Privacy Policy

1. Who We Are

Malanta Ltd ("Malanta", "we", "us", or "our") is a venture capital investment firm incorporated in England and Wales with its registered office at 25 Old Broad Street, London, EC2N 1HQ, United Kingdom. We are registered with Companies House and operate as a financial services business subject to applicable UK financial regulation.

This Privacy Policy explains how Malanta Ltd collects, uses, discloses, and safeguards personal data in connection with: (a) visits to and use of our website at malantaltd.com (the "Website"); (b) business enquiries, investment discussions, and related communications; (c) our investor relations and limited partner communications; and (d) any other interactions with Malanta Ltd where personal data is processed.

Malanta Ltd acts as a data controller for the personal data described in this Privacy Policy. This means we determine the purposes and means by which your personal data is processed.

If you have questions about this Privacy Policy or wish to exercise any of your data protection rights, please contact us at privacy@malantaltd.com or at the registered address above.

2. Data We Collect

We collect the following categories of personal data:

2.1 Data You Provide Directly

• Contact and identification data: Name, job title, organisation name, professional email address, telephone number, and business address, provided when you submit our contact form, send us an email, or communicate with us by telephone.
• Investment and business enquiry data: Information contained in pitch decks, business plans, financial projections, and other materials you share with us in connection with a potential investment relationship.
• LP and investor relations data: Know-Your-Customer documentation, identity verification materials, and financial information provided by existing or prospective limited partners in connection with fund administration and regulatory compliance obligations.
• Correspondence data: The content of any written or verbal communications you have with Malanta Ltd, including emails, letters, and records of telephone conversations.

2.2 Data We Collect Automatically

• Technical data: IP address, browser type and version, operating system, device identifiers, referring URL, and pages visited on our Website.
• Usage data: Information about how you interact with our Website, including pages viewed, time spent on pages, links clicked, and navigation paths.
• Cookie data: Data collected via cookies and similar tracking technologies as described in Section 9 of this Policy and in our Cookie Policy.

2.3 Data We Obtain from Third Parties

• Publicly available data: Information about you that is publicly available through professional directories, corporate registries, financial databases, and news sources, which we may use for due diligence and background research purposes.
• Referral data: Information provided to us about you by mutual contacts, co-investors, or advisors who introduce you to Malanta Ltd.

3. How We Use Your Data

We use the personal data we collect for the following purposes:

• Responding to enquiries: To respond to contact form submissions, email enquiries, and telephone enquiries from founders, co-investors, limited partners, and other parties.
• Investment evaluation: To conduct initial assessment of investment opportunities, including review of materials submitted by founders and management teams of companies seeking investment from Malanta Ltd.
• Due diligence: To conduct background research, financial analysis, and reference checks as part of our investment decision-making process for opportunities under active consideration.
• Fund administration: To satisfy our legal and regulatory obligations in connection with fund administration, including anti-money laundering checks, KYC verification, and reporting obligations to regulatory authorities.
• Portfolio company support: To connect founders and management teams of portfolio companies with relevant contacts, advisors, and resources within our network.
• Investor relations: To communicate with existing and prospective limited partners about fund performance, portfolio developments, and investment opportunities.
• Website analytics: To understand how visitors use our Website, identify technical issues, and improve the content and functionality of our digital presence.
• Legal compliance: To comply with our legal and regulatory obligations under applicable law, including financial services regulation, anti-money laundering legislation, and data protection law.

4. Legal Basis for Processing

Under the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (EU GDPR), we are required to identify a lawful basis for processing personal data. We rely on the following lawful bases:

• Legitimate interests (Article 6(1)(f)): We process contact and professional data for the purpose of conducting our investment business, evaluating potential investments, maintaining business relationships, and operating our Website. We have assessed that our legitimate interests in conducting these activities are not overridden by your interests or fundamental rights.
• Contractual necessity (Article 6(1)(b)): We process LP and investor data as necessary to administer our contractual relationships with limited partners and to perform our obligations under fund administration agreements.
• Legal obligation (Article 6(1)(c)): We process certain data as required by applicable law, including anti-money laundering and counter-terrorism financing regulations, financial services reporting obligations, and UK Companies House requirements.
• Consent (Article 6(1)(a)): Where we rely on consent as our lawful basis for processing (for example, for optional newsletter communications), we will obtain your clear and affirmative consent prior to processing. You may withdraw consent at any time by contacting us at privacy@malantaltd.com.

