PRIVACY POLICY

1. Introduction

This Privacy Policy explains how we collect, use, store, and protect personal information when you interact with our website or invest in any scheme of our Category III Alternative Investment Fund registered with SEBI. By using this website, you agree to the practices described here.

2. Information We Collect

We may collect information in the following categories:

  • Identity details - name, PAN, passport, KYC documents
  • Contact details - email, phone number, address
  • Financial and regulatory information - bank details, investment commitments, FATCA/CRS data
  • Website usage data - IP address, device information, browser type, and analytics data
  • Documents shared voluntarily - forms, queries, or submissions made through the website

3. How We Use Your Information

Your information is used for:

  • Investor onboarding, KYC/AML checks, and regulatory compliance
  • Managing commitments, capital calls, distributions, and investor communication
  • SEBI mandated reporting and disclosures
  • Improving website performance and security
  • Responding to queries submitted through the website
  • Internal governance, audit, and record keeping
We do not sell your personal information.

4. Sharing of Information

We may share information with:

  • SEBI and other regulators, where required
  • Custodians, fund administrators, auditors, and service providers
  • Banks, brokers, and intermediaries involved in fund operations
  • Legal or tax authorities, when mandated by law
All third party partners operate under confidentiality and data protection obligations.

5. Data Security

We use administrative, technical, and physical safeguards to protect your information, including:

  • Encryption and secure servers
  • Access controls and monitoring
  • Vendor due diligence and confidentiality agreements
  • Incident response protocols
While we take reasonable measures, no online system is completely risk free.

6. Data Retention

We retain personal data for as long as required under:

  • SEBI AIF Regulations
  • PMLA and KYC record keeping rules
  • Tax and audit laws
  • Contractual obligations with investors

7. Your Rights

Subject to applicable law, you may request:

  • Access to your personal information
  • Correction of inaccurate or outdated information
  • Withdrawal of consent (where applicable)
  • Deletion of data, where legally permissible
  • Information on how your data is processed
Requests may be limited where retention is required by law or regulation.

8. Cookies and Website Analytics

Our website may use cookies or analytics tools to:

  • Improve user experience
  • Monitor website performance
  • Enhance security
You may disable cookies through your browser settings, though some features may not function optimally.

9. Cross Border Transfers

If information is transferred outside India (for example, to global service providers or investors), such transfers comply with the Digital Personal Data Protection Act, 2023 and contractual safeguards.

10. Contact

For privacy related questions or requests, you may contact our Compliance Officer or Data Protection Officer at the details provided in our fund documents or on this website.

11. Updates to This Policy

We may update this Privacy Policy to reflect changes in law or fund operations. Updates will be posted on this page with the revised effective date.