Privacy Policy

1. Introduction

Welcome to Sourcefolio ("Sourcefolio", "we", "us", "our").

This Privacy Policy explains how we collect, use, store, process and protect personal information when you access or use our website, application, software platform, investor portals, CRM tools, deal management tools and related services (collectively, the "Service").

We are committed to handling personal information responsibly and transparently.

This Privacy Policy applies to users located in the United Kingdom and is intended to comply with applicable data protection laws, including:

• The UK General Data Protection Regulation ("UK GDPR");
• The Data Protection Act 2018;
• The Privacy and Electronic Communications Regulations ("PECR");
• Other applicable UK privacy legislation.

By using Sourcefolio, you acknowledge that you have read and understood this Privacy Policy.

2. Who We Are

Sourcefolio is a software platform providing property professionals, investors, businesses and related users with tools to manage deals, contacts, relationships, workflows, enquiries and investor communications.

Sourcefolio provides technology infrastructure only.

We do not:

• control the information users choose to store within their own CRM areas;
• verify the accuracy of user-uploaded information;
• determine the purpose for which users collect information from their own customers, investors, suppliers or contacts;
• provide financial, legal, tax or investment advice.

For questions regarding privacy, please contact: Support@sourcefolio.uk

3. Important Information About CRM Data

Sourcefolio allows users to create and manage their own CRM records, including investor contacts, business contacts, suppliers, builders, solicitors and other third parties.

Users may store information such as:

• names;
• email addresses;
• telephone numbers;
• investment preferences;
• notes;
• communication records;
• business relationship information;
• other information entered by the user.

User Responsibility

Where you use Sourcefolio CRM features to store information about other individuals, you are responsible for ensuring that:

• you have a lawful basis for collecting and processing that information;
• you have provided appropriate privacy notices where required;
• you have obtained necessary permissions or consents;
• your use of the information complies with UK GDPR and applicable laws.

Sourcefolio acts as a technology provider enabling users to organise their own information.

You remain responsible for the information you enter into your own CRM workspace and how you use that information.

4. Information We Collect

We may collect the following categories of information.

4.1 Account Information

When you create an account, we may collect:

• name;
• email address;
• login information;
• authentication information;
• account details;
• subscription status;
• account activity information.

4.2 Payment Information

Payments may be processed by third-party payment providers including Stripe.

We do not store your full payment card details.

We may receive limited payment information including:

• subscription status;
• payment status;
• transaction references;
• billing information;
• subscription plan;
• payment dates.

Payment providers process payment information according to their own privacy policies.

4.3 CRM Information

Users may voluntarily enter information into CRM systems provided through Sourcefolio.

This may include:

• investor information;
• customer information;
• supplier information;
• professional contact information;
• notes;
• communication history;
• preferences;
• relationship information.

The user who enters this information remains responsible for ensuring lawful use.

4.4 Deal and Property Information

Users may upload or create deal information including:

• property details;
• descriptions;
• images;
• videos;
• documents;
• calculations;
• projections;
• notes;
• investment information;
• portfolio information.

Users are responsible for ensuring they have appropriate rights and permissions to upload and share this information.

4.5 Technical Information

We may automatically collect technical information including:

• IP address;
• device information;
• browser information;
• operating system;
• approximate location information;
• login activity;
• usage activity;
• pages accessed;
• system performance information.

This information helps maintain, secure and improve the Service.

5. Sensitive Personal Information

Sourcefolio is not designed for storing highly sensitive personal information.

You should not upload or store:

• passport copies;
• driving licences;
• identity documents;
• bank account details;
• payment card information;
• passwords;
• government identification numbers;
• medical information;
• highly confidential personal records.

If you choose to upload information that you should not store on the platform, you do so at your own risk and responsibility.

6. How We Use Information

We may use information to:

Provide the Service

Including:

• creating accounts;
• providing platform access;
• managing subscriptions;
• operating CRM features;
• providing investor portal functionality;
• maintaining user accounts.

Maintain Security

Including:

• detecting abuse;
• preventing fraud;
• protecting accounts;
• investigating suspicious activity;
• maintaining platform security.