5. Data Sharing

We do not sell personal data. We may share personal data in the following circumstances:

• Service providers: We engage third-party service providers who process personal data on our behalf for purposes including IT infrastructure, cloud storage, legal services, accounting, compliance, and fund administration. These providers are bound by contractual data processing agreements that restrict their use of personal data to the purposes for which it was shared.
• Co-investors and advisors: In the context of investment transactions, we may share relevant information about companies or individuals with co-investors and external advisors who are bound by confidentiality obligations.
• Regulatory and law enforcement authorities: Where required by law or in response to lawful requests from public authorities, including financial regulators, tax authorities, and law enforcement agencies.
• Professional advisers: Our legal counsel, auditors, and other professional advisers who are subject to professional confidentiality obligations.

6. International Transfers

Malanta Ltd operates across multiple jurisdictions and may transfer personal data to recipients located outside the United Kingdom and European Economic Area. Where such transfers occur, we ensure that appropriate safeguards are in place, including:

• Transfer to countries that the UK government or European Commission has determined provide an adequate level of data protection;
• Use of the International Data Transfer Agreement (IDTA) approved by the UK Information Commissioner's Office, or EU Standard Contractual Clauses;
• Other appropriate transfer mechanisms as permitted by applicable data protection law.

7. Data Retention

We retain personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to our legal and regulatory obligations. Our general retention periods are as follows:

• Contact enquiries: Retained for two years from the date of last meaningful contact, after which data is deleted unless a business relationship has developed that requires continued retention.
• Investment evaluation records: Retained for five years from the date of the most recent evaluation activity, reflecting the time periods relevant to investment decision-making and potential liability.
• LP and fund administration records: Retained for a minimum of seven years following the termination of the relevant fund, as required by UK financial regulation and anti-money laundering legislation.
• Legal correspondence: Retained for six years following the resolution of any matter to which the correspondence relates, in accordance with the UK Limitation Act 1980.
• Website analytics data: Retained for 26 months from the date of collection, after which it is aggregated and anonymised.

8. Your Rights

Under the UK GDPR and EU GDPR, you have the following rights with respect to your personal data:

• Right of access: You have the right to request a copy of the personal data we hold about you, together with information about how it is being processed.
• Right to rectification: You have the right to request that we correct any inaccurate personal data we hold about you, and to complete any incomplete personal data.
• Right to erasure: In certain circumstances, you have the right to request that we delete personal data we hold about you. This right is not absolute and may be overridden by our legal obligations.
• Right to restrict processing: In certain circumstances, you have the right to request that we restrict our processing of your personal data.
• Right to data portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to object: You have the right to object to processing of your personal data where we rely on legitimate interests as our lawful basis, or where data is processed for direct marketing purposes.
• Rights related to automated decision-making: You have the right not to be subject to decisions made solely by automated processing where those decisions have significant effects on you.

To exercise any of these rights, please contact us at privacy@malantaltd.com. We will respond within 30 days of receiving your request. You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk, or with the relevant supervisory authority in your country of residence.

9. Cookies

Our Website uses cookies and similar tracking technologies. A cookie is a small text file stored on your device that allows us to recognise your browser across multiple sessions. We use the following categories of cookies:

• Strictly necessary cookies: Required for the Website to function and cannot be disabled. These include cookies that remember your cookie consent preferences.
• Analytics cookies: Used to collect anonymous statistical information about how visitors use our Website, which we use to improve performance and content. These cookies are only set with your consent.

You can manage your cookie preferences at any time using our cookie consent banner. For more detailed information about the specific cookies we use, please see our Cookie Policy.

10. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, alteration, or disclosure. Our security measures include encrypted data storage and transmission, access controls restricting data access to authorised personnel, regular security reviews, and staff training on data protection obligations. While we take reasonable steps to protect your personal data, no method of electronic transmission or storage is entirely secure. If you become aware of any potential security vulnerability, please notify us immediately at privacy@malantaltd.com.

11. Children's Privacy

Our Website and services are intended for use by adults aged 18 and over in a professional capacity. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child, we will take prompt steps to delete it. If you believe we may have collected personal data from a child, please contact us at privacy@malantaltd.com.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our processing practices, legal requirements, or regulatory guidance. When we make material changes to this Policy, we will update the "Last updated" date at the top of this page. We encourage you to review this Policy periodically. Your continued use of our Website following any changes constitutes your acknowledgement of the updated Policy.

13. Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or our processing of your personal data, please contact:

Data Protection Contact
Malanta Ltd
25 Old Broad Street
London, EC2N 1HQ
United Kingdom
Email: privacy@malantaltd.com
Telephone: +44 (0) 20 7946 0847

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. The ICO can be contacted at ico.org.uk or by telephone on 0303 123 1113.