Vitruvian Partners

Privacy Policy

Date: September 2026

1. Introduction

1.1 Vitruvian Partners LLP ("Vitruvian, "us", "our", "we") takes the protection of your privacy and personal data seriously and we are committed to respecting the privacy of all visitors to the www.vitruvianpartners.com website (the "Website"). Vitruvian is authorised and regulated by the UK Financial Conduct Authority (the "FCA") with registration number 454063.

1.2 This Privacy Policy ("Policy") sets out what personal data we might collect, how we process and protect that data, the lawful grounds for that processing, and your related rights. This Policy applies to any personal data we collect about you, for example by accessing this Website or by investing in funds managed by Vitruvian or enquiring about any funds managed by Vitruvian or our services. 'Personal data' means any information relating to an identified or identifiable natural person, namely one who can be identified, directly or indirectly from that information alone or in conjunction with other information. Vitruvian Partners LLP of 105 Wigmore Street, London W1U 1QY, England, is registered as a data controller with the Information Commission, registration number Z3534459. Vitruvian Partners Limited of 105 Wigmore Street, London W1U 1QY, England, is also registered as a data controller with the Information Commission, registration number Z3534323.

1.3 By visiting and/or contacting us through the Website, you consent to this Policy, and you acknowledge that we may collect, use and transfer your personal data pursuant to the terms of this Policy. If you do not accept the terms of this Policy, please do not use the Website. We do not market to or enter into contracts with children nor do we collect personal data from any person under 18 years of age. Please do not access or use the Website or services if you are under 18 years of age.

1.4 Please note that, unless specified herein, the definitions used in this Policy are defined in the Terms and Conditions.

2. Information we may collect from you

2.1 Vitruvian may collect and process the following categories of personal data in the normal course of business:

  • technical information: this will include information such as the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit: this will include the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), page response times, download errors, length of visits to certain pages, and methods used to browse away from the page;
  • statistical information about your visit to the Website including the pages you visited and which browsers are used to visit the Website; and
  • personal information obtained from you, such as name and email addresses, as may be provided by you through discussions in person or communications by email, telephone or other electronic means, when creating user profiles or contacting us (including, where notice is provided through the use of recording devices).

2.2 If you apply for a job at Vitruvian, we may collect the following categories of personal data about you (in addition to the categories set out above):

  • personal data provided as part of job applications (such as CVs, application forms, information relating to your right to work, passport information and visa details), which is either collected directly from you (for example, from interviews or applications) or from third parties, such as recruitment agencies; and
  • special category data, such as information relating to health (e.g. dietary requirements, accessibility requirements or information relating to reasonable adjustments), racial or ethnic origin, religion or sexual orientation and the results of pre-employment and criminal record history checks.

2.3 We generally collect the personal data described above directly through you when you engage with us, however, in some circumstances we may collect personal data from third parties such as recruitment agencies, former employers, referees and background check agencies.

3. Use of Personal Data

3.1 Vitruvian may use personal data held about you for the following purposes :

  • to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve the Website to ensure that content is presented in the most effective manner for you and for your computer;
  • as part of our efforts to keep the Website safe and secure;
  • to correspond with you and to respond to queries about the investment funds we manage, to investigate investment opportunities, and to market our funds in accordance with applicable rules and regulations where we have a right to do so;
  • for recruitment purposes when considering applications for positions with us and to carry out checks to verify the information provided by you (including reference, background, identity, suitability and criminal record checks); or
  • to provide our services and to run our business affairs (including, for example, for internal record keeping).

3.2 We will only use your personal data if and to the extent that applicable law allows.  In most cases we will process your personal information on one of the following lawful bases:

  • it is necessary for the performance of a contract with you or the organisation you work for;
  • it is necessary in connection with a legal obligation;
  • you have given your consent (where necessary) to such use or the organisation you work for has obtained your consent (where necessary) to share your information with us;
  • if we (or a third party) have a legitimate interest which is not overridden by your interests or your rights and freedoms. Such legitimate interests include the provision of our services, running Vitruvian's business and marketing relevant services directly to you; or
  • it is necessary in connection with our employment law or regulatory rights, obligations and requirements (including in respect of recruitment information which falls within "special categories" described in section 2.2).

3.3 Where you are required to provide personal data in connection with a statutory or contractual requirements, if you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented form complying with our legal obligations.

4. Disclosure

4.1 We will not give, sell or rent your personal data to third parties so they can market their services to you. Nor do we accept advertising from third parties on the Website. We may share personal data with the following third parties (in each case, as necessary to fulfil the purposes set out in this Policy):

  • any member or affiliate of the Vitruvian group;
  • employees of the Vitruvian group;
  • our fund administrator and our advisers;
  • analytics, platform and search engine providers that assist us in the improvement and optimisation of the Website; and
  • recruiters, screening check providers, providers of occupational personality tests, health service providers, professional associations, government and law enforcement agencies, referees and your current and previous employers (in respect of recruitment information).

