Legal Documentation
Community Investment Capital ("CIC", "we", "us", "our") is [LEGAL ENTITY NAME], a company registered in [JURISDICTION] under company number [NUMBER]. Our registered address is [REGISTERED ADDRESS].
CIC operates a community-governed digital asset investment fund built natively on the XRP Ledger. We provide the CIC website, investor portal, start-up application portal, and careers portal (collectively, the "Services").
For the purposes of the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018, CIC is the data controller of personal data collected through the Services.
We collect personal data directly from you when you use our Services, and in some cases from third-party sources.
| Category | Data Collected | Source |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality, government-issued ID document, photograph | You directly (KYC process) |
| Contact Data | Email address, telephone number, residential address, postcode | You directly |
| Financial Data | Source of funds declaration, investor classification, investment amount, XRP Ledger wallet address | You directly; XRPL blockchain (public) |
| Verification Data | Proof of address, sanctions screening results, PEP status | You directly; third-party screening providers |
| Technical Data | IP address, browser type and version, device type, time zone | Automatically via your browser |
| Application Data | Start-up application details, pitch decks, financial projections; job application details, CV, cover letter | You directly |
| Communications Data | Messages sent via the contact form, support enquiries | You directly |
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Verify your identity and complete KYC/AML checks | Identity, Contact, Verification Data | Legal obligation (UK MLR 2017) |
| Create and manage your investor account | Identity, Contact, Financial Data | Contract performance |
| Enable governance voting via the investor portal | Usage Data, Wallet Address | Contract performance |
| Assess start-up funding applications | Application, Identity, Contact Data | Legitimate interests; contract (if approved) |
| Review job applications | Application Data (CV, cover letter) | Legitimate interests; pre-contract |
| Send fund updates and governance notifications | Contact, Identity Data | Contract performance; legitimate interests |
| Improve platform security | Technical, Usage Data | Legitimate interests |
For KYC/AML purposes, providing personal data is a legal requirement. If you do not provide the required information, we cannot offer you access to the fund.
| Data Type | Retention Period | Reason |
|---|---|---|
| KYC / AML records | 5 years after the end of the business relationship | UK Money Laundering Regulations 2017, Reg. 40 |
| Investor account data | Duration of relationship + 7 years | Regulatory compliance, tax records |
| Start-up applications (rejected) | 12 months after rejection | Legitimate interests (appeals), then deleted |
| Job applications (unsuccessful) | 6 months (12 if future-consideration consent given) | Legitimate interests |
| Contact form enquiries | 2 years | Legitimate interests, audit trail |
| Technical / Usage data | 12 months | Security monitoring |
We do not sell your personal data. We may share data with: KYC/AML verification providers, legal and compliance advisers, regulatory bodies (FCA, HMRC, ICO) where required by law, technology/hosting providers, auditors, and — for anonymised start-up summaries only — the CIC investor community for governance voting.
CIC uses only essential functional storage and does not use advertising or tracking cookies.
| Storage Item | Type | Purpose |
|---|---|---|
cic-theme | localStorage | Stores your dark/light theme preference |
cic_admin_session / cic_investor_session | httpOnly cookie | Authenticates your admin or investor session server-side |
csrf_token | cookie (JS-readable) | Cross-site request forgery protection (double-submit pattern) |
We do not use Google Analytics, Meta Pixel, or any third-party tracking technologies.
Under UK GDPR, you can exercise the following rights by contacting dpo@ciccapital.io.
The CIC Services are intended solely for individuals aged 18 and over. We do not knowingly collect personal data from anyone under 18.
Note that XRP Ledger blockchain data (wallet addresses and transaction records) is stored on a decentralised, globally distributed ledger. Once recorded on-chain, such data cannot be deleted. We minimise the amount of personal data recorded on-chain.
We may update this Privacy Policy from time to time. Material changes will be notified via the investor portal and the "Last Reviewed" date above will be updated.
Community Investment Capital · [Registered Address] · [City] · [Postcode] · United Kingdom