PRIVACY AND COOKIE POLICY

1. Who We Are

This policy explains how Stephens and Partners Ltd ("we", "us", or "our") collects, uses, and protects your personal data. We operate the website at dashawhite.com and the services accessible through it, including the Circle Investor Network and our business consultancy and mentorship practice. The website is promoted under the personal brand and professional name of Dasha White. For the purposes of UK data protection law, Stephens and Partners Ltd is the data controller responsible for your personal data. Our details are: company number 12171696, registered address 128 City Road, London EC1V 2NX United Kingdom. You can contact us through the Contact page.

This policy should be read alongside our Terms and Conditions. Where this policy and the Terms and Conditions differ on the handling of personal data, this policy prevails.

2. The Data We Collect

We collect the following categories of personal data:

Information you give us when you complete a form on our website or engage our services - including your name, contact details, professional background, company information, and any financial or investment information relevant to your application or engagement;

Information about introductions - where you are an investor or founder, the profile and business information you share with us so that we can make introductions on your behalf;

Information we collect automatically when you visit our website - including your IP address, device and browser type, the pages you view, and how you interact with the site. This is collected through cookies and similar technologies, explained in the cookie section below;

Communications - records of correspondence and contact between us.

3. How and Why We Use Your Data

We use your personal data only for the purposes for which it was provided, and on the legal bases under UK GDPR.

4. Marketing Communications

Where you have consented, we may send you newsletters and information about our events and services by email. We will only do this on the basis of your consent.

You can withdraw your consent and unsubscribe at any time, either by using the unsubscribe link in any marketing email or by contacting us through the Contact page. Withdrawing consent will not affect any processing carried out before you withdrew it.

5. How We Share Your Data

We never sell your personal data. We share it only in the following circumstances:

To make introductions - with prospective investors or founders, where you have asked us to make introductions, limited to the information reasonably necessary for them to assess and decide whether to proceed;

With our service providers - trusted providers who support our operations, such as our CRM provider and email and analytics providers, who act on our instructions and under confidentiality obligations.

Where required by law - with regulators, authorities, or courts where we are legally obliged to disclose.

We are responsible only for how we ourselves handle your data. Once information passes to a third party - such as an introduced investor or founder - how they handle it is their responsibility, governed by their own privacy practices.

6. International Transfers

Our network and clients are based in the United Kingdom, the United States, and elsewhere. This means your personal data may be transferred to, stored in, or accessed from countries outside the UK including when we make an introduction to a party in another country, or use service providers based abroad.

Where we transfer personal data outside the UK, we take steps to ensure it is protected to a standard consistent with UK data protection law, for example, by relying on an adequacy decision, or by putting appropriate safeguards such as the International Data Transfer Agreement or Standard Contractual Clauses in place. You can ask us for details of the safeguards that apply.

7. How Long We Keep Your Data

We keep your personal data only for as long as we need it for the purpose it was collected, or as required by law. In practice this means we keep your data for the duration of your membership or engagement, and for a reasonable period afterwards to meet our legal, accounting, and record-keeping obligations.

When we no longer need your data, we securely delete or anonymise it. Where you ask us to delete your data or you withdraw from the network, we will do so within a reasonable period, subject to any legal obligation we have to retain certain records.

8. How We Protect Your Data

We treat your information in good faith and apply appropriate technical and organisational measures to keep it secure and to prevent unauthorised access, loss, or disclosure. While no system can be guaranteed completely secure, we take the protection of your data seriously and review our measures regularly.

9. Your Rights

Under UK data protection law, you have the right to:

access the personal data we hold about you;

ask us to correct data that is inaccurate or incomplete;

ask us to delete your data, where there is no legal reason for us to keep it;

object to, or ask us to restrict, our processing of your data;

withdraw your consent at any time, where we rely on consent;

ask us to transfer your data to another provider (data portability).

To exercise any of these rights, contact us through the Contact page. We will respond within one month.

If you are unhappy with how we have handled your data, you have the right to complain to the Information Commissioner's Office. We would ask that you contact us first so we can try to resolve the matter.

COOKIE POLICY

10. What Cookies Are

Cookies are small text files placed on your device when you visit a website. They help the website function, remember your preferences, and understand how visitors use the site. Similar technologies such as pixels and tags work in the same way, and references to cookies in this policy include them.

11. Your Cookie Choices

When you first visit our website, you will see a cookie banner. Essential cookies, which are needed for the site to work, are always active. Optional cookies are only set after you accept them. You can accept or reject optional cookies with a single choice, and change your choice at any time through the banner or your browser settings.

Rejecting optional cookies will not stop you using the website, though some features may work less smoothly.

12. The Cookies We Use

We use the following categories of cookie:

Some of these cookies are set by third parties, including Google and Meta, who process the data in line with their own privacy policies.

Where we add or change the tools we use, we will update this policy and the categories above will continue to apply.

13. Changes to This Policy

We may update this policy from time to time. The current version will always be published on our website, with the date it last changed shown below. We encourage you to review it periodically.

Last updated: 30th June 2026