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Privacy Policy (UK)

This Privacy Policy explains how The CoFoundery ("we", "us", "our") collects, uses, shares, and protects personal data when you access or use our platform, website, applications, analytics, and related services (collectively, the "Platform").

Last updated: 24th January 2026

We are committed to protecting your privacy and processing personal data transparently, lawfully, and responsibly in accordance with UK GDPR, the Data Protection Act 2018, and guidance from the UK Information Commissioner's Office (ICO).

This Policy should be read with our Terms & Conditions.

1. Who We Are (Data Controller)

The CoFoundery is operated by:

Legal Entity Name: e turn Ltd.

Registered Address: Glasgow, United Kingdom

Contact Email: support@thecofoundery.com

For the purposes of UK GDPR, The CoFoundery is the Data Controller.

2. Scope of This Policy

This Privacy Policy applies to:

  • all users of the Platform,
  • all user types (founders, startups, talent, mentors, institutions, investors),
  • all data collected online or through Platform interactions.

It should be read together with our Terms & Conditions, which define how the Platform operates.

3. Core Privacy Principles

The CoFoundery processes data according to the following principles:

  • Purpose limitation - data is used only for clearly defined purposes
  • Data minimisation - only necessary data is collected
  • User control - individuals retain control over their personal data
  • Aggregation by design - institutions see patterns, not people
  • No automated decision-making with legal or significant effects
  • Trust before scale

4. What Data We Collect

4.1 Personal Data You Provide Directly

Depending on your role, this may include:

  • name, email address, and contact details
  • profile information (role, experience, interests)
  • startup or organisational details
  • communications with us or other users

4.2 Psychometric & Learning Data (High-Sensitivity)

Where applicable (currently founders/co-founders):

  • psychometric assessment responses
  • learning and soft-skills participation data

Important: Psychometric data is treated as high-sensitivity personal data and handled with enhanced safeguards.

4.3 Behavioural & Interaction Data

Automatically generated through Platform use, such as:

  • searches and navigation patterns
  • matching and engagement activity
  • interactions with content, mentors, or programs
  • timestamps and frequency of activity

4.4 Aggregated & Anonymised Intelligence Data

We generate derived datasets that:

  • are aggregated across multiple users,
  • are anonymised to prevent identification,
  • describe ecosystem-level patterns (not individuals).

This data cannot be traced back to you.

5. How We Use Your Data

We use personal data to:

  • operate and improve the Platform
  • enable matching, navigation, and learning features
  • support ecosystem coordination and insight
  • generate aggregated intelligence dashboards
  • ensure platform security and governance
  • meet legal and regulatory obligations

We do not sell personal data.

6. Lawful Bases for Processing (UK GDPR)

6.1 Consent (Article 6(1)(a), Article 9(2)(a))

Used for:

  • psychometric assessments
  • optional learning participation
  • certain communications

You may withdraw consent at any time.

6.2 Contractual Necessity (Article 6(1)(b))

Used to:

  • create and manage your account
  • deliver platform services

6.3 Legitimate Interests (Article 6(1)(f))

Used for:

  • platform improvement
  • security and fraud prevention
  • creation of aggregated ecosystem intelligence

All legitimate interest processing is subject to balancing tests and safeguards.

7. How We Share Data

7.1 With Other Users

Only where platform functionality requires it (e.g. profile visibility), and always according to your role and permissions.

7.2 With Institutions & Partners

Only aggregated, anonymised intelligence is shared.

  • No individual-level personal data is shared without explicit consent
  • No psychometric data is shared in identifiable form

7.3 With Service Providers

We may share data with trusted processors (e.g. cloud hosting, analytics) under strict contractual and security controls.

7.4 Legal & Regulatory Disclosure

Where required by law or regulatory authority.

8. Automated Decision-Making

The CoFoundery does not engage in automated decision-making that produces legal or similarly significant effects on individuals (UK GDPR Article 22).

All recommendations are decision-support only, interpretable, and subject to human judgment.

9. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this Policy, meet legal or regulatory requirements, and maintain platform integrity.

Aggregated and anonymised intelligence data may be retained longer, as it no longer identifies individuals.

10. Your Rights Under UK GDPR

You have the right to:

  • access your personal data
  • rectify inaccurate data
  • request erasure
  • restrict processing
  • object to processing based on legitimate interests
  • data portability
  • withdraw consent at any time

Requests can be made by emailing support@thecofoundery.com.

You also have the right to lodge a complaint with the ICO.

11. Data Security

We implement appropriate technical and organisational measures, including:

  • access controls
  • encryption where appropriate
  • role-based permissions
  • audit and monitoring mechanisms

No system is 100% secure, but we take security seriously and continuously improve safeguards.

12. International Data Transfers

For UK users: data is primarily processed within the UK or jurisdictions deemed adequate. Where transfers occur, appropriate safeguards (e.g. SCCs) are applied.

Cross-ecosystem intelligence does not involve raw personal data sharing.

13. Children's Data

The Platform is not intended for individuals under 18. We do not knowingly collect children's data.

14. Changes to This Privacy Policy

We may update this Privacy Policy to reflect legal changes, platform evolution, and governance improvements. Material changes will be communicated through the Platform.

15. Contact Us

For privacy-related questions or requests:

Email: support@thecofoundery.com

Address: Glasgow, UK

16. Final Statement

The CoFoundery is built on the belief that ecosystem intelligence should empower people - not expose them. We design our data practices accordingly.