Privacy Notice

Pulse is operated by FMP Ventures Ltd, a company registered in England and Wales with company number 13810662, trading as FundMyPitch. Our registered office is 128 City Road, London EC1V 2NX.

We are the controller of the personal data described in this notice. That means we decide why and how it is used.

You can contact us about anything in this notice at [email protected], or by post at 128 City Road, London EC1V 2NX.

We have not appointed a data protection officer, because we are not required to. The contact at 1.3 handles data protection questions and will involve our advisers where a question needs legal input.

Pulse is a research tool that shows who invests in UK companies, built from documents filed at Companies House and from published Innovate UK grant data.

This notice is in two parts, because we hold two very different kinds of personal data:

1. Part A applies if you are named in Pulse as a shareholder, investor or grant recipient, and you have not given us your data yourself.
2. Part B applies if you are a subscriber, a member of a subscriber's team, someone who has contacted us, or someone who has signed in with LinkedIn.

If you fall into both groups, both parts apply to you.

If you appear in filings at Companies House as a shareholder, or in a published Innovate UK grant award, we hold:

1. your name as it appears in the filing, together with spelling variants we have matched to the same person (section 3.4);
2. the companies whose shares you hold, the number and class of shares, and the filing dates;
3. an estimate of the amount you invested: the number of shares you hold multiplied by the price paid per share in the round in which you acquired them, with a confidence rating;
4. figures derived from those estimates, such as your total estimated investment, your average investment and the number of companies you have backed (section 5.5);
5. if you hold shares jointly with other people, the joint holding, shown as one holding under all the names filed, never as an investment by each of you;
6. where a company you hold shares in has been acquired or has changed control, the outcome;
7. which investors appear in the same rounds as you; and
8. if you are a founder or director, the same information, held only so that we can exclude your own holdings from what subscribers see.

We do not hold your email address, telephone number, home address, or any social media profile, unless you have verified your record and chosen to add a link to it (section 11.8). If you are also a director, or a person with significant control, of a company where you hold shares, we hold the month and year of birth and the officer identifier that Companies House publishes for you there. We use them only to tell apart people who share a name; they are never shown to subscribers.

We do not set out to hold special category data or criminal offence data about you, and we hold no field for it. A name, or a joint holding, could in some cases suggest something about a person; we do not draw such inferences or show them.

The same name can appear in many filings, so we group filings under one record by the name filed. Names with different middle names are kept as different people. A name filed without a middle name joins the one person it could be when there is only one, and is otherwise kept apart in a record of its own. Where Companies House shows the same officer, or the same month and year of birth, we use that to join records or keep them apart, and a person on our team reviews other possible matches. You can ask us to separate a record that mixes you up with someone else, and we will tell you which filings make up your record (section 12.5).

Your data comes from filings that companies are legally required to make at Companies House, including share allotments and confirmation statements with their shareholder lists, and from the registers of directors and of persons with significant control that Companies House publishes for the same companies. It also comes from published Innovate UK grant awards. For investors that are firms, we also use the public Financial Services Register (FCA) and the Global LEI Index (GLEIF).

We do not obtain it from you, and we do not obtain it from data brokers or from internet sources at large.

We use it to compile, organise and publish a searchable record of who invests in UK companies, and to make that record available to paying subscribers who use it for investment research and fundraising. That includes helping subscribers find and research investors: showing which investors appear in the same companies and the shortest chains of shared shareholdings between them, and letting a subscriber open a search for an investor's name on LinkedIn in the subscriber's own LinkedIn account.

Our lawful basis is legitimate interests: Article 6(1)(f) of the UK GDPR. We do not rely on your consent, because we do not have it, and we do not rely on any of the other bases in Article 6(1).

The specific interests we rely on are:

1. the interest of founders, investors, accelerators and advisers in understanding the UK startup investment market, which is currently spread across tens of thousands of individual filings that are public but practically unreadable;
2. our commercial interest in operating a paid research service; and
3. the interest of the wider market in a more transparent record of investment activity, consistent with the policy of public filing under the Companies Act 2006.

