WULPHEN Privacy & Cookie Policy
 

Effective Date: 30th May 2026
 

Wulphen Ltd trading as Wulphen (“Wulphen”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This document comprises two integrated policies: our Privacy Policy (Sections 1–15) and our Cookie Policy (Sections 16 onwards). Both should be read together and alongside our Terms & Conditions.
 

This Policy explains how we collect, use, store, share, and protect personal data when you visit our website, apply for membership, participate in mentorship programmes, attend events, or otherwise interact with Wulphen.
 

PART ONE — PRIVACY POLICY
 

1. Identity & Scope
 

1.1 Data Controller

Wulphen Ltd is the data controller in respect of the personal data described in this Policy.

Our contact details are:
 

Wulphen Ltd
Summit House,
170 Finchley Road,
London,
United Kingdom, NW3 6BP

email us here
 

This Policy applies to:

• www.wulphen.com

• Membership applications

• Founder and mentor onboarding

• Private events and experiences

• Digital communications

• Community platforms and member interactions
   

1.2 Acting as Data Processor

In certain circumstances, Wulphen may act as a data processor on behalf of a partner organisation, sponsor, or strategic partner. Where applicable, Wulphen processes personal data only under the instructions of the relevant controller and in accordance with applicable data protection laws.
 

2. What Data We Collect
 

2.1 Identity & Contact Data

Full name, email address, telephone number, company name, professional role, billing address, and account credentials.
 

2.2 Membership & Application Data

Application responses, professional background, founder stage, revenue information, mentorship interests, referrals, profile details, membership tier information, event attendance, and communication history.
 

2.3 Payment Data

Transaction history, membership status, invoices, and partial payment identifiers. Payment card information is processed securely by third-party payment providers. Wulph does not store full card numbers.
 

2.4 Technical & Usage Data

IP address, browser type, operating system, device identifiers, pages viewed, website interactions, referral sources, and analytics data.
 

2.5 Marketing Data

Communication preferences, subscription status, and engagement with newsletters or announcements.
 

2.6 Sensitive or Confidential Information

Wulphen operates as a private membership society for founders, operators, and mentors. Information shared during applications, introductions, mentorship discussions, or private events may occasionally include commercially sensitive or confidential information.

Such information is treated with a high degree of discretion and access is restricted to authorised personnel strictly on a need-to-know basis. Wulphen does not disclose confidential member information to third parties except where necessary to provide requested services or where legally required.
 

3. How We Collect Data
 

Directly From You
 

Through membership applications, onboarding forms, meetings and discussions (in-person, online, telephone), event registrations, payments, email correspondence, introductions, and community interactions.
 

Automatically
 

Through cookies, analytics tools, website tracking technologies, and platform usage data.
 

From Third Parties
 

From payment providers, referrals, community, event hosts, analytics providers, and community software platforms.
 

4. Purpose of Processing
 

We process personal data to:
 

• Assess membership applications

• Administer member accounts

• Facilitate mentor-founder introductions

• Manage events and private gatherings

• Process payments and subscriptions

• Improve platform functionality and member experience

• Monitor platform security and prevent misuse

• Communicate operational updates

• Send marketing communications where permitted

• Comply with legal and regulatory obligations
   

5. Legal Basis for Processing (UK GDPR / EU GDPR)
 

• Contractual Necessity

• To provide membership services, mentorship access, and events.

• Legitimate Interests

• To improve our services, maintain community integrity, prevent fraud, and operate the business effectively, while balancing these interests against your rights.

• Consent

• For marketing communications, non-essential cookies, and any processing requiring explicit consent.

• Legal Obligation

• To comply with tax, accounting, fraud prevention, and regulatory requirements.
   

6. Data Sharing
 

6.1 Service Providers

We may share data with hosting providers, payment processors, email providers, analytics platforms, CRM systems, and cloud infrastructure providers. These providers process data only under contractual obligations.
 

