Privacy Policy

Who we are

XX Invest is a trading name of XX Horizons Ltd, a company registered in England and Wales (Company No. 16937500). Our registered address is 167–169 Great Portland Street, 5th Floor, London, W1W 5PF.

We are the data controller for the personal data you share with us. If you have questions about how we handle your data, contact us at hello@xxinvest.co.uk.

What data we collect

We collect the minimum we need to operate the platform and meet our legal obligations. Depending on how you interact with us, that may include:

• Contact details – name, email address, phone number
• Professional and financial information – employer, income bracket, and information you provide when self-certifying as a High Net Worth Individual under the Financial Services and Markets Act 2000
• Identity verification information – where required by law or our compliance obligations
• Investment activity – records of investment decisions and transactions made through the platform
• Communications – emails, messages, and any correspondence with our team
• Technical data – IP address, browser type, device information, and how you interact with our website (via cookies, where you have consented)

We do not sell your personal data. We never have and never will.

Why we collect it and our legal basis

We process your data for the following purposes, each on a specific legal basis under UK GDPR:

• To provide our service – processing your membership application, verifying your HNWI status, and presenting investment opportunities to you. Legal basis: contract performance.
• To meet legal and regulatory obligations – maintaining records required under applicable financial services law, anti-money laundering rules, and HMRC requirements. Legal basis: legal obligation.
• To communicate with you – sending member updates, deal briefings, and administrative communications. Legal basis: contract performance or legitimate interests.
• Marketing communications – if you have joined our waitlist or opted in. Legal basis: consent. You can withdraw consent at any time.
• To improve our platform – understanding how members use the site, fixing technical issues. Legal basis: legitimate interests.

Who we share it with

We share your data only where necessary, and only with parties who are contractually required to protect it:

• Technology and platform providers who support the operation of our service (for example, email and CRM infrastructure)
• Legal and compliance advisers where required to meet our regulatory obligations
• SPV and nominee service providers (such as Seedlegals) where you choose to invest through a structured vehicle – you will be made aware of this at the point of investment
• HMRC or other regulatory authorities, where we are legally required to report

We do not share your data with third parties for their own marketing purposes.

How long we keep it

We keep your data for as long as your membership is active and for a period afterwards as required by our legal and regulatory obligations. Investment records and HNWI certifications are typically retained for a minimum of six years in line with HMRC requirements. Where there is no legal obligation requiring retention, we delete data once it is no longer needed for the purpose it was collected.

Transfers outside the UK

We aim to keep your data within the UK and European Economic Area wherever possible. Where we use technology providers that transfer data internationally, we ensure appropriate safeguards are in place – including standard contractual clauses approved by the ICO.

Your rights

Under UK data protection law, you have the right to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete data
• Request deletion of your data (subject to our legal obligations)
• Object to or restrict certain processing
• Withdraw consent at any time, where processing is based on consent
• Request a portable copy of your data
• Lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk

To exercise any of these rights, contact us at hello@xxinvest.co.uk. We will respond within one month.

Cookies

Our website uses cookies to understand how visitors use the site and to improve their experience. We use strictly necessary cookies (which do not require consent) and, with your consent, analytics cookies. You can manage your cookie preferences at any time via the cookie settings on our site.

We do not use advertising or tracking cookies.

Changes to this policy

We may update this policy from time to time. The date at the top of this page reflects when it was last revised. If we make material changes that affect how we process your data, we will notify you directly by email.