1. Who we are
This notice explains how UNTITLED collects and uses personal data about investors, portfolio company contacts, advisers, counterparties, job and partnership candidates, and visitors to this website.
- UNTITLED Advisors LLP is the controller for most processing described here. It is a limited liability partnership registered in England and Wales (OC437270), registered office 14-16 Bruton Place, London W1J 6LX. ICO registration number: ZB154986.
- UNTITLED Investors ICC and its incorporated cells, established in Jersey, are controllers for investor and investment data they hold. Their processing is subject to the Data Protection (Jersey) Law 2018.
- Where UNTITLED Advisors LLP acts on behalf of UNTITLED Investors ICC, it may do so as processor or joint controller. UNTITLED Investors ICC are UNTITLED Advisors LLP are joint controllers for investor records and investment data and UNTITLED Advisors LLP is processor for UNTITLED Investors ICC for particular fund administration and services functions. Where it matters to your request, we will tell you which entity holds your data.
We have not appointed a statutory Data Protection Officer. Questions and requests go to privacy@untitled.co or by post to the Data Protection Lead, UNTITLED Advisors LLP, 14-16 Bruton Place, London W1J 6LX.
2. What we collect and where it comes from
| Category | Examples (non-exhaustive) |
|---|---|
| Identity and contact | Name, title, employer, email, phone, address |
| Due diligence and KYC | Passport or ID copies, proof of address, source of wealth and funds, PEP and sanctions screening results, tax residency |
| Professional | CV, track record, references, right to work and general applicant checks, role history, employment verification, directorships |
| Investment and financial | Commitments, holdings, distributions, bank details for payments, loan and investment terms |
| Communications | Emails, messages, meeting notes, call records, documents exchanged |
| Website and technical | IP address, browser type, pages visited (see cookies below) |
We collect data directly from you, and from third parties: your employer or firm, introducers and co-investors, referees, placement agents, fund administrators, public registers (Companies House, FCA Register, court records), screening and background-check providers, and press or professional networking sites.
We do not generally seek to collect special category personal data or information about criminal convictions and offences. However, such information may arise in connection with KYC, sanctions, background checks, legal or regulatory compliance, or information provided to us by candidates and other individuals. Where we process such information, we do so only where permitted by applicable data protection law, including where necessary to comply with legal or regulatory obligations, establish, exercise or defend legal claims, or where another applicable condition permits the processing.
Information you need to provide. In some circumstances, we need certain personal data to comply with legal or regulatory requirements, or to enter into or perform a contract with you or an organisation you represent. For example, we may require identification and source of funds information to complete KYC and anti-money laundering checks. If you do not provide information we need, we may be unable to onboard you, accept an investment, complete a transaction or enter into the relevant relationship.
Cookies. This website uses only cookies strictly necessary for it to function.
3. Why we use it and our lawful basis
| Purpose | Lawful basis |
|---|---|
| Onboarding investors and counterparties; anti-money laundering, sanctions and tax checks (FATCA, CRS) | Legal obligation; legitimate interests |
| Administering investments, loans, distributions and reporting | Contract; legitimate interests |
| Sourcing, assessing and monitoring investments, including diligence on founders and management | Legitimate interests |
| Assessing candidates for employment, membership, partnership or advisory roles, including references | Legitimate interests; steps before entering a contract |
| Managing relationships and sending updates you have asked for or would reasonably expect | Legitimate interests; consent where required for marketing |
| Regulatory compliance, record-keeping and responding to regulators | Legal obligation |
| Establishing, exercising or defending legal claims | Legitimate interests |
| Running and securing our website and IT systems | Legitimate interests |
Our legitimate interests are running a permanent capital investment platform, managing risk, and protecting our business, investors and portfolio companies. We weigh these against your rights and do not rely on them where your interests override ours.
Where we rely on consent, you can withdraw it at any time by emailing privacy@untitled.co.
We do not make decisions about you based solely on automated processing, including profiling, that produce legal or similarly significant effects.
4. Who we share it with
We share personal data only where needed for the purposes above, with:
- UNTITLED group entities, including UNTITLED Investors ICC and its cells, and our principal firm Robert Quinn Advisory LLP for regulatory oversight
- Fund administrators, custodians, banks and payment providers
- Legal, tax, accounting and other professional advisers
- Co-investors, portfolio companies and transaction counterparties, where relevant to a deal
- KYC, screening and background-check providers
- IT, cloud, email, CRM and document-management providers
- Regulators, tax authorities, courts, law enforcement and others where the law requires or permits
We do not sell personal data.
International transfers. Some recipients are outside the UK, including in Jersey, the EEA, Switzerland and the United States. Jersey, the EEA and Switzerland benefit from UK adequacy regulations. For US transfers we rely on the UK Extension to the EU-US Data Privacy Framework where the recipient is certified. For other transfers we use the ICO's International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. You can ask us for a copy of the relevant safeguards.
5. How long we keep it
We keep personal data only as long as needed for the purpose it was collected, then delete or anonymise it.
| Record | Retention |
|---|---|
| KYC and anti-money laundering records | Generally 5 years following the end of the relevant business relationship or completion of the relevant transaction, subject to applicable legal or regulatory requirements |
| Investor, investment and transaction records | Life of the investment plus 7 years, longer if a claim is made or reasonably expected |
| Contracts, loans and deeds | 6 years after expiry (12 years for deeds), longer if a claim is made or reasonably expected |
| Unsuccessful candidates and prospective partners | 12 months after the decision, longer if a claim is made or reasonably expected |
| General correspondence and relationship contacts | 3 years after last meaningful contact, longer if a claim is made or reasonably expected |
| Website logs | 12 months |
We may keep data longer where a legal hold applies, a regulator requires it, or it is needed to establish, exercise or defend legal claims.
6. Your rights and how to exercise them
You have the right to:
- access a copy of your personal data (a subject access request)
- have inaccurate data corrected
- have data erased or its use restricted, in certain circumstances
- object to processing based on legitimate interests, and to direct marketing at any time
- receive data you provided to us in a portable format, where processing is by consent or contract
- withdraw consent, where we rely on it
Making a request. Email privacy@untitled.co or write to the address in section 1. Please say what information you want and, if you can, the period or subject it concerns. That helps us respond quickly.
How we respond.
- We may ask for information reasonably necessary to confirm your identity or clarify the information or processing activities to which your request relates.
- We endeavor to respond within one month. For complex or multiple requests we may extend this by up to two further months and will tell you why.
- We carry out reasonable and proportionate searches for your personal data.
- We provide a copy of your personal data, with enough context to make it intelligible. This may be an extract rather than whole documents, and we will redact information about other people.
- We normally respond free of charge. We may charge a reasonable fee, or refuse, where a request is manifestly unfounded or excessive.
Limits. These rights are not absolute. Your rights are subject to certain exemptions and limitations under applicable data protection law, including in relation to legally privileged information and the rights and freedoms of other people.
7. Security, complaints and changes
Security. We use access controls, encryption, multi-factor authentication and vetted service providers to protect personal data. Staff and contractors access it only where their role requires.
Complaints. If you are unhappy with how we have handled your data, please contact privacy@untitled.co first. We will acknowledge your complaint as soon as is reasonably practicable and will respond without undue delay. You also have the right to complain to:
- the Information Commissioner's Office (UK): ico.org.uk, 0303 123 1113
- the Jersey Office of the Information Commissioner, for data held by UNTITLED Investors ICC: jerseyoic.org
Changes. We may update this notice. The current version is always on this page.
Last updated: September 2026.