Privacy Policy
Controller: Quantum Light Management Ltd (company no. 13878761).
Version 1.1 — 13 October 2026.
1. IMPORTANT INFORMATION AND WHO WE ARE
This privacy policy sets out how Quantum Light uses and protects your personal data when you visit quantumlightcapital.com, use the QuantumLight Portal, or accept our invitation to be introduced to the companies in our investment portfolio. It is provided in a layered format so you can click through to the specific areas set out below. If you are an investor in one of our funds, our Investor Privacy Notice at https://quantumlightcapital.com/investor-privacy-notice applies to your investment; this policy applies to your use of our website and the Portal.
- Important information and who we are.
- The types of personal data we collect about you.
- How your personal data is collected.
- How we use your personal data.
- Disclosures of your personal data.
- International transfers.
- Data security.
- Data retention.
- Your legal rights.
- Contact details.
- Complaints.
- Changes to the privacy policy and your duty to inform us of changes.
- Third-party links.
This privacy policy gives you information about how Quantum Light collects and uses your personal data through your use of this website and the QuantumLight Portal, including any data you provide when you register for the Portal, sign in to it, search it, read or rate material on it, or contact us.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller
Quantum Light Management Ltd, a company incorporated in England and Wales with company number 13878761 whose registered office is at 5th Floor, North Side 7/10 Chandos Street, Cavendish Square, London W1G 9DQ, is the controller and responsible for your personal data ("Quantum Light", "we", "us" or "our" in this privacy policy). We are registered with the Information Commissioner's Office under registration reference ZB332737.
You can contact our data protection officer, Kate Chan, at dpo@quantumlightcapital.com, about anything in this policy, including to exercise your rights (paragraph 9). Our contact details are in paragraph 10.
Our representative in the European Union
Because we offer the QuantumLight Portal to individuals in the European Union and record how they use it, we have appointed a representative in the Union under Article 27 of the EU GDPR. Data Protection Representative Limited (trading as DataRep) has been appointed as our Data Protection Representative for the purposes of The General Data Protection Regulation (GDPR) in the EU/EEA and the Federal Act on Data Protection (FADP) in Switzerland. DataRep is registered in the Republic of Ireland with registered number 616588 and their registered address is 77 Camden Street Lower, Dublin, D02 XE80, Ireland. If you are in the EEA you may contact our representative on any matter relating to our processing of your personal data.
2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
"Personal data" means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- "Identity Data": includes your first name, last name, the company you are associated with, and your QuantumLight Portal username.
- "Contact Data": includes your work email address.
- "Credential Data": includes your passkey public key if you use one, and the one-time codes used to verify a sign-in. We hold no password for you.
- "Profile Data": includes your QuantumLight Portal account profile, namely your username, the interface preferences you set, and your marketing and communication preferences.
- "Reading Data": includes which playbooks and other materials you open in the QuantumLight Portal, when you open them, how long each page is open, which sections of a page or report you read and for how long, how far down each page you have read and whether you have finished it, and whether you mark an item helpful.
- "Search Data": includes the words you type into the Portal search box, how many results came back, and whether you opened one of them and which page it was. We do not record who searched. No account identifier is stored against a search, there is no session identifier, and the time is kept only to the nearest hour.
- "Problem Report Data": includes what you tell us when you report a problem with the QuantumLight Portal, the address of the page you were on, your browser and screen size and, if you leave that option ticked when you send the report, an image of the page as it appeared to you at that moment.
- "Candidate Data": includes the email address and the address of the professional networking profile (for example LinkedIn) that you give us when you accept our invitation to be introduced to the companies in our investment portfolio, together with the date you accepted and a record of the invitation you accepted.
- "Technical Data": includes your internet protocol (IP) address, your sign-in times, browser type and version, time zone setting, operating system and platform, and the entries recorded in our web server access log.
- "Preference Data": includes the interface choices you make in the QuantumLight Portal, such as dark mode or a collapsed sidebar, whether you have asked to stay signed in, and the cookie choices you make.
