--- title: Privacy and AI Policy | Sapphire Business Advisers description: How Sapphire Business Advisers Limited collects, uses and protects your personal data, including our use of AI tools, and your rights under UK data protection law. --- [![Sapphire Business Advisors](https://www.sapphirebusinessadvisers.co.uk/hubfs/Sapphire%20Adviser%202026%20Assets/Sapphire%20Business%20Advisors.svg)](https://www.sapphirebusinessadvisers.co.uk?hsLang=en-gb) [![Sapphire Business Advisors](https://www.sapphirebusinessadvisers.co.uk/hubfs/Sapphire%20Adviser%202026%20Assets/Sapphire%20Business%20Advisors.svg)](https://www.sapphirebusinessadvisers.co.uk?hsLang=en-gb) - [About us](https://www.sapphirebusinessadvisers.co.uk/about) - [Services](https://www.sapphirebusinessadvisers.co.uk/services) - [Why Us](https://www.sapphirebusinessadvisers.co.uk/why-us) - [Contact](https://www.sapphirebusinessadvisers.co.uk/contact) - [Pricing](https://www.sapphirebusinessadvisers.co.uk/pricing) - [Blog](https://www.sapphirebusinessadvisers.co.uk/client-success-stories) ###### Legal # Our Privacy and AI Policy ## Last updated: 29 October 2026 #### **1) Introduction** Sapphire Business Advisers ("we", "us" or "our") is committed to protecting your personal data. This policy explains how we collect, use, store and share personal data when you use our website, contact us or work with us, and the rights you have over that data. For the purposes of the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018, the data controller is Sapphire Business Advisers Limited (company number NI615236), whose registered office is at 28 Deramore Park, Belfast BT9 5JU. Sapphire Business Advisers is a separate business from Sapphire Capital Partners LLP. This policy covers Sapphire Business Advisers only. #### **2) Our details** We are registered with the Information Commissioner’s Office ("ICO") under registration number ZA679535. Questions about this policy or your personal data should be sent to [boyd@sapphirebusinessadvisers.co.uk](mailto:boyd@sapphirebusinessadvisers.co.uk). #### **3) Personal data we collect** We collect personal data that you give us and that is generated when you use our website, including: - your name, job title, company and contact details (email address, telephone number and address), for example when you complete a form, book a call or email us; - information about your business that you share with us to deliver our services, such as pitch decks, business plans, financial forecasts, shareholder and cap table information and details of directors and shareholders; - information needed to prepare SEIS and EIS Advance Assurance applications for HMRC on your company’s behalf; - records of our calls, meetings and correspondence with you; - information about how you use our website, collected through cookies and similar technologies (see section 10); and - if you apply for a role with us, your CV and the information in your application. We may also obtain information from public sources such as Companies House. #### **4) How we use your personal data** - **Responding to enquiries:** to reply to your questions, arrange calls and send you proposals. Our lawful basis is our legitimate interest in responding to people who contact us. - **Providing our services:** to prepare Advance Assurance applications, readiness reviews, valuations and non-executive director support. Our lawful basis is to perform our contract with you or your company. - **Legal and regulatory obligations:** to keep accounting and tax records and meet our other legal obligations. - **Marketing:** to send you news and insights that may interest you. We will only do this with your consent or where the law otherwise allows, and you can unsubscribe at any time. - **Running our business:** to manage our client records, improve our website and services, and protect our legal rights. Our services are aimed at businesses and adults. We do not knowingly collect personal data from children. #### **5) AI and technology tools** We use technology, including artificial intelligence (AI) tools, to help us work efficiently, for example to help draft and check documents, summarise information and organise our work. A member of our team always reviews the output, and we do not make decisions about you that have legal or similarly significant effects using automated processing alone. Some of these tools are provided by third parties. We only use providers that agree to keep your data confidential and secure, we share only the minimum personal data needed, and we do not allow providers to use your data to train their own models where we can prevent it. #### **6) Sharing your personal data** We do not sell your personal data. We share it only where needed, with: - **HMRC**, when we submit an Advance Assurance application or correspond with HMRC on your company’s behalf; - **service providers** who help us run our business, such as our website, customer relationship management (HubSpot), email, document storage and IT providers; - **professional advisers** such as our accountants, lawyers and insurers; - **other Sapphire group businesses**, including Sapphire Capital Partners LLP, only where you ask us to introduce you or otherwise agree; and - **regulators, law enforcement or courts** where the law requires it. Anyone we share data with must keep it secure and use it only for the purposes we specify. #### **7) International transfers** Some of our service providers store or process data outside the UK. Where they do, we make sure your data is protected by UK adequacy regulations, the UK International Data Transfer Agreement or Addendum, the UK-US Data Bridge or another safeguard recognised under UK data protection law. Contact us for more information. #### **8) How long we keep your data** - Enquiries that do not lead to an engagement: up to two years from our last contact. - Client files and engagement records: six years after the engagement ends, to meet tax, accounting and legal requirements. - Marketing preferences: until you unsubscribe, after which we keep a record so that we do not contact you again. - Job applications: up to six months after the recruitment process ends, unless you agree to us keeping them longer. When we no longer need your data, we delete it securely or anonymise it. #### **9) Your rights** Under UK data protection law you have the right to: - ask for a copy of the personal data we hold about you; - ask us to correct inaccurate or incomplete data; - ask us to delete your data; - ask us to restrict how we use your data; - object to us using your data, including for direct marketing; - ask for your data to be transferred to another organisation; and - withdraw your consent at any time, where we rely on consent. To use any of these rights, email [boyd@sapphirebusinessadvisers.co.uk](mailto:boyd@sapphirebusinessadvisers.co.uk). We will respond within one month. If you are unhappy with how we have handled your data, you can complain to the Information Commissioner’s Office at [ico.org.uk](https://ico.org.uk), although we would appreciate the chance to resolve your concern first. #### **10) Cookies** Our website uses cookies and similar technologies to make it work, to understand how visitors use it and, with your consent, for marketing. You can manage your cookie preferences through the cookie banner on our website or in your browser settings. #### **11) Security** We use appropriate technical and organisational measures to protect your personal data against loss, misuse and unauthorised access. #### **12) Changes to this policy** We may update this policy from time to time. The latest version will always be on this page. #### **13) Contact us** If you have any questions about this policy, please email [boyd@sapphirebusinessadvisers.co.uk](mailto:boyd@sapphirebusinessadvisers.co.uk) or write to us at our registered office. × A free, no-obligation 15-minute call with a senior adviser about your raise. We can talk through SEIS and EIS Advance Assurance, a fundraising readiness review, a business valuation or board support, and tell you honestly what you need, and what you do not. Nothing to prepare in advance. Boyd Carson co-founded the Sapphire group in 2009. He spent 12 years in PwC’s M&A due diligence practice in New York, has founded and exited a number of start-ups, and is an Honorary Professor and an Assistant Instructor on Harvard University’s graduate course in venture capital. ## Let’s talk about what you’re working on. Whether you are preparing for a funding round, considering SEIS or EIS advance assurance, need valuation support or are looking for experienced business advice, we would be happy to start with a conversation. [Speak To Adviser](https://www.sapphirebusinessadvisers.co.uk/privacy-and-ai-policy#contact-us-popup) ![SBA Logo](https://www.sapphirebusinessadvisers.co.uk/hubfs/Sapphire%20Adviser%202026%20Assets/SBA%20Logo.svg) Sapphire Business Advisers provides specialist advisory services to early-stage and growing companies, including SEIS and EIS advance assurance, valuations, consulting and non-executive director support. ## Company [About Us](https://www.sapphirebusinessadvisers.co.uk/about?hsLang=en-gb) [Services](https://www.sapphirebusinessadvisers.co.uk/services?hsLang=en-gb) [Contact](https://www.sapphirebusinessadvisers.co.uk/contact?hsLang=en-gb) [Blog](https://www.sapphirebusinessadvisers.co.uk/client-success-stories?hsLang=en-gb) [Why Us](https://www.sapphirebusinessadvisers.co.uk/why-us?hsLang=en-gb) [Pricing](https://www.sapphirebusinessadvisers.co.uk/pricing?hsLang=en-gb) ## Services [SEIS & EIS Advance Assurance](https://www.sapphirebusinessadvisers.co.uk/seis-eis-advance-assurance?hsLang=en-gb) [Business Valuations](https://www.sapphirebusinessadvisers.co.uk/business-valuations?hsLang=en-gb) [Fundraising Readiness Review](https://www.sapphirebusinessadvisers.co.uk/fundraising-readiness-review?hsLang=en-gb) [Non-Exec Director Support](https://www.sapphirebusinessadvisers.co.uk/non-executive-director-support?hsLang=en-gb) ## Contact [Email Us](mailto:boyd@sapphirebusinessadvisers.co.uk) [Schedule A Call](https://www.sapphirebusinessadvisers.co.uk/privacy-and-ai-policy#contact-us-popup) ## Legal [Privacy Policy](https://www.sapphirebusinessadvisers.co.uk/privacy-and-ai-policy) [Terms & Conditions](https://www.sapphirebusinessadvisers.co.uk/terms-conditions?hsLang=en-gb) © 2026 Sapphire Business Advisers. 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