Anti-Bribery and Corruption Policy

Upside VC

Introduction

Upside VC (the Firm) strongly values its adherence to and reputation for ethical behaviour, financial probity and reliability. It also fully recognises that the breach of any of these may also amount to the commission of a crime.  Its aim therefore is to limit its exposure to bribery by: 

• Setting out a clear anti-bribery policy; 
• Training all consultants and clients, so that they can recognise and avoid the use of bribery by themselves and others; 
• Encouraging its consultants and clients to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately; 
• Notifying all third parties that Upside VC engages with its policy and has zero tolerance of bribery and/or corruption. 
• Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution; 
• Taking firm and vigorous action against any individual(s) involved in bribery. 

The Policy

Upside VC prohibits the offering, the giving, the solicitation, or the acceptance of any bribe, whether cash or other inducement:

• to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company; 
• by any individual consultant, agent or other person or body acting on Upside VC’s behalf; 
• in order to gain any commercial, contractual or regulatory advantage for Upside VC in a way which is unethical; or 
• in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual. 

Further Clarification

Upside VC recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Firm or of the person or body employing or contracting with them or whom they represent. 

This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:

• normal and appropriate hospitality;
• the giving of a gift for a corporate reason or at another special time, as long as it is reported in the proper manner within the Firm on the gifts register.

Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the local senior manager with responsibility for this policy before proceeding. If necessary, guidance should also be sought from the Compliance Officer.

Consultants and Principles Responsibility within Upside VC

The prevention, detection and reporting of bribery is the responsibility of all consultants throughout Upside VC. Suitable channels of communication by which consultants or others can report confidentially any suspicion of bribery will be maintained via the Firm’s anti-corruption reporting procedures.

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Useful resource: www.transparency.org.uk for the Transparency Index

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A fuller Policy and Procedures outlining all the principles of the Bribery Act 2010 and the relevant FCA rules and guidance can be requested from the Compliance Officer of Sturgeon Ventures LLP, of whom Upside VC is an Appointed Representative firm, by emailing sw@sturgeonventures.com. 

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DATA PROTECTION PRIVACY STATEMENT

Upside VC (company number: 14925725), [Amelia House, Crescent Road, Worthing, West Sussex, BN11 1QR] (us or we) is committed to ensuring that your privacy is protected, and all data collected by us will be processed in accordance with this Data Protection Privacy & Cookies Policy. Please read this statement carefully to ensure you understand our views and practices regarding your personal data and how we will treat it.

For the purposes of the Data Protection Act 2018 (DPA) and/or in the Regulation (EU) 2016/679 (General Data Protection Regulation) as amended) (together “Data Protection Laws”), the data controller is Sam Uwins. We can be contacted at [insert contact email and phone number]. Upside VC is registered with the Information Commissioner's Office (ICO) with registration reference (C141056).

By visiting our Site or by providing us with information you are accepting the practices described in this Data Protection Privacy Statement.

What information we process
Personal information (or ‘personal data’) means any information that can identify a living person, whether directly or indirectly. We collect and process a variety of personal information about individuals, as detailed below.

1.1 We process the personal information of our clients and the individuals who work for our clients. As such, if we act for you (or the entity you work for) we will process your:
personal demographics such as your title name, date of birth, residential and employment details;
financial information, such as income and expenditure and your financial history;
other customer due diligence information, which may include criminal convictions data; and
contact details and records of all correspondence with you.

1.2 This information will primarily be collected from you directly, but may also be collected from third parties whom we contact to obtain information about you, such as the entity you work for, previous employers if references are being sought and corporate search engines such as LinkedIn.

1.3 We may also obtain personal data belonging to members of your family. Where we do that, you must notify them that you are providing their information to us and draw their attention to this statement.

1.4 We will process this information when considering the application to become a client and retain it (in accordance with our retention procedures) whether the application is successful or not. Note that we require personal information in order to consider an application and if it is not provided we will not therefore be able to consider the application.

1.5 If you are a client or contact, we will process the customer due diligence information that was collected. This may include:
personal demographics such as your title name, date of birth, residential and employment details, as well as relationships with PEPs or family members where relevant to assessment process;
financial information, such as income and assets;
your current and previous employment and educational experience/background;
your relevant financial services related experience, resources and sources of wealth; and
criminal convictions data (if applicable).