- "Usage Data": includes information about how you interact with our public website, collected through Google Analytics as described in paragraph 3 and in our Cookie Policy, and the anonymous counts of reading on our public playbook pages described in paragraph 3.
- "Marketing and Communications Data": includes your preferences in receiving communications from us, where you have asked to receive them. We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
We do not collect any special category data about you, and we do not knowingly collect any data about children. The QuantumLight Portal is available only to adults acting in a business capacity.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you, including through:
Direct interactions
You may give us your Identity Data, Contact Data and Credential Data by filling in forms or by corresponding with us by post, telephone, email or otherwise. This includes the personal data you provide when you:
register for, or are given access to, the QuantumLight Portal; sign in to, search, read or rate material in the QuantumLight Portal; download or request one of our playbooks; ask us to send you updates; accept our invitation to be introduced to the companies in our investment portfolio; apply for a role with us; report a problem with the QuantumLight Portal; or give us feedback or contact us.
Automated technologies or interactions
As you interact with our public website, we collect Technical and Usage Data about your equipment and browsing, using cookies and similar technologies and our server logs. On the public website this is done through Google Analytics 4 (measurement ID G-H0MWQX733J), which we deploy only where you have consented. On the public playbook pages, which you can read without signing in, our own server also counts which playbooks and sections are opened, for how long, and whether a page is marked helpful. These counts are not kept with any account, cookie or IP address, and nothing is stored on your device for them; a random number that lasts only while you have the site open groups the counts from one visit. Inside the QuantumLight Portal we use no third-party analytics or advertising technology and nothing is stored on your device to measure your reading.
Third parties
We receive Technical and Usage Data from our analytics provider, Google LLC, which is based outside the UK.
Your company or our investment team
Where your name, email address or company is provided to us so that we can create your QuantumLight Portal account, rather than by you, we obtain it from your company or from our own investment records.
Where we invite you to be introduced to the companies in our investment portfolio, the email address and professional networking profile address that we may have filled in for you were obtained from our own records or from the member of our team who invited you. You can correct them before you accept.
4. HOW WE USE YOUR PERSONAL DATA
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of contract: We may use your personal data where it is necessary to perform our contract with you, namely the QuantumLight Portal terms of service.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure experience of our website and the QuantumLight Portal. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Use | Type of data | Legal basis |
|---|---|---|
| To create and secure your QuantumLight Portal account and sign you in. | (a) Identity (b) Contact | Performance of a contract with you. |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries. | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you). |
| To protect the QuantumLight Portal and our website from abuse and to keep them secure | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | Necessary for our legitimate interests in protecting our systems and the material on them from unauthorised access, and in investigating misuse |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To understand how the QuantumLight Portal is used: which materials are read and which are ignored, whether the founders we onboard reach the material we built for them, and whether reading is sustained or glancing, so that we can decide what to improve and what to retire; and to decide whether a member of our team should follow up with you personally about material you have or have not read | (a) Identity (b) Contact (c) Profile (d) Reading (e) Search (f) Usage (g) Marketing and Communications (h) Technical | Necessary for our legitimate interests in understanding whether the QuantumLight Portal is used and is useful, in deciding what to build and what to retire, and in supporting the founders we have backed. You can object to this at any time: see paragraph 9. We will retain this data in a form that identifies you for 90 days, after which we keep only aggregated figures. |
| To show you your own progress through the QuantumLight Portal: which material you have read, which you have marked helpful, and where you had got to, so that the Portal opens where you left it and you can see what you have covered | (a) Identity (b) Reading | Necessary for our legitimate interests in providing a Portal that remains usable over time rather than one that resets. We keep this for as long as you have an account, because a progress record that expires is of no use to you. You can clear it yourself at any time, or object, from Privacy choices, under Privacy in your account menu. |
| To investigate and fix a problem you report with the QuantumLight Portal | (a) Identity (b) Contact (c) Technical (d) Problem Report | Necessary for our legitimate interests in keeping the QuantumLight Portal working. We keep a report for as long as we need it to investigate and fix the problem. |
| To keep a record of the cookie choices you make | (a) Preference | Necessary to comply with a legal obligation (UK GDPR Article 7(1) and PECR). We keep these records to show what you chose |
| To use data analytics to improve our website and to measure how effective our communications are | (a) Technical (b) Usage | Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform how we communicate with founders and prospective founders) |
| To introduce you, at your request, to the companies in our investment portfolio: to hold your details in our pool of candidates, to match them against roles at those companies, to pass your details to their founders, and to contact you about those roles | (a) Contact (b) Candidate | Consent, given when you accept our invitation, which you may withdraw at any time by emailing dpo@quantumlightcapital.com. When you withdraw it we delete your Candidate Data and make no further introductions. |
| To send you updates about our playbooks, events and research, where you have asked to receive them | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Consent, which you may withdraw at any time. We will not send you any communication other than service messages about the QuantumLight Portal unless you have asked us to. |
Direct marketing
You will receive marketing communications from us only if you have asked to receive them. We will not add you to a marketing list because you have a QuantumLight Portal account.
