Basefund Privacy Policy

This policy explains how Polycorp Ltd collects, uses and protects personal information when you use our website and products (together, "our services"). We aim to collect as little as we need, keep it for no longer than we need it, and never sell it.

1. Who we are

Polycorp Ltd ("Polycorp", "we", "us") is a limited company registered in England and Wales under company number 14957566. We are the data controller for personal information processed through our services, under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

You can contact us about anything in this policy at [email protected].

2. Information we collect

Depending on which service you use, we may collect:

• Account information - your name, email address and login credentials when you create an account.
• Content you provide - information you enter, upload or create while using a product.
• Usage and device information - technical data such as IP address, browser and device type, pages or features used, and timestamps, collected through server logs and similar tools.
• Communications - the content of emails and support requests you send us.
• Payment information - where a product charges, payments are handled by a payment provider. We receive confirmation of payment and limited details (such as the last four digits of a card), not your full card number.

We do not knowingly collect special category data (such as health information) unless a product clearly asks for it and you choose to provide it.

3. How we use it, and our lawful basis

We use personal information only where we have a lawful basis to do so:

• To provide the service you asked for - creating and running your account, storing your content, and delivering features. Basis: performance of a contract.
• To keep our services secure and working - preventing abuse, fixing faults and understanding how features are used in aggregate. Basis: our legitimate interests.
• To communicate with you - service notices, replies to your messages and important changes. Basis: performance of a contract or our legitimate interests.
• To send optional updates - such as product news, only where you have opted in. Basis: consent, which you can withdraw at any time.
• To meet legal obligations - such as tax, accounting and responding to lawful requests. Basis: legal obligation.

4. Cookies and similar technologies

We use only the cookies and local storage that are strictly necessary for a service to work, such as keeping you signed in. Where we would like to use any non-essential cookies, such as analytics, we will ask for your consent first, in line with the Privacy and Electronic Communications Regulations (PECR). You can also block or delete cookies in your browser settings.

5. Who we share it with

We do not sell your personal information. We share it only with:

• Service providers who process it on our behalf, such as hosting, email delivery and payment processing. They act under contract, on our instructions, and must keep it secure.
• Professional advisers such as accountants and lawyers, where necessary.
• Authorities, where required by law or to protect the rights, safety or property of our users, ourselves or others.
• A successor business, if Polycorp or a product is sold or reorganised, in which case this policy will continue to apply to your information.

6. International transfers

Some of our service providers may process information outside the UK. Where they do, we make sure it is protected by UK adequacy regulations or by appropriate safeguards such as the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

7. How long we keep it

We keep personal information only for as long as we need it for the purposes above. Account information and content are kept while your account is active and deleted within a reasonable period after you close it, unless we need to keep some of it to meet legal, tax or accounting obligations, or to resolve disputes. Server logs are kept for a limited period for security purposes.

8. How we protect it

We use appropriate technical and organisational measures to protect personal information, including encryption in transit, access controls and keeping our systems up to date. No system is perfectly secure, but we take care to reduce risk, and we will notify you and the Information Commissioner's Office where the law requires us to.

9. Your rights

Under UK data protection law you have the right to:

• access the personal information we hold about you;
• correct information that is inaccurate or incomplete;
• erase your information in certain circumstances;
• restrict how we use your information in certain circumstances;
• data portability - receive your information in a structured, commonly used format;
• object to processing based on our legitimate interests;
• withdraw consent at any time, where we rely on consent.

To exercise any of these rights, email [email protected]. We will respond within one month, and there is usually no charge. We may need to confirm your identity before acting on a request.

10. Children

Our services are not directed at children under 13, and we do not knowingly collect personal information from them. If you believe a child has given us personal information, contact us and we will delete it.

11. Complaints

If you have a concern about how we handle your information, please contact us first so we can try to put it right. You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk or on 0303 123 1113.

12. Changes to this policy

We may update this policy from time to time. The date at the top shows when it last changed. If we make significant changes, we will let you know through the service or by email before they take effect.

13. Contact

Polycorp Ltd, registered in England and Wales, company number 14957566. Email [email protected].