Privacy Policy

Effective Date: November 11th, 2025

Last Updated: March 27, 2026

1. Introduction

Engage Capital Ltd trading as Engage Venture (““Engage Venture”, “we”, “us”, “our”) is committed to protecting your privacy and ensuring your personal data is handled in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Privacy Policy explains how we collect, use, store, and protect your personal information when you visit our website (www.engageventure.com) or interact with our business.

2. Who We Are

Data Protection Officer Contact:

Email:

For any other enquiries:

Email:

3. Information We Collect

We may collect and process the following categories of personal data:

3.1 Information You Provide to Us

1. Contact Information: Name, email address, telephone number, company name, job title
2. Communication Data: Information contained in any communications you send to us via email, contact forms, or other channels
3. Business Information: Information about your business, investment interests, or proposals if you approach us for funding
4. Event Information: Registration details if you attend any events or webinars we host

3.2 Information We Collect Automatically

When you visit our website, we may automatically collect:

• Technical Data: IP address, browser type and version, time zone setting, browser plug-in types, operating system and platform
• Usage Data: Information about how you use our website, including pages visited, time spent on pages, links clicked
• Device Information: Device type, unique device identifiers, mobile network information

This information is collected through cookies and similar tracking technologies. Please see our Cookie Policy for more details.

4. How We Use Your Information

We use your personal data for the following purposes:

4.1 Legal Bases for Processing

We process your personal data on the following legal bases:

• Legitimate Interests: To operate our website, respond to enquiries, and conduct our business operations
• Contractual Necessity: To evaluate investment opportunities and communicate with portfolio companies and prospective investments
• Legal Obligation: To comply with legal and regulatory requirements, including anti-money laundering checks and financial regulations
• Consent: Where you have given explicit consent for specific processing activities, such as marketing communications

4.2 Specific Purposes

1. To respond to your enquiries and provide information you request
2. To evaluate investment proposals and conduct due diligence
3. To communicate with portfolio companies and manage investments
4. To improve our website and user experience
5. To send marketing communications (only with your consent)
6. To comply with legal and regulatory obligations
7. To protect our business interests and legal rights
8. To analyse website traffic and usage patterns

5. Sharing Your Information

We may share your personal data with the following categories of recipients:

• Professional Advisors: Legal advisors, accountants, auditors, and financial consultants who assist with due diligence and investment activities
• Service Providers: Technology service providers, website hosting providers, email service providers, and CRM systems (all subject to appropriate data processing agreements)
• Business Partners: Co-investors or syndicate partners where relevant to investment opportunities (only with your knowledge and in connection with your proposal)
• Regulatory Authorities: Government bodies, law enforcement, and regulatory authorities when required by law

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

6. International Transfers

We primarily store and process data within the United Kingdom. If we transfer your personal data outside the UK or European Economic Area (EEA), we will ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the UK Information Commissioner’s Office
• Transfers to countries with adequacy decisions
• Other legally approved transfer mechanisms

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

• General Enquiries: 2 years from last contact
• Investment Proposals (Unsuccessful): 3 years from decision date
• Investment Proposals (Successful): Duration of investment plus 7 years (to meet financial and legal record-keeping requirements)
• Website Analytics Data: 26 months
• Marketing Consent Records: Duration of consent plus 3 years

After these periods, we will securely delete or anonymise your personal data unless we are required to retain it for legal, regulatory, or legitimate business purposes.

8. Your Rights

Under UK data protection law, you have the following rights:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate or incomplete personal data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request that we limit how we use your personal data
• Right to Data Portability: Request transfer of your personal data to another organisation or to you
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Rights Related to Automated Decision-Making: We do not use automated decision-making or profiling

To exercise any of these rights, please contact our Data Protection Officer at .

ICO registration number: ZC142267

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Information Commissioner’s Office

Wycliffe House, Water Lane

Wilmslow, Cheshire, SK9 5AF

Tel: 0303 123 1113

Website: www.ico.org.uk

9. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication requirements
• Staff training on data protection and security
• Secure data backup procedures

10. Children’s Privacy

Our website and services are not directed at children under 16 years of age. We do not knowingly collect personal data from children. If you believe we have inadvertently collected information from a child, please contact us immediately at .

11. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The “Last Updated” date at the top of this policy indicates when it was last revised. We encourage you to review this policy periodically.

Significant changes will be communicated through prominent notices on our website or by email where appropriate.

13. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

Email: (Data Protection Officer)

Email: (General Enquiries)