sharing it with third parties for the same purpose. If you would prefer, you can simply tell us which channel you would like us to use and how often.

We will only use your personal information to send you marketing material by electronic means, such as email, if you have given us your consent in advance. You can withdraw that consent at any time, either by following the unsubscribe instructions included in the marketing material, or by emailing us at the address on our Contacts page.

6. How to contact us

For any privacy issue, question or complaint about this policy, or to exercise your right of access or correction under it, contact Signals at Scale at the email address on the Contacts page of our website. Our Data Compliance Officer can be reached at the same address. The Data Compliance Officer is our contact point for data compliance matters, but does not hold the role of, or carry the obligations of, a Data Protection Officer under the GDP Regulation 2016.

The formal terms used in this policy

This policy uses everyday language. The terms below have specific meanings under data protection law, and are set out here so the legal position is clear.

Data Controller: the organisation that determines the purposes for which, and the manner in which, personal data is processed. For the purposes of this policy, the Data Controller is Signals at Scale Ltd.

Data Processor: the individual or organisation that processes personal data on behalf of the Data Controller.

Data Compliance Officer, or DCO: the data compliance officer nominated by Signals at Scale to be the contact point for data compliance, but without the obligations of a Data Protection Officer applicable under the GDP Regulation 2016.

Data Subject: any individual about whom Signals at Scale holds personal data. In this policy, that is you.

EEA: the European Economic Area, made up of the EU Member States plus Iceland, Norway and Liechtenstein.

Personal Data: any data relating to a living individual which allows that individual to be identified, whether from the data alone or in combination with other information. Section 1 describes the personal data Signals at Scale processes. This policy usually calls it personal information.

Processing: any operation or set of operations performed on personal data, such as collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure and destruction. This policy usually says use or handle.

Sensitive Personal Data: personal data revealing, among other things, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and data concerning health or sex life. Special provisions apply to the processing of sensitive data.

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