We have carried out and documented a legitimate interests assessment. We weighed those interests against your interests, rights and freedoms, taking account of the following: the information is already public and you made it public by acquiring shares in a company that files at Companies House; we do not add contact details, and the only other public registers we use about individuals (the Companies House registers of directors and of persons with significant control) are used solely to tell apart people who share a name and are never shown; we present amounts as estimates with a confidence rating; we exclude founder and director holdings from what subscribers see; exports never include individual investors, and usage limits stop the record being copied in bulk; a LinkedIn search runs in the subscriber's own account and we receive nothing back from LinkedIn; subscribers are bound by our terms to contact anyone lawfully and to honour objections; you can object and be removed from every view at once; and removal is permanent because you are added to a suppression list that later imports check against.

We derive figures about you from the filings, such as your estimated total investment, your average investment and the number of companies you have backed, and Pulse ranks investors by the number of companies they have backed. That is profiling in the sense of Article 4(4) of the UK GDPR: an evaluation of your investment activity from public filings. We do not use it, or anything else, to make decisions about you, and it produces no legal or similarly significant effect for you. You can object to it, as to everything in Part A (section 10.2). When you ask us to hide your record, a person reviews the request before it is actioned, as described in section 12.

We do not have your contact details, so we cannot write to you directly, and obtaining them for this purpose would not be appropriate.

Article 14 of the UK GDPR normally requires us to give you this information individually, within one month of obtaining your data or, where we intend to communicate with you, at the time of the first communication. We rely on Article 14(5)(e), which disapplies that requirement to the extent that providing the information is impossible or would involve a disproportionate effort.

That exemption applies here because the population is very large, much of the data concerns rounds that closed years ago, and we hold no contact details. On 7 November 2026, Pulse held 311,949 records of named individual investors (people, single names and joint holdings, which can name several people; one person can also have more than one record) across 103,482 investor-backed companies. This figure is worked out the same way each time and is up to date whenever this page is opened.

Article 14(7) of the UK GDPR also requires us to take appropriate measures to protect your rights, freedoms and legitimate interests, including by making this information publicly available. Those measures are:

1. this notice, published on a page that anyone can reach without an account or password;
2. a public data request form at https://pulse.fundmypitch.com/privacy/request, which does not require you to be a subscriber;
3. a suppression mechanism that removes you from every view, count and portfolio at once, and adds you to a list that future imports are checked against;
4. a correction route for estimates and for records that mix people up, described at section 12;
5. a complaints procedure, described at section 12;
6. a published statement of the categories of data we hold and the categories of recipient, in sections 3 and 7;
7. exports that never include individual investors, and usage limits that stop the record being copied in bulk; and
8. a published statement of how estimates are worked out and when records are joined, in sections 3.1 and 3.4.

The exemption in section 6.2 covers the giving of information only. It does not authorise us to use your data for a new purpose, and it does not remove your right to object.

We do not send marketing to people named in Pulse. We do not sell, rent or share your data for anyone else's marketing. Where a subscriber contacts you using what they found in Pulse, that subscriber is acting as a controller in its own right and is responsible for its own compliance; our terms prohibit subscribers from using Pulse for unlawful unsolicited marketing, and we suspend accounts that do.

Subscribers see your name, the companies you hold shares in, the date of the shareholding, the estimated amount and the confidence rating, and your co-investors. Subscribers on the Founder, Angel, Professional and Ecosystem plans see individual investors by name. Subscribers on the Company data plan do not. Subscribers who can see you can also open a search for your name on LinkedIn in their own LinkedIn account (LinkedIn receives only the search words, and we receive nothing back), and see chains of shared shareholdings that connect you with other investors and companies. If you hold shares jointly, subscribers see the joint holding as one holding under all the names filed.