1.6 We will process personal information about you that we have collected from our website [insert web address]. We collect information when you submit information to us directly using the contact form on our Website. We also collect information automatically when you use the Website. This includes technical information including the internet protocol (IP) address used to connect to the internet, information about your visit including the full uniform resource locators (URL) clickstream and your search history on our Website.

How do we use your personal data?
2.1 When you provide us with your information in making an enquiry we will use it for the purpose of administering your query and responding to you. We have legitimate interests in processing your personal data in this way, since if we do not process your data we will be unable to do this.

2.2 When we collect information from you (or the entity you work for) in the provision of our services, we use it in order to consider your application (which will include verifying your identity) and to provide services if we are engaged to do so. We have legitimate interests in processing your personal data in this way, namely in order to assure ourselves that we are able to conduct business with you (or the entity you work for) and tailor our services as may be necessary. If we contract with you directly, the processing may be necessary for the performance of the contract that we have in place with you, or to take steps at your request before entering into the contract.  Where we process criminal convictions data in the application process, this processing is necessary for reasons of substantial public interest, namely in order to comply with our regulatory requirements relating to unlawful acts and dishonesty (Data Protection Act 2018, Part 2, Paragraph 12).

2.3 If you are a client, we will process the customer due diligence information. This processing is necessary to ensure compliance with our legal obligations and for the purposes of our legitimate interests in ensuring that our clients have acted diligently and are treated appropriately. If criminal convictions data was collected about you in the customer due diligence process, this information will be held by us on the basis that the processing is necessary for reasons of substantial public interest, namely in order to comply with our regulatory requirements relating to unlawful acts and dishonesty [delete if not applicable].

2.4 Unless you provide your consent by ticking the opt-in box provided on the contact form, we will not send you marketing information that you have not requested. Any consent that you provide can be withdraw at any time by clicking “unsubscribe” on any marketing email we send to you, or by emailing us at [insert]. Withdrawing your consent does not affect the lawfulness of any processing which occurred prior to the withdrawal of consent.

2.5 We may also process your personal information collected on our Website on the basis of our legitimate interests in providing you with the best possible service:
to ensure that the content from our Website is presented in the most effective manner for you and your computer;
as part of our efforts to keep our Website safe and secure; and
for internal analytical and statistical purposes.
Such data processing will normally be conducted on an anonymous basis.

Disclosure of Information
3.1 We will only supply your personal information to a third party:

3.1.1 where we need to verify your identity before we provide services to you (or the entity you work for) in which case we will share your information with CRAs and the DBS. The identities of the CRAs and the ways in which they use and share personal information are explained in more detail in the CRA Information Notice which can be found at: www.callcredit.co.uk/crain; www.equifax.co.uk/crain; www.experian.co.uk/crain/index.html;
3.1.2 where we need to share the information to provide a product, or a service requested by you;

3.1.3 where we need to send the information to persons or organisations who work on our behalf to provide a product or service to you, in which case such persons or organisations may only use this information in order to provide such product or service and not for any other purpose;

3.1.4 companies which perform marketing services on our behalf or with whom we have joint marketing agreements, where we have your consent to share the information;

3.1.5 if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets; or

3.1.6 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, or to protect the rights, property or safety of our company, our clients or others, including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your information
4.1 The data that we collect from you is stored in the UK, but data may also be processed by staff operating outside the EEA who work for us or for one of our suppliers for the purposes set out above only. In order to ensure that any third party treats your personal data in a way which is consistent with UK and EU laws on data protection, we have put in place agreements with those third parties which contain provisions approved by the EU for protecting personal data.

4.2 We will retain your information for six years, after which time it will be destroyed.

IP addresses and cookies
5.1 When you use our Website we may obtain information about your computer and general internet usage, including your IP address, operating system and browser type, for system administration purposes.

5.2 Cookies contain information that is transferred to your computer’s hard drive. Cookies allow us to tailor our Website to your needs by gathering and remembering information about your usage and preferences.

5.3 In particular, cookies enable us:

5.3.1 to gather information on IP addresses and pages visited;
5.3.2 to analyse trends;
5.3.3 to administer the website;
5.3.4 to track users’ movements on the website; and
5.3.5 to undertake statistical analysis.

5.4 Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Website or accessing certain parts. Our system will issue cookies when you access our Website, unless you have adjusted your browser settings so that it will refuse cookies.

5.5 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

5.6 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

5.7 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.

