Legal
Privacy Policy
1. Who we are
XX Horizons Ltd, trading as XX Invest, is the data controller for personal data processed under this policy. We are incorporated in England and Wales (company number 16937500), registered office 167–169 Great Portland Street, 5th Floor, London W1W 5PF.
You can contact us about data protection at hello@xx-invest.com.
2. Data we collect
When you visit the site: We collect standard server log data (IP address, browser, pages visited, referral source) and analytics data. We use cookies as described in our Cookie Policy.
When you join as a Member: We collect your name, email address, phone number, town, country, chosen membership plan, and your investor self-certification (HNWI or Sophisticated Investor). We also collect payment data, processed by Stripe on our behalf.
When you engage with us: We collect correspondence and any information you share in discussions, events or community features.
From third parties: Where you connect a LinkedIn or other social profile, we may receive profile information from that provider.
3. How we use your data and our legal basis
| Purpose | Legal basis | Details |
|---|---|---|
| Providing and managing your Membership account | Contract | Necessary to deliver your Membership and the services associated with it. |
| Processing payments | Contract | Processed by Stripe; we retain a record of the subscription for account management. |
| Investor self-certification | Legal obligation | We are required to confirm your eligibility before giving access to certain investment-related content under the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005. |
| Communicating with you about your account and Membership | Contract | Service emails, renewal reminders, and support. |
| Sending you our newsletter and updates about XX Invest | Legitimate interests / consent | Members receive updates under our legitimate interest; marketing emails to non-Members require consent. You can unsubscribe at any time. |
| Running events and community features | Contract / Legitimate interests | Organising events for Members and recording attendance where relevant. |
| Improving the site and our services | Legitimate interests | Analytics, user research, and product development. |
| Complying with law | Legal obligation | Responding to lawful requests from regulators or law enforcement. |
4. Who we share your data with
We share data only where necessary:
- Stripe — payment processing
- MailerLite — email communications (Members list)
- Hosting and infrastructure providers — cloud hosting and server management
- Analytics providers — aggregate, anonymised site analytics
- Professional advisors — legal, accounting and compliance advisors, under confidentiality obligations
We do not sell your personal data to third parties, and we do not share it with founders or companies on the platform without your consent.
Where we transfer data outside the UK, we ensure appropriate safeguards are in place (for example, Standard Contractual Clauses or an adequacy decision).
5. How long we keep your data
| Category | Retention period |
|---|---|
| Active Membership account | For the duration of Membership plus 7 years |
| Investor self-certification | For the duration of Membership plus 5 years (regulatory requirement) |
| Payment and transaction records | 7 years (financial record-keeping obligation) |
| Communications and correspondence | 3 years after last contact, or as required by law |
| Site analytics data | 26 months (aggregated/anonymised data retained longer) |
| Marketing consent records | Until consent is withdrawn, plus reasonable period for record-keeping |
6. Your rights
Under UK GDPR, you have the following rights in relation to your personal data:
Access
Request a copy of the personal data we hold about you.
Rectification
Ask us to correct inaccurate or incomplete data.
Erasure
Request deletion of your data where there is no legal basis for us to keep it.
Restriction
Ask us to restrict processing of your data in certain circumstances.
Portability
Receive your data in a structured, machine-readable format.
Object
Object to processing based on legitimate interests, including for direct marketing.
To exercise any of these rights, contact us at hello@xx-invest.com. We will respond within one month. You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk.
7. Cookies
We use cookies and similar technologies for authentication, analytics, and preferences. For full details, see our Cookie Policy. You can manage your cookie preferences at any time through your browser settings or our cookie banner.
8. Changes to this policy
We may update this policy from time to time. We will notify Members of material changes by email. The current version is always available on our website.
Contact
For data protection enquiries: hello@xx-invest.com
XX Horizons Ltd, 167–169 Great Portland Street, 5th Floor, London W1W 5PF
You may also contact the ICO: ico.org.uk · 0303 123 1113