Legal
Submission Terms & Privacy Notice
The Pitch Desk — ACTS VentureLabs · Alternative Circle
Effective date: 25 May 2026
1. Introduction
1.1This document sets out the terms on which Alternative Circle Limited (“Alternative Circle”, “we”), through The Pitch Desk available at this site (the “Service”), receives pitches, ideas, business plans, decks and other content from founders and members of the public (“Submitters”), and the terms on which personal data submitted via the Service is collected, processed and stored.
1.2The Pitch Desk is the idea-intake channel for ACTS VentureLabs. Alternative Circle Limited, a company incorporated in Kenya, is the data controller of personal data collected via the Service.
1.3By ticking the consent box and submitting, the Submitter accepts these Submission Terms and consents to the processing described in this Privacy Notice. If the Submitter does not agree, they should not submit.
2. Definitions
2.1“Alternative Circle” means Alternative Circle Limited and its subsidiaries, affiliates, directors, officers, employees, agents and ventures (including, without limitation, Shika, Oye, and Dhahabu).
2.2“Applicable Law” means the Data Protection Act, No. 24 of 2019 (Kenya); the General Data Protection Regulation (EU) 2016/679 (“GDPR”) to the extent applicable; and any other laws applicable to the processing of personal data by us.
2.3“Submission” means any pitch, idea, deck, business plan, concept or other content submitted via the Service, including the Submitter’s name, email address, company name, pitch text and any uploaded file.
2.4“Personal Data”, “Processing” and “Consent” have the meanings given under Applicable Law.
Part A — Submission Terms
3. Non-Confidentiality of Submissions
3.1The Submitter acknowledges and agrees that any Submission is provided on a non-confidential, non-proprietary basis. We are under no obligation to treat any Submission as confidential.
3.2No confidential relationship, fiduciary duty, partnership, joint venture, agency or employment relationship is created by virtue of any Submission.
3.3The Submitter should not submit information they regard as confidential or a trade secret. To share confidential information, a written non-disclosure agreement must be executed with us beforehand.
4. No Obligation
4.1We have no obligation to read, review, evaluate, respond to, retain or act upon any Submission beyond providing the automated coaching feedback that the paid Service generates. We may engage with, ignore, or delete any Submission in our sole discretion.
4.2No promise, representation or warranty — whether to fund, invest in, partner with, or otherwise engage with the Submitter — is implied by any Submission, any score, or any feedback provided.
5. Independent Development
5.1We are continuously engaged in identifying, evaluating, developing, investing in and operating ventures across many sectors. We may, before or after a Submission, be developing or already engaged in ventures, products, services or ideas that are similar to, identical to, or competitive with the subject matter of a Submission, without reference to or reliance on the Submission.
5.2Nothing in a Submission entitles the Submitter to any compensation, equity, credit, royalty, licence fee, or partnership in respect of any venture we pursue, in the absence of a separately executed written agreement signed by an authorised representative of Alternative Circle.
6. Licence and Rights Granted
6.1To the extent a Submission contains material in which the Submitter holds intellectual property rights, the Submitter grants us a worldwide, royalty-free, non-exclusive, perpetual, irrevocable, sub-licensable and transferable licence to use, reproduce, adapt and process the Submission for the purpose of operating the Service and our investment review.
6.2The Submitter represents and warrants that they have the rights necessary to make the Submission and grant this licence; that the Submission does not infringe any third-party right; and that it is not unlawful, defamatory, or otherwise objectionable.
Part B — Privacy Notice
7. Data Controller
7.1The data controller is Alternative Circle Limited, Nairobi, Kenya, a company incorporated under the laws of Kenya.
7.2Enquiries about the processing of personal data, or to exercise data subject rights, may be made via alternativecircle.com/contact.
8. Personal Data Collected
8.1When a Submitter uses the Service, we collect: name; email address; company name (if provided); the pitch itself (pasted text and/or an uploaded PDF deck); the Submitter’s consent and optional data-use selections; and payment metadata returned by our payment processor (we do not store full card details).
8.2The Service does not request special categories of personal data (such as health, race, religious or biometric data). Submitters should not include such data in a Submission.
9. Purposes & Lawful Basis
9.1Personal data is processed to: (a) receive the Submission and take payment; (b) generate and deliver automated, AI-assisted coaching feedback; (c) conduct our internal investment review; (d) maintain records; (e) detect and prevent fraud, spam and abuse; and (f) comply with legal obligations.
9.2The lawful basis is the Submitter’s consent (Section 30, Data Protection Act, 2019; Article 6(1)(a), GDPR), evidenced by ticking the consent box and submitting; and, where applicable, our legitimate interests in operating and securing the Service (Article 6(1)(f), GDPR).
10. Automated Processing & Recipients
10.1The Submission is processed by a third-party AI model to produce the review and coaching feedback. Personal data is processed via the following processors acting on our behalf: Vercel (hosting), Neon (database), Vercel Blob (deck file storage), Anthropic (AI scoring of the pitch), Paystack (payment processing), Resend (email delivery), Google (reCAPTCHA spam prevention), and Clerk (authentication for our review team).
10.2Personal data is not sold, licensed or traded to any third party for marketing or commercial purposes.
11. Optional Data Uses (Consent Tiers)
11.1By default, a Submission is used only to deliver the Submitter’s coaching feedback and conduct our review. Submitters may additionally opt in to: (a) inclusion of anonymised insights in trend reports; and (b) sharing with co-investors where there is a fit. These opt-ins are voluntary and can be withdrawn at any time.
12. Cross-Border Transfer
12.1Several processors in clause 10.1 are located outside Kenya, primarily in the United States and the EU. Submitting therefore involves the transfer of personal data outside Kenya, necessary to provide the Service and conducted in reliance on the processors’ safeguards and the Submitter’s consent.
13. Payment
13.1The Service requires a per-submission fee, processed by Paystack. The fee covers the cost of the review. Because the review is generated and delivered promptly after payment, the fee is non-refundable once the review has been produced, save where required by Applicable Law.
14. Retention
14.1We retain the Submission and associated personal data for as long as reasonably necessary to deliver feedback, conduct review, and for record-keeping, and thereafter in line with our retention practices and legal obligations.
14.2The Submitter may at any time request deletion of personal data held in connection with their Submission, subject to any overriding legal retention obligation.
15. Data Subject Rights
15.1Where Applicable Law confers rights (including Sections 26 and 40 of the Data Protection Act, 2019 and Chapter III of the GDPR), the Submitter has the right to access, rectify, erase, restrict or object to processing, withdraw consent, obtain data portability, and lodge a complaint with the Office of the Data Protection Commissioner of Kenya (odpc.go.ke) or, for EU/EEA residents, the relevant authority.
15.2To exercise any right, contact us via alternativecircle.com/contact.
16. Security
16.1We take reasonable technical and organisational measures — including reliance on processors providing industry-standard encryption in transit and at rest, and internal access controls — to protect personal data. No internet transmission can be guaranteed fully secure, and the Submitter acknowledges this inherent risk.
17. Changes, Governing Law & Severability
17.1We may revise these terms from time to time; the revised version will be posted here with an updated effective date.
17.2These terms are governed by the laws of Kenya, and any dispute is subject to the exclusive jurisdiction of the courts of Kenya. If any provision is held unenforceable, the remaining provisions continue in full force.
These Submission Terms and Privacy Notice are provided for consent purposes under Section 30 of the Data Protection Act, 2019.