Privacy policy

1. Who is responsible

Founder Factor Management LLC, a United States company, operates the Founder Factor Portal and is the controller of the personal data held in it. In this policy “the firm” means Founder Factor Management LLC.

Questions about this policy, and every request it describes, go to investors@founderfactor.com.

2. What is held

The portal holds what the firm's work with you requires, and nothing collected in case it is useful later:

• Identity and contact details: your name, or your entity's legal name and legal form and the person who acts for it; its jurisdiction and tax residence; a registration number where one exists; the email addresses registered to your account; and a telephone number if you gave one.
• Tax information: your tax identifier, the tax forms filed for you, such as a W-8 or a W-9, and your Schedules K-1.
• Bank details: the account holder's name, the account number or IBAN, the bank, its country, the currency of the account and its routing codes, with every earlier account and the dates it was in force.
• Your investments and entitlements: your participations in each fund, your capital accounts and every entry in them, and your distributions; for an introducer or a carry beneficiary, the agreement, the shares it sets and what has been earned and paid.
• Documents filed against you: subscription agreements, introducer and carry beneficiary agreements, tax forms, Schedules K-1, distribution and payment advices, and quarterly reports. Identity and anti-money-laundering checks are carried out outside the portal, which performs none; where the firm files a record of such a check against you, it is held as a document and is not shown in your own portal.
• Sign-in records: when you signed in and by which method, the IP address and browser your session came from, and each attempt to sign in with your address. No password is held for any account, and a sign-in code is stored only in hashed form.
• Messages: the notifications and reports sent to you, the address each went to and whether it was delivered.
• The activity log, described in section 4.
• For founders of portfolio companies: the name, role, short biography, LinkedIn address and photograph the firm recorded, and the updates the company sends the firm, with the address they were sent from.

3. Why it is held, and on what basis

Each kind of data is held for a purpose. Where the law that applies to you asks for a legal basis, as it does in the European Union and the United Kingdom, the basis is one of these:

• To perform the subscription, introducer or carry beneficiary agreement you are party to: recording what you invested, what you are owed and why, paying it to the account you gave, and sending you your documents and reports.
• To meet the firm's legal obligations, in particular its tax reporting: a partnership return names its partners, and Schedules K-1 are prepared from these records.
• The firm's legitimate interest in operating the portal securely and accountably: signing you in, throttling repeated wrong codes, and keeping a record of who did what.

4. The activity log

Every change made in the portal is written to an activity log in the same transaction as the change itself: who acted, in what capacity, on which records, when and from which IP address, and for a change to an amount or a rate, its previous and its new value. Opening a document, revealing a tax identifier or a bank account number in full, and taking an export are logged too. When the firm's staff look at the portal as you see it, to answer a question, that view changes nothing and is itself logged.

The log is append-only: no entry is ever edited or deleted, and an erasure request does not remove entries from it. It is the evidence that answers an investor's, an auditor's or a tax authority's question years later, and a gap in it could not be filled afterwards.

5. Who sees it

Within the firm, staff see personal data according to their role. Tax identifiers and bank account numbers are shown masked; the full value is opened deliberately, by staff whose role allows it, and each opening is logged.

If an introducer is attached to you, that introducer sees your name, the funds you invested in, the amount you contributed and what they earned from it. Founders' details are shown to those who can see the company they founded.

Outside the firm, the firm gives its tax preparer what is needed to prepare Schedules K-1, and discloses personal data where the law requires it. Personal data is not sold, and the portal carries no advertising.

The portal relies on these service providers, each of which receives only what its service needs:

• Google Cloud hosts the portal. The database, the documents and the images are stored in its europe-west1 region, in Belgium, in the European Union.
• Google, if you choose to sign in with Google. The portal asks only for the openid, email and profile scopes. Google tells the portal your verified email address and your name; the portal uses the address to find your account, and sends Google nothing about you.
• Resend, in the United States, delivers the emails the portal sends: sign-in codes, address confirmations and notifications. It receives the address each message goes to and the message. No message carries a tax identifier, a bank account number or the contents of an identity document.
• Google Workspace (Gmail) holds the mailbox to which portfolio companies send their updates, and the portal reads that mailbox.
• Anthropic, in the United States, reads company update emails and their attachments to propose figures such as revenue and cash, and fund-level facts about portfolio companies to draft a quarterly report. It receives no investor's, introducer's or carry beneficiary's personal data. Nothing it proposes is used until a member of the firm's staff has reviewed it.
• Google Fonts. The portal's pages load their typefaces from Google's font service, so your browser requests them from Google, which receives your IP address and browser details with that request.