5.8 The below provides more information about the cookies we use and why: [AR to insert details of their own cookies]

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Google Analytics

This is a web analytics service provided by Google Inc which uses cookies to show us how visitors found and explore our site, and how we can enhance their experience. It provides us with information about the behaviour of our visitors (eg how long they stayed on the site, the average number of pages viewed) and also tells us how many visitors we have had.

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Windows 10 uses the Microsoft edge
Chrome, Firefox etc
Windows 10 uses the Microsoft edge browser by default unless you install Chrome, Firefox etc

5.9 Most browsers allow you to refuse to accept cookies, for example
in Firefox (version 51) you can block all cookies by clicking “tools”, “options”, “privacy”, selecting “use custom settings for history” from the drop-down menu, and unticking “accept cookies from sites”:
in Chrome (version 55), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading; and
in Internet Explorer (11) you can turn “Cookies” off by opening Internet Explorer, click Internet options and select the “Privacy” tab. Under “Settings” move the slider to the top or bottom to decline or allow “Cookies” by selecting high or low and then press “apply”.

5.10 You can delete cookies already stored on your computer, for example:
in Firefox (version 51), you can delete all cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”.
in Chrome (version 55), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”; and

5.11 In Internet Explorer (11) you can select the safety button and then select Delete Browsing History. Then select the check box next to “Cookies”. Select the “preserve favourites” website data check box if you don’t want to delete the “Cookies” associated with website in their favourites list. Select delete.

Links to other policies and websites
6.1 This statement does not cover your use of provision of data to and collection of your data on any website other than the Website.

6.2 Our Website may from time to time contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or policies. You should always check these policies before you submit any personal data to any third-party website.

Your rights in respect of your information
The GDPR gives you several rights in respect of your personal data, including:

7.1 Right to access
7.1.1 You have the right to access the information we hold about you. We may request proof of your identity before sharing such information.

7.2 Right to rectify your personal data
7.2.1 If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information.

7.3 Right to be forgotten
7.3.1 You may ask us to delete information we hold about you in certain circumstances. It may not be possible for us to delete all of the information we hold about you where we have an ongoing relationship, however please contact us and we will do our best to assist with your request.

7.4 Other rights
7.4.1 In addition to the above, you may also ask us to stop or restrict processing of the information we have about you. You may also ask us to transfer your personal information to a third party in certain circumstances. If you would like any other information on this aspect of your rights or would like to exercise them, please contact us at [email address]

Contact
8.1 If you have any questions, want to exercise any of your rights or make a complaint, please contact us using the details at the beginning of this statement.

8.2 If we are unable to resolve your complaint you may contact the Information Commissioner’s Office at the Exchange Tower, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tel: 0303 123 1113.

Changes to this Data Protection Privacy Statement
This statement may be reviewed and amended from time to time. As a result of improvements we make to our services, changes in the law or developments in technology, we may change the information we hold about you, the method and purposes for which we process such information. If we make any substantial change in the way in which we use your personal information we will notify you by email.

Law and Jurisdiction
Your use of the Website is subject to the laws of England and Wales and the exclusive jurisdiction of the English courts regarding any disputes that may arise under it.

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This page (together with the documents referred to on it) tells you the Terms and Conditions of Use (Terms of Use) on which you may make use of this website upsd.vc (the Website).

Please read these terms of use carefully before you start to use our Website. By using our Website, you indicate that you accept the Terms of Use and that you agree to abide by them. If you do not agree to the Terms of Use, please refrain from using our Website.