6.2 Mentors, Founders & Members

Where relevant to facilitate introductions, mentorship relationships, collaborations, or event participation, limited profile information may be shared between approved members.
 

6.3 Professional Advisers

Legal, accounting, compliance, and insurance advisers under confidentiality obligations.
 

6.4 Authorities

Where disclosure is required by applicable law or regulatory obligation.
Wulphen does not sell personal data.
 

7. International Transfers

Wulph may transfer personal data outside the UK or European Economic Area where necessary for operations or service providers.

​

8. Data Retention

We retain personal data only as long as reasonably necessary for the purposes outlined in this Policy.

• Unsuccessful applicant data may be retained for up to 12 months.

• Member data may be retained during membership and for up to 6 years thereafter for legal, accounting, and dispute purposes.

• Marketing data is retained until consent is withdrawn.

• Data is securely deleted or anonymised when no longer required.
   

9. Profiling & Automated Processing

We may use limited profiling to improve member recommendations, event relevance, and mentorship matching.

We do not engage in automated decision-making producing legal or similarly significant effects without human involvement.
 

10. Your Rights
 

Depending on your jurisdiction, you may have the right to:

• Access your personal data

• Correct inaccurate information

• Request deletion of your data

• Restrict or object to processing

• Withdraw consent

• Request portability of your data

• Lodge a complaint with a relevant supervisory authority

UK users may contact the Information Commissioner’s Office: www.ico.org.uk
 

11. Data Security
 

We implement appropriate technical and organisational safeguards including:

• Encrypted data transmission

• Role-based access controls

• Secure cloud infrastructure

• Password management systems

• Multi-factor authentication

• Confidentiality obligations for authorised personnel

• Internal incident response procedures
   

While we take reasonable steps to protect personal data, no system can guarantee absolute security.
 

12. Children

Wulphen services are intended solely for individuals aged 18 or over. We do not knowingly collect data from children.
 

13. Updates to This Policy

We may update this Policy periodically to reflect operational, legal, or regulatory changes.

Material changes may be communicated through email or website notice.
 

14. Governing Law

This Policy is governed by the laws of England and Wales unless otherwise required by applicable local law.
 

15. Contact

Wulphen Ltd
Summit House,
170 Finchley Road,
London,
United Kingdom, NW3 6BP

email us here

 

PART TWO — COOKIE POLICY
 

16. What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help websites function properly, improve performance, remember preferences, and provide analytics information.

Cookies may be session-based or persistent, and may be first-party or third-party cookies.
 

17. Types of Cookies We Use
 

Strictly Necessary Cookies

Essential for website functionality, security, authentication, and session management.

Analytics Cookies

Used to understand website traffic and user behaviour.

Marketing Cookies (If Enabled)

Used for marketing performance and audience measurement.

Functionality Cookies

Used to remember preferences and improve usability.
 

18. Representative Cookies Used
 

Strictly Necessary

• session_id — Maintains secure user session

• cookie_consent — Stores cookie preferences
   

Analytics

• _ga / ga* — Google Analytics tracking

• _gid — User session analytics
   

Marketing (If Enabled)

• _fbp — Meta advertising measurement

• hubspotutk — Visitor tracking and CRM attribution
   

19. Third-Party Cookies

We may use third-party services including analytics providers, payment platforms, CRM systems, embedded media providers, and community tools which may set cookies in accordance with their own policies.
 

20. Managing Cookies

Users may:

• Accept or reject non-essential cookies through the cookie banner

• Modify preferences through website settings

• Configure browser settings to block or remove cookies
   

Disabling certain cookies may affect website functionality.
 

21. Consent Mechanism

Non-essential cookies are activated only after user consent where legally required.
 

22. Updates to This Cookie Policy

We may update this Cookie Policy periodically to reflect changes in technology, legal requirements, or operational practices.

The effective date at the top of this document indicates the latest revision date.

For any questions about this Privacy & Cookie Policy, please contact us here