Third-party marketing
We do not share your personal data with any third party for that third party's own marketing purposes.
Opting out of marketing
You can ask us to stop sending you marketing communications at any time by following the unsubscribe link in any communication we send you or by emailing dpo@quantumlightcapital.com.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative purposes, for example sign-in codes, notices of changes to the QuantumLight Portal terms of service or to this privacy policy, and messages checking that your contact details are correct.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy at https://quantumlightcapital.com/cookie-policy.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data where necessary with the parties set out below for the purposes set out in the table under "Purposes for which we will use your personal data" in paragraph 4 above.
- Our hosting and infrastructure provider, Amazon Web Services, which hosts the QuantumLight Portal in the United Kingdom; the provider that delivers your one-time sign-in codes by email; Google LLC, in respect of analytics on our public website where you have consented; our documentation platform provider where playbook content is synchronised; and our auditors, insurers and professional advisers.
- The companies in our investment portfolio, where you have accepted our invitation to be introduced to them: we pass them your Candidate Data so that their founders can consider you for roles. Once we have introduced you, each company handles your personal data under its own privacy notice. You can ask us at any time to stop sharing your details: see paragraph 9.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
The QuantumLight Portal and its database are hosted in the United Kingdom. Two flows leave the UK, and both are described below.
- Analytics. Where you consent to analytics on our public website, Google Analytics sends your IP address and a randomly generated identifier to Google LLC in the United States.
- Sign-in codes. Where you receive a one-time sign-in code by email, it passes through a communications provider that may route it outside the United Kingdom. Whenever we transfer your personal data out of the UK to a country whose laws do not provide the same level of data protection as UK law, we ensure that a similar degree of protection is afforded to it by putting in place one of the safeguards described below.
Where personal data is transferred out of the UK we rely on the UK International Data Transfer Agreement, or the UK Addendum to the European Commission's standard contractual clauses, or (for transfers to the United States) the UK Extension to the EU-U.S. Data Privacy Framework where the recipient is certified. Where personal data of individuals in the European Economic Area is transferred out of the EEA, we rely on the European Commission's adequacy decision for the EU-U.S. Data Privacy Framework where the recipient is certified, or on the Commission's standard contractual clauses. To obtain a copy of the safeguards we use, please contact us at dpo@quantumlightcapital.com.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
You sign in with a passkey or a one-time code sent to your email address, so we hold no password for you. Access to the QuantumLight Portal database is limited to named individuals and is logged.
8. DATA RETENTION
How long will you use my personal data for? The reading records we use for our own analysis — which playbooks you opened, when, for how long, which sections you read, how far down you read and whether you finished — are held in a form that identifies you for 90 days. After 90 days we keep only aggregated figures, which do not identify you. The anonymous reading counts from our public playbook pages are kept for 90 days in the same way, and then only as totals.
Your read marks, your helpful marks and your reading position are different: they are the progress record the Portal shows back to you, so we keep them for as long as you have an account. You can clear them yourself at any time from Privacy choices, under Privacy in your account menu.
Search Data is held for 90 days. After that we keep only, for each term searched at least three times, a count of how many times it was searched and how many of those searches found results or opened a page, with nothing else attached; those counts are deleted after 24 months.