Exports contain companies, rounds and investment firms only. Since 2 November 2026 they do not include individual investors, single names or joint holdings, so your data is not exported from Pulse. If we correct, erase or restrict your data, the change applies at once everywhere in Pulse. Before that date, subscribers on some plans could export lists that included individual investors. We record that an export took place, but not which rows it contained, so we cannot identify who received a particular person's data, and telling each recipient of a correction or erasure (Article 19 of the UK GDPR) is not possible. Our terms require any subscriber who holds an earlier copy to stop using it for direct marketing if you object.

We use the following suppliers. Each is a processor acting on our written instructions, except where marked as an independent controller.

We also disclose personal data where we are required to by law, to a court or regulator, or to establish or defend a legal claim; to professional advisers bound by confidentiality; and to a buyer or successor if the business is sold, in which case the notice will be updated and you will be told.

We do not sell personal data.

Some of our suppliers process data outside the United Kingdom, principally in the United States and the European Union. The transfers are to the suppliers marked as located outside the United Kingdom in section 7.3. The safeguard we rely on for each is set out in the table below.

Where we rely on the UK Extension to the EU-US Data Privacy Framework, we do so under regulations made under Article 45A of the UK GDPR. We check that the certification is active, that it covers the contracting entity, and that it covers the type of data transferred, before each transfer begins, and we review that position at least annually.

Where we rely on the International Data Transfer Agreement or the UK Addendum, we carry out and record an assessment that the standard of protection provided would not be materially lower than under the UK GDPR, as Article 46(6) requires.

You can ask us for a copy of the relevant safeguard at [email protected].

Our supplier contracts require the supplier to act only on our instructions, to keep the data secure, to assist us with your rights, to tell us about a personal data breach without undue delay, and to delete or return the data at the end of the arrangement. Where a supplier engages a sub-processor, that sub-processor is bound by the same obligations.

We keep your data for as long as the shareholding or grant appears on the public register and remains relevant to the service.

If you object and we suppress your record, we keep your name and a minimal identifier on a suppression list indefinitely, so that later imports do not restore you. That is the only way to make the suppression durable. The suppression list holds no shareholding, financial or contact information.

The full retention schedule, including retention for subscribers and for data requests, is at section 14.

You have the right to be told what we hold about you (Article 15), to have inaccurate data corrected (Article 16), to have your data erased (Article 17), to restrict what we do with it (Article 18), and to object to our processing (Article 21).

Your right to object is particularly important here. Because we rely on legitimate interests, you can object on grounds relating to your particular situation, and we must stop unless we can show compelling legitimate grounds that override your interests. In practice, where you object and we cannot identify an overriding reason, we will suppress your record.

We do not process your data on the basis of consent, so the right to withdraw consent (Article 7(3)) does not arise for Part A.

Data portability (Article 20) does not apply to Part A, because we process your data neither on the basis of consent nor under a contract with you.

Section 12 explains how to exercise these rights, and the correction and suppression routes.

If you subscribe, or are invited to a seat on someone else's subscription, we hold your name, email address, organisation name, job title, a hash of your password, your plan and billing status, and, if you sign in with LinkedIn, your LinkedIn member ID. If you are the account owner we also hold billing details, which are passed to Stripe; we do not receive or store your card number.

We also record how you use Pulse: the searches you run, the pages you open, what you shortlist and export, when you open a LinkedIn search from Pulse, and the questions you ask Ask Pulse and the answers you receive. We also record when you open an investor's own website or application from Pulse (which investor, not what you do there). We record this ourselves. We use no third-party analytics once you are signed in, and we do not track you on other websites.

We send account emails through Twilio SendGrid: password resets, team invitations, replies to data requests and service notices. Link and open tracking are switched off for these emails.

The lawful basis for each activity is set out in section 15.

If you sign in with LinkedIn, LinkedIn tells us your name, email address and member ID. We use the member ID to recognise you when you return. We never post on your behalf, read your connections, or store your profile photograph. LinkedIn is an independent controller for your LinkedIn account, and its own privacy notice applies to that relationship. We receive your data from LinkedIn rather than from you directly, and we tell you here what we receive and why.