Improve the Platform

Including:

• analysing usage;
• improving functionality;
• fixing errors;
• developing new features.

Communicate With Users

Including:

• account notifications;
• service updates;
• support requests;
• important operational communications.

Marketing communications will only be sent where permitted by applicable law.

7. Lawful Basis for Processing

Under UK GDPR, we rely on the following lawful bases:

Contract

Where processing is necessary to provide the Service requested by you.

Examples:

• account creation;
• subscription management;
• platform functionality.

Legitimate Interests

Where necessary for our legitimate business interests.

Examples:

• improving services;
• maintaining security;
• preventing misuse;
• managing customer relationships.

Consent

Where required.

Examples:

• certain marketing communications;
• non-essential cookies.

Legal Obligations

Where required to comply with legal responsibilities.

8. Sharing Information

We do not sell personal information.

We may share information with trusted service providers necessary to operate Sourcefolio.

These may include:

• hosting providers;
• database providers;
• authentication providers;
• payment providers;
• analytics providers;
• email providers;
• security providers;
• software infrastructure providers.

These providers process information according to appropriate agreements and their own privacy policies.

9. Investor Portals and Shared Links

Sourcefolio may allow users to create investor portals, shared deal pages and access links.

Users are responsible for:

• deciding who receives access;
• ensuring recipients are authorised;
• protecting confidential information;
• removing access when appropriate.

Sourcefolio is not responsible for:

• users sharing links incorrectly;
• users providing access to unauthorised people;
• recipients misusing information;
• information being shared outside the intended audience due to user actions.

10. Security and Data Protection

We implement reasonable technical and organisational measures designed to protect information.

These measures may include:

• access controls;
• authentication protections;
• security monitoring;
• infrastructure protections;
• appropriate data handling procedures.

However, no internet-based service can guarantee complete security.

You acknowledge that:

• cyber attacks may occur;
• vulnerabilities may exist despite reasonable precautions;
• third-party providers may experience failures;
• data transmission over the internet carries inherent risks.

Sourcefolio cannot guarantee that information will never be accessed unlawfully, lost, altered or unavailable.

To the maximum extent permitted by law, we are not responsible for security incidents caused by circumstances outside our reasonable control, including third-party failures, cyber attacks, malicious actions, user negligence or compromised credentials.

11. Data Retention

We retain information only for as long as reasonably necessary.

Retention periods depend on:

• the purpose of processing;
• legal requirements;
• business requirements;
• security considerations.

Information may be deleted or anonymised when no longer required.

12. International Transfers

Some technology providers may process information outside the United Kingdom.

Where international transfers occur, we take reasonable steps to ensure appropriate safeguards are implemented in accordance with UK GDPR.

13. Your Data Protection Rights

Under UK GDPR, you may have rights including:

• access to your personal information;
• correction of inaccurate information;
• deletion requests;
• restriction of processing;
• objection to processing;
• data portability;
• withdrawal of consent.

Requests can be made by contacting: Support@sourcefolio.uk

We may require identity verification before responding.

14. Account Deletion

You may request deletion of your account.

Where possible, we will delete or anonymise personal information.

We may retain certain information where necessary for:

• legal obligations;
• fraud prevention;
• accounting purposes;
• dispute resolution;
• enforcement of agreements.

15. Cookies

We may use cookies and similar technologies for:

• authentication;
• security;
• functionality;
• analytics;
• improving user experience.

Where required, we will obtain consent before using non-essential cookies.

16. Children's Privacy

Sourcefolio is not intended for anyone under 18.

We do not knowingly collect information from children.

17. Changes to This Privacy Policy

We may update this Privacy Policy periodically.

Updates will be posted with a revised date.

Continued use of Sourcefolio after changes means you accept the updated policy.

18. Complaints

If you have concerns about how we process information, please contact us first.

You also have the right to complain to:

Information Commissioner's Office (ICO)
https://ico.org.uk

19. Governing Law

This Privacy Policy is governed by the laws of England and Wales.

Any disputes will be subject to the courts of England and Wales.

20. Contact

For privacy enquiries: Support@sourcefolio.uk