4.2 Vitruvian may also disclose your personal information to third parties in the following limited circumstances:

  • in the event that it sells or buys any business or assets, in which case it may disclose your personal data to the prospective seller or buyer of such business or assets or their advisors;
  • if Vitruvian or substantially all of its assets are acquired by a third party, in which case personal data held by it, including about its investors will be one of the transferred assets; and
  • if it is under a duty to disclose or share your personal data by law or in order to comply with any legal obligation, regulation or court order, or in order to enforce or apply the Terms and Conditions, or to protect the rights, property, or safety of Vitruvian.

4.3 In each case, we shall take steps as reasonably necessary to share the minimum personal data necessary and have written contracts in place incorporating relevant wording to safeguard that personal data and comply with data protection legislation, and we will only share such personal data as is necessary for the purpose in question.

4.4 The personal data that you provide to us may be accessed by (or given to) our staff working outside the UK and the third parties referred to above, some of whom may be located outside the European Economic Area. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy and the applicable data protection legislation when it is processed in, or otherwise accessed from, a location outside the UK or the European Economic Area. This means that we will only transfer your personal data to third parties outside the UK or the European Economic Area if the transfer:

  • is to a third party situated in a country that has been confirmed by the European Commission or the UK Information Commissioner's Office (as applicable) to provide adequate protection to personal data;
  • is to a third party which has agreed (by way of written contract incorporating a data transfer mechanism approved by the relevant supervisory authority or by some other form of data transfer mechanism approved by the relevant supervisory authority) to provide all necessary protections to your personal data. You may obtain a copy of the written contract or the relevant data transfer mechanism by using the contact details detailed below; or
  • is otherwise subject to an exception under data protection legislation.

4.5 As a default position, we will only keep your personal data for as long as we reasonably require in order to achieve the purposes for which it was collected and, in any event, only for as long as applicable data protection legislation and our own internal rules and policies allow. This is subject, for example, to any valid opt-out or withdrawal of consent where processing is based on consent, or other valid exercise of your data subject rights which is affected.

5. Third Party Websites

The Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Vitruvian does not accept any responsibility or liability for these policies. We suggest that you carefully review the terms and conditions of use, and privacy policies, of each website that you visit before you submit any personal data to these websites. This Policy does not cover the information practices of those websites linked to from our Website. Other websites may send their own cookies to users, collect data, or solicit personal information.

6. Protection

The security of data is very important to our business. In accordance with our legal obligations, we take appropriate technical and organisational measures to protect your personal data and keep those measures under review. However, we can only be responsible for systems that we control and we would note that the internet itself is not inherently a secure environment.

7. Your Rights

Individuals whose personal data is processed by Vitruvian have certain legal rights regarding their personal data where relevant data protection legislation apply. Subject to certain exemptions, you have the right to:

  • be informed about how we collect and use your personal data;
  • receive a copy of the personal data we hold about you;
  • ask us to remove or correct any personal data that is inaccurate;
  • to object to certain processing and to withdraw any consent you may have given us for any processing of your personal data;
  • ask us to restrict the processing of your personal data,
  • to erase your personal data;
  • ask us to transfer your personal data to another provider; and
  • at any time, object to the processing of your personal data for direct marketing.

8. Cookies

8.1 We use cookies, which are a small text files that a website stores on your browser or the hard drive on your device when you visit our Website. We do not use cookies to store any personal data that could be read or understood by others. We use necessary cookies to make our Website work, however, we would also like to set analytics cookies which collect information about how visitors use our Website and help us to improve it. As they are optional, we won't set these unless you activate them. You are able to update your preferences regarding cookies at any time by accessing the ‘Cookies and site data’ settings in your browser.

8.2 The tables below explain the cookies we use and the purposes for which these are used. To learn more about what cookies are set on your computer as you browse the Internet and how to manage or delete them, visit www.allaboutcookies.org.

8.3 Necessary Cookies

These cookies are necessary for our Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of our Website will not then work.

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8.4 Analytics Cookies

These cookies collect information in an anonymous form and are used to analyse how visitors use and interact with our Website. We use this information in order to improve our Website. They may be set by us or by third party providers.

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9. Changes to our Privacy Policy

As data protection legislation and practice are constantly developing, this Policy will require updating from time to time. Any changes will be made by updating this Policy on the Website. It is your responsibility to return to the Website from time to time and check for changes.

10. Terms and Conditions

Use of the Website is subject to our Terms and Conditions.

11. Contact

If you have any questions or requests in relation to this Policy or if you would like to lodge a complaint about the processing of your personal data or our compliance with data protection legislation more generally, please address these to compliance@vitruvianpartners.com. We hope that we will be able to resolve any query or concern you raise about our use of your personal data.   If you feel we have not handled your query or concern to your satisfaction you can also contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at www.ico.org.uk/concerns or telephone 0303 123 1113.

12. Governing Law and Jurisdiction

This Privacy Policy is governed by and is to be construed in accordance with English law. The courts of England and Wales shall have exclusive jurisdiction to settle any dispute arising out of or in connection with this Policy.