A problem report is kept for as long as we need it to investigate and fix the problem. Your account details are held for as long as you have an account and for 12 months afterwards. Web server access logs are held for 30 days. Candidate Data is held for as long as you remain in our pool of candidates; we delete it when you withdraw your consent or ask us to remove you. Analytics data on our public website is retained by Google for the period set in our Google Analytics configuration, currently 14 months.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Object to our use of your Reading Data. Most of what we do with your QuantumLight Portal reading records relies on our legitimate interests. You can object at any time, on grounds relating to your particular situation, from Privacy choices, under Privacy in your account menu, or by emailing dpo@quantumlightcapital.com. Objecting is free, you do not have to give a reason, and it will not affect your access to the Portal or to any material on it. When you object we stop recording your reading against your name immediately, and the records we already hold are folded into our anonymous totals so that they no longer identify you. Your own read marks, helpful marks and reading position are kept, so the Portal still works the way you left it; you can clear those yourself at any time from the same place.
- Withdraw your consent to being introduced to the companies in our investment portfolio, at any time and free of charge, by emailing dpo@quantumlightcapital.com. We will delete your Candidate Data and make no further introductions. This will not affect any introduction already made, and it will not affect your use of the QuantumLight Portal.
- Withdraw your consent to our storing your interface preferences. Separately from the right above, you can withdraw your consent to our storing your interface preferences on your device when you use our website, free of charge, from the Cookie Settings link in the footer of our website. In the QuantumLight Portal your interface choices are kept with your account rather than on your device, and you change them from the Portal's own controls.
- Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph 4 for details of how to object to receiving direct marketing communications).
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information in relation to which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios: If you want us to establish the data's accuracy; Where our use of the data is unlawful but you do not want us to erase it; Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. If you wish to exercise any of the rights set out above, please contact us at dpo@quantumlightcapital.com.
No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to confirm your identity before we act on a request. For QuantumLight Portal users we will normally do this by asking you to re-authenticate through your account rather than by asking for identity documents.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. CONTACT DETAILS
If you have any questions about this privacy policy or about the use of your personal data, or you want to exercise your rights, please contact us in the following ways:
- Email: dpo@quantumlightcapital.com
- Post: Data Protection, Quantum Light Management Ltd, 5th Floor, North Side 7/10 Chandos Street, Cavendish Square, London W1G 9DQ
11. COMPLAINTS
You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection (www.ico.org.uk). If you are in the EEA you may instead complain to the supervisory authority in your country, or to our EU representative. Before doing so, please make sure you have first made your complaint to us.
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We will update this privacy policy when our processing changes, and will tell QuantumLight Portal users by email if we make a material change. This version is dated 13 October 2026 (version 1.1). Version 1.1 names which sections of a page you read, how far you have read it, your helpful marks and problem reports, describes your searches as their own category with their own retention, says what happens when you object to our use of your reading records, keeps a record of the cookie choices you make, lets you withdraw your consent to our storing your interface preferences, adds the safeguards for transfers out of the European Economic Area, and removes passwords, sign-in codes by SMS and Google Tag Manager, none of which the QuantumLight Portal uses. Version 1.0 was dated 11 September 2026.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
13. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Previous versions
Version 1.0 of the Website and QuantumLight Portal Terms of Service, first published on 10 September 2026 and in force until 21 September 2026, is kept at https://quantumlightcapital.com/terms-of-service/2026-09-11.
Version 1.0 of the QuantumLight Portal privacy notice, in force from 11 September 2026 until 13 October 2026, is kept at https://quantumlightcapital.com/investor-privacy-notice/2026-09-11.
Version 1.0 of the Website and QuantumLight Portal Privacy Policy, in force from 11 September 2026 until 13 October 2026, is kept at https://quantumlightcapital.com/privacy-policy/2026-09-11.
The privacy notice published on quantumlightcapital.com before these documents took effect on 11 September 2026 is kept at https://quantumlightcapital.com/privacy-policy/2026-09-10. It governed personal data collected up to that date, and is published so that you can see what you were told when you gave it to us.