6. Transfers outside the European Union

The portal's data is stored in the European Union. Resend and Anthropic process what they receive in the United States, and the firm itself is a United States company. These transfers are made under the providers' data processing terms, which include the standard contractual clauses approved by the European Commission where those are required.

7. Separation between investors

You see your own record, your own investments, the documents filed against you and the reports addressed to you, and no one else's. The fact that another person invested at all is itself confidential and is not shown to you, as yours is not shown to them.

The portal enforces this when it reads data, by asking only for what belongs to the person signed in, not by hiding other people's data on the page.

8. How long it is kept

The activity log, capital accounts and their entries, valuation marks, documents and published reports are kept for at least seven years after the later of the dissolution of the fund concerned and the end of the tax year the record relates to, and in practice indefinitely. Seven years is the period over which a tax authority may ask about a partnership return.

Accounts are blocked rather than deleted: blocking ends access at once and keeps the record of who did what.

Diagnostic logs, which never contain a tax identifier, a bank account number or the contents of an identity document, are kept for ninety days. Database backups are kept for 35 days and are never edited, so data erased at your request leaves them as they age out, within 35 days.

9. Your rights

Each request is answered by a person, not by a button: write to investors@founderfactor.com. The request and its outcome are themselves logged.

• Access. You may ask for a copy of what the portal holds about you: your record and its history, your investments and capital accounts with every entry, your documents, the messages sent to you and the log of actions taken on your data. The firm sends it to you outside the portal. If you invest through more than one legal entity, each has its own record and its own copy.
• Rectification. You may ask for anything inaccurate to be corrected. Your email addresses and your bank account you can change yourself, in Details; anything else the firm changes on your instruction.
• Erasure. Contact details with no evidential role can be erased: a telephone number, email addresses beyond the one needed to reach you while you are owed money, and correspondence that is not evidence of an instruction. What a tax record depends on cannot: your identity, tax identifier and tax form, your capital accounts and every entry in them, your executed subscription agreement, your Schedules K-1, your distributions and the activity log are kept for the period in section 8. The firm tells you in writing what was removed, what was kept, and why.
• Other rights. Where the law that applies to you gives you further rights, such as to restrict or object to processing or to receive your data in a portable form, you may exercise them the same way, within the same limits.
• Complaints. If you are in the European Union or the United Kingdom, you may also complain to the data protection authority where you live or work.

10. Security

All traffic to and from the portal is encrypted in transit, with no unencrypted fallback, and the database, the document store and the backups are encrypted at rest. Bank account numbers are further sealed with keys of their own, and only their last four characters are stored in clear.

There are no passwords. You sign in with Google or with a single-use code sent to an email address registered to your account, which expires within minutes. Accounts are created by the firm, never by signing in, and an address the portal does not know is refused. Repeated wrong codes are throttled, and a link in a notification never signs you in by itself.

Tax identifiers, bank account numbers and identity documents are never written to diagnostic logs or error reports and never sent by email.

If your data has been, or may have been, seen by someone who should not have seen it, the firm tells you individually: what was exposed, to whom if known, over what period, and what has been done.

11. Cookies

The portal sets only the cookies it needs to work. It sets no advertising or analytics cookies and collects no analytics of any kind.

• ff_session identifies your signed-in session. It holds a session identifier and nothing else, and lasts until you sign out or the session expires.
• ff_google is held only while you sign in with Google, for at most ten minutes, to match Google's answer to the request that asked for it.
• ff_refused keeps what you typed into a form in Details that was refused, never an account number, for at most five minutes, so the form can be shown again.

12. Changes and contact

The current version of this policy is always published at this address, with the date it took effect. A material change is notified to account holders before it takes effect.

Requests, questions and complaints about personal data go to investors@founderfactor.com.