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1. Information about us 
   1. We are a Limited Company registered in England and Wales at Companies House under the Upside VC (we, us, our, and Upside VC). Our registered office is at Amelia House, Crescent Road, Worthing, West Sussex, BN11 1QR  and our company number is 14925725.
   2. We are an Appointed Representative of Sturgeon Ventures LLP whose FRN # 452811, which is authorised and regulated by the Financial Conduct Authority (the FCA) and entered on the Financial Services Register with the FRN #  . 
   3. If you have any queries about the Website or any information contained on it, please contact us by email at info@upsd.vc.
2. Accessing our website 
   1. Access to our Website is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our Website without notice. From time to time, we may restrict access to some or all of our Website. We will not be liable if for any reason our Website is unavailable at any time or for any period.
   2. If you breach these Terms of Use, your permission to use the Website terminates immediately and you must immediately destroy any downloaded or printed extracts from the Website.
   3. You are responsible for making all arrangements necessary for you to have access to our Website.
   4. By accessing our Website any person using your computer agrees to be bound by these Terms of Use. You are responsible for ensuring that all persons who access our Website through your internet connection and on your computer are aware of these Terms of Use and that they comply with them. You are also responsible for the use of our Website by any person using your computer.
3. Disclaimer 
   1. Nothing on this Website is intended, nor should it be taken, to create any legal or contractual relationship. Any transmission, downloading or sending of any information from the Website does not create any contractual relationship.
   2. The content of the Website is designed for information purposes only. Neither the information nor any opinions stated in the Website constitutes a solicitation or offer by Upside VC to buy or sell any securities or other financial instruments or to provide any investment advice. 
   3. The provision of investment services may be restricted in certain jurisdictions. It is your responsibility to acquaint yourself with any local laws and restrictions on the usage of this Website and the availability of any services described on it. The information on this Website is not intended for distribution to or use by any personal entity in any jurisdiction or country where such distribution would be contrary to local law or regulation. The Services are available only to persons in the United Kingdom. The Services are not available to United States persons directly, unless introduced to Upside VC by a FINRA registered broker or their United States attorney. 
   4. Nothing in this Website may be published in the press or elsewhere without permission of Upside VC. 
   5. Upside VC does not provide legal or tax advice. Clients of Upside VC and viewers of this Website are encouraged to consult their own legal and tax advisers before making any investment decision. Private companies in all jurisdictions and potential investors should take independent legal and taxation and investment advice before proceeding with any type of fund raising activity. 
   6. While we endeavour at all times to ensure information on our Website is clear, fair and not misleading at the date of publication, we do not hold the information as impartial and it should not be viewed as wholly objective. Information on this Website is based on sources that we believe to be reliable but we give no undertaking that it is accurate or complete and Upside VC cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose or at all. 
   7. The contents of this Website are subject to change without notice and Upside VC is under no obligation to report updates or amendments or keep information accurate. 
   8. This Website is controlled and operated by Upside VC in the United Kingdom. We make no representations that materials in the Website are appropriate or available for use in other locations. Those who choose to access the Website from other locations do so at their own risk and are responsible for compliance with all applicable laws.
4. Intellectual property rights 
   1. This Website, its contents, any materials downloaded, and all intellectual property pertaining to or contained on the Website (including but not limited to copyrights, patents, database rights, graphics, designs, text, logos, trade dress, trademarks and service marks) are owned by or licensed to us and/or from third parties and all rights, title and interest in them shall remain the property of Upside VC and/or such third parties (collectively, the Content).
   2. The Content is protected by copyright, patent and trademark laws, and various other intellectual property rights and unfair competition laws.
   3. You are permitted to print copies and download extracts of the content on the Website for your own personal use for information purposes only, and may draw the attention of others within your organisation to material posted on the Website, subject to the following conditions:some text
      1. our status (and that of any identified contributors) as the authors of material on our Website must always be acknowledged;
      2. you must not modify in any way the paper or digital copies of any materials you have printed off or downloaded, and you must not use any illustrations, photographs, video or audio sequences or graphics separately from any accompanying text;
      3. you must not duplicate, copy, publish, modify, create derivative works from, participate in the transfer of, post on the internet, or in any way distribute, redistribute or exploit our Website, or any portion of the Website, for any public or commercial use without our express prior written consent;
      4. you must not otherwise use any part of the Website in contravention of these Terms of Use.
   4. If you print off, copy or download any part of the Website in breach of these Terms of Use, your right to use the Website will cease immediately and you must, at our option, return to us or destroy any copies of the materials you have made.
5. Unlawful or prohibited use 
   1. We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses, trojans, worms, logic bombs or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Website or to your downloading of any material posted on it, or on any website linked to it.
   2. You must not misuse our Website by knowingly or recklessly introducing viruses, trojans, worms, logic bombs or any other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our Website, the server on which our Website is stored or any server, computer or database connected to our Website. You must not attack our Website via a denial-of-service attack or a distributed denial-of service attack.
