Compliance & Legal
Privacy Policy.
How Sapphire Capital Partners LLP collects, uses, and protects your personal data in connection with the DealsFlow platform. Our commitment to data integrity and regulatory transparency.
1. Data Controller
The data controller responsible for your personal data is Sapphire Capital Partners LLP, a limited liability partnership registered in England and Wales. Sapphire Capital Partners LLP is authorised and regulated by the Financial Conduct Authority (FCA), Firm Reference Number 565716.
Registered Entity
Sapphire Capital Partners LLP · Belfast, United Kingdom
Primary Contact
info@dealsflow.co.ukDealsFlow is a product brand operated under Sapphire Capital Partners LLP. References to "DealsFlow", "we", "us", or "our" in this policy refer to Sapphire Capital Partners LLP acting through the DealsFlow platform.
2. Scope of This Policy
This Privacy Policy applies to personal data we collect and process in connection with:
Note: This policy does not apply to data processed on behalf of our fund clients where we act strictly as a data processor.
3. Personal Data We Collect
We may collect and process the following categories of data to ensure platform integrity and performance:
Contact & Identity
Full name, professional email, job title, company name, and LinkedIn profiles for authentication.
Account & Usage
Hashed credentials, activity logs, feature engagement, and session metadata.
Deal Submission
Company details, pitch materials, financial metrics, and founder biographies submitted by company representatives.
Technical Data
IP addresses, browser specifications, and referring domains used for security monitoring.
4. Legal Basis for Processing
We process personal data only where we have a lawful basis under UK GDPR and the Data Protection Act 2018:
Legitimate Interests
Operating and improving the DealsFlow platform, ensuring security, and business development.
Contract Performance
Providing the DealsFlow service to our contracted platform subscribers.
Legal Obligation
Complying with FCA regulatory requirements and AML obligations.
5. How We Use Your Personal Data
Data utilisation is strictly governed by operational necessity and regulatory compliance:
- Platform maintenance and delivery
- AI-assisted scoring and memo generation
- Routing inbound deal submissions
- Security and audit logging
- FCA and AML regulatory reporting
- Fraud prevention and detection
- Internal analytics and improvements
- Direct support and walkthroughs
Transparency Notice: We do not sell personal data to third parties, nor do we use data for automated decision-making with legal effects without human oversight.
7. Data Retention
Our retention schedules are designed to balance business necessity with data minimisation principles:
Account Data
Duration + 7 years (FCA)
Deal Data
Up to 7 years
Enquiries
2 years
Access Logs
90 days
8. Data Security
DealsFlow employs industry-leading security protocols to safeguard your sensitive information:
9. Your Rights
Under UK GDPR, you maintain comprehensive control over your personal data:
To exercise these rights, contact our data protection team at info@dealsflow.co.uk.
11. Changes to This Policy
We reserve the right to update this policy to reflect platform evolution or legal updates. Registered users will be notified of material changes via their primary account email.
12. Contact Us
For any enquiries relating to this policy or our data practices, please reach out directly:
Sapphire Capital Partners LLP
Belfast, United Kingdom