If you choose to, you can tell us which investor record or company in Pulse is yours ("Is this you?"). We then link your account to that record, show you a private view of your own holdings, and keep the answers you give about them (for example that a holding is not yours, or that an amount is wrong) so that a member of our team can check them. Nothing you tell us changes what other subscribers see until we have checked it. If you ask us to verify your record, we keep the information you send for that check. You can remove the link at any time from your account.

If you join a syndicate in Pulse, its other members see your name, your role and, only if you opt in, the holdings in your confirmed record, combined into the syndicate's portfolio. Syndicates are visible only to their members. You can stop sharing your holdings, or leave the syndicate, at any time. If a syndicate we have verified chooses to have a public page, other subscribers see its name and description, and you appear on it only if you choose to be listed; the companies in your verified record appear there only if you also choose that (amounts are never shown on the public page). Where you are listed in a public syndicate, other subscribers may also see the syndicate's name on your investor record and in the network views.

Once we have verified that a record is yours, or your firm's or company's, you can choose to add details to it, such as a LinkedIn or website link, an investment focus, a typical cheque size, a description, your name and role, and, for a company, that it has told us it is raising. These are shown to subscribers only while you choose to show them, and a raising notice lapses after 90 days unless you renew it. We show how many times your record was viewed, as a number only, never who viewed it. If you record the status of your contact with investors on your shortlist, only you see it; we hold it for you as your processor (section 13.7 of our Terms) and look only at totals across all subscribers. You can change or remove any of this at any time from your account.

If you are a founder, we hold what you tell us about your company and your raise: what brings you to Pulse, your company, sector, stage and region, your round (including any valuation you give), your traction, your team and anything else you add, and, if you upload one, your pitch deck and what we read from it. Each answer is kept with where it came from and a history of changes. We use this only to show you investors who fit, to set up your saved searches and to plan your next steps in Pulse. It is private to you: we never show it to investors or other subscribers. If you choose to answer a question about the diversity of your founding team, we keep that answer only with your explicit consent, and you can remove it at any time. You can change or delete any answer, your deck and its history at any time, and they are deleted with your account.

If you ask to join a FundMyPitch community group chat, we hold your mobile number, the group you asked to join and the wording you agreed to. The group depends on your account type (founders, investors or the wider startup ecosystem) and the groups do not overlap. We use your number only to add you to that group. Other members of the group, and WhatsApp (Meta) as the platform, see your name and number. If you leave, we keep your number only until it has been removed from the group, then delete it.

If you visit our public pages (the home page, Pricing, Who it's for, the sector pages, Contact, the Terms and this notice) and accept analytics cookies, Google Analytics measures which of those pages you view, how you arrived and roughly where from, so that we can see how people find Pulse. We see totals and trends, not who you are. If you reject, or make no choice, nothing is sent to Google. You can change your choice at any time from Cookie settings at the bottom of any public page. Google Analytics never runs on the sign-in, sign-up and data request pages, or anywhere in Pulse once you are signed in.

You can exercise any right in Part A or Part B by using the form at https://pulse.fundmypitch.com/privacy/request, or by emailing [email protected], or in writing to 128 City Road, London EC1V 2NX.

We will respond within one month. If a request is complex we may extend that by up to two further months, and we will tell you within the first month if we do. Exercising your rights is free.

A person reviews every request before we act on it. We may ask you to confirm your email address and to confirm that the request is about you, and, because the same name can appear more than once in the filings, for the name of a company you hold shares in or an approximate date, so that we identify the right record. That is a proportionate check, not a barrier: we do not require identity documents for a suppression request.

If you ask us to stop showing your data, we will hide your record from every view at once, including subscriber views, counts and portfolio pages, and we will add you to our suppression list so that later imports do not restore it. We will confirm when this is done. The shareholding remains on the public register at Companies House; that is outside our control and you would need to deal with Companies House separately.

If you tell us a figure about you is wrong, we will check it against the filing. If our calculation is wrong, we will correct it. If the filing itself is wrong, the correction has to be made at Companies House, and we will reflect the corrected filing at the next import. We will tell you which of those applies.