   3. Any such unauthorised use of our Website may give rise to a claim for damages and/or be a criminal offence under the Computer Misuse Act 1990. We will report any such activity to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Website will cease immediately and without further notice.
6. Privacy
   1. Our Data Protection Privacy Statement applies to use of our Website, and its terms are made a part of these Terms of Use by this reference.  A copy of this statement may be obtained from our Compliance Officer.
   2. Additionally, by using our Website, you acknowledge and agree that internet transmissions are never completely private or secure. You understand that any message or information you send to our Website may be read or intercepted by others, notwithstanding our efforts to protect such transmissions. We are not responsible for any messages which are lost, altered by third parties or intercepted and we will not be liable to you or anyone else for any damages or otherwise in connection with any message sent by you to us or by us to you via the internet. 
   3. Our Website makes use of cookies. Cookies are files which our server uses to identify your computer. Cookies cannot identify which person is using the computer. The cookies we use record which parts of our Site are being visited and for how long. 
   4. The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 requires that cookies can only be placed on a computer where the user has given their express consent. You can choose to accept or decline cookies when you first access our Site. We require you to indicate your choice via an automated "pop-up" box, which explains the cookies we use and what we use them for. Most web browsers automatically accept cookies, but you can also usually modify your browser setting to decline cookies if you prefer. If you decline to accept our use of cookies or set your web browser to decline their use, you will have only limited functionality in the use of our Site. Our Data Protection Privacy Statement contains further guidance on our use of cookies.
7. Exclusion of liability 
   1. The material displayed on our Website is provided without any guarantees, conditions or warranties as to its accuracy, originality or completeness. To the extent permitted by law, we and third parties connected to us hereby expressly exclude:some text
      1. all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity;
      2. any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our Website or in connection with the use, inability to use, or results of the use of our Website, any websites linked to it and any materials posted on it, including:some text
         1. loss of income or revenue;
         2. loss of business;
         3. loss of profits or contracts;
         4. loss of anticipated savings;
         5. loss of data;
         6. loss of goodwill;
         7. wasted management or office time; and
         8. any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.
      3. In jurisdictions which do not allow the exclusion or limitations of certain types of liability, Upside VC's liability will be limited to the maximum extent permitted by law.
8. indemnity
   1. By using our Website, you agree to indemnify and hold harmless Upside VC from and against any and all losses, claims, damages, costs and expenses (including reasonable legal and accounting fees) that Upside VC may become obliged to pay, arising or resulting from your use of our Website, the Content, or your breach of these Terms of Use. Upside VC reserves the right to assume or participate, at your expense, in the investigation, settlement and defence of any such action or claim. 
9. Links to third party websites
   1. Our Website may contain links to websites and resources maintained by third parties. These links are provided for your information only. We have no control over the contents of those websites and resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. We are not responsible for the content, availability or privacy policies of those sites, and the existence of such links should not be considered an endorsement or recommendation of those sites or of any product or service offered on those sites or of any party that is associated with those sites.
   2. Please note that other websites and resources linked to on our Website may be governed by separate terms and conditions, including privacy policies. You should refer to the applicable terms and conditions of those websites and resources before using them and you should direct any questions or comments about the linked website or resource to the appropriate website provider.
10. LINKING TO OUR WEBSITE
    1. You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. 
    2. You must not establish a link from any website that is not owned by you.
    3. Our Website must not be framed on any other website, nor may you create a link to any part of our Website other than the home page. We reserve the right to withdraw linking permission without notice.
    4. If you wish to make any use of material on our Website other than that set out above, please address your request to info@upsd.vc. 
11. Revision of terms
    1. We may revise these Terms of Use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our Website.
12. Jurisdiction and Applicable law 
    1. The English courts will have non-exclusive jurisdiction over any claim arising from, or related to, a visit to our Website. We retain the right to bring proceedings against you for breach of these conditions in your country of residence or any other relevant country.
    2. These terms of use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales.
13. Miscellaneous
    1. Any failure by Upside VC to exercise any rights or enforce any of these Terms of Use shall not constitute a waiver of such rights or terms.
    2. If any provision of these Terms of Use or their application in a particular circumstance is held to be invalid or unenforceable to any extent, the remainder of these Terms of Use, or the application of such provision in other circumstances, shall not be affected thereby, and each provision of these Terms of Use shall be valid and enforced to the fullest extent permitted by law.
    3. These Terms of Use (together with any documents referred to in them) constitute the entire agreement between you and Upside VC with regard to your use of our Website, and any and all other written or oral agreements or understandings previously existing between you and Upside VC with respect to such use are superseded and cancelled.
14. Your Concerns
    1. If you have any concerns about any material which appears on our Website, please contact info@upsd.vc.

Upside VC Limited FRN# 1004247 is an Appointed Representative Firm of Sturgeon Ventures LLP which are authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom FRN#452811