If you are not satisfied with how we have handled your data or your request, you can complain to us. You can use the form at https://pulse.fundmypitch.com/privacy/request, email [email protected], or write to 128 City Road, London EC1V 2NX. We will acknowledge your complaint within 30 days of receiving it, we will investigate without undue delay and keep you informed, and we will tell you the outcome. This right to complain to us is in section 164A of the Data Protection Act 2018, and we tell you about it because Article 13(2)(ca) and Article 14(2)(da) of the UK GDPR require us to. There is no charge and no exemption that applies to us.

You can also complain to the Information Commission, which is the regulator and took over the functions of the Information Commissioner's Office on 30 September 2026. Its website is https://ico.org.uk. The statutory route is section 165(2) of the Data Protection Act 2018. We would ask you to raise the matter with us first, but you are not required to.

If you are a subscriber and you want a copy of your account data, or you want your account deleted, use the same form. We will provide the data in a structured, commonly used, machine-readable format, which is your right under Article 20.

We do not act on data protection requests automatically. Every request, whether from a subscriber or from a person named in Pulse, is reviewed by a person before anything happens.

We do not make decisions about you based solely on automated processing. In the language of Articles 22A to 22C of the UK GDPR, we take no significant decisions based solely on automated processing. Section 5.5 explains the figures we derive about people named in Pulse, which is profiling but involves no decision about them. If you are a founder, Matches compares what you tell us with investors' published criteria to show you which investors may fit; it decides nothing for you or for any investor.

If you think something has been handled wrongly, say so at [email protected] and a person will look at it again. There is no charge for this.

Apart from the analytics cookies in section 13.5, we use cookies only to keep you signed in, to keep the service secure and to remember your cookie choice: pulse_session (keeps you signed in); pulse_preview (lets invited people past the preview password, while Pulse has one); pulse_li_state and pulse_li_pending (only during a sign-in with LinkedIn); pulse_consent (remembers whether you accepted or rejected analytics cookies, for six months); and, for our own staff only, pulse_2fa (five minutes, during two-step sign-in) and pulse_view_as. Cloudflare, which carries our web traffic, may set its own security cookie (__cf_bm) to protect the site from automated abuse. These are strictly necessary for the service you have asked for, or for its security, so they do not require consent, under paragraph 4 of Schedule A1 to the Privacy and Electronic Communications (EC Directive) Regulations 2003. A page may also remember small settings in your own browser, such as whether you prefer a chart or a list; that stays on your device. We do not use advertising cookies.

On our public pages only, and only if you press Accept on the cookie banner, we use Google Analytics, which sets the cookies _ga and _ga_ followed by our measurement code, for up to 13 months, on pulse.fundmypitch.com only. Nothing is sent to Google before you accept. We have switched off Google signals and advertising features, and the analytics data is kept in Google Analytics for two months. You can withdraw your consent at any time from Cookie settings at the bottom of any public page: pressing Reject stops Google Analytics and removes its cookies. The lawful basis is your consent, under regulation 6 of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and Article 6(1)(a) of the UK GDPR.

If you are a subscriber, we need your name, email address and payment details to provide the service. Without them we cannot open an account. The rest is optional.

If you are named in Pulse, you have not given us your data and you are not required to. You can object at any time, as described at section 12.

We keep data on a server with restricted administrative access, protected by a firewall and key-only sign-in, store passwords only as a hash, keep nightly backups for 14 days, and review access regularly.

If a breach occurs that is likely to result in a risk to your rights, we will tell the Information Commission within 72 hours, and we will tell you without undue delay where the breach is likely to result in a high risk to you, as Articles 33 and 34 of the UK GDPR require.

We will publish any change here, with a new version number and effective date, and we will tell subscribers by email if the change is significant. The current version is always at https://pulse.fundmypitch.com/privacy.

This notice is governed by the law of England and Wales. It is not a contract and creates no contractual rights.