1. Our role

   1. Our Platform connects Investors, Distributors and AMCs and makes it easier to report on the performance of a wide range of Alternative Investment Funds, Portfolio Management Service Funds and other Structured Products (each referred to as "AIF") that are invested only through private placement. Our authorisation from AMCs permits us to provide real time access on the performance of their AIFs in a digital format to Investors and prequalified Distributors. In making our Platform available to users, we are acting as an intermediary between various parties participating in the AIF distribution and reporting process.

   2. Any of the information we collect from you may be used in one of the following ways:

      1. To prove your identity and give you proper access to resources;

      2. To improve our product and services;

      3. To process transactions;

      4. To administer our products;

      5. To create the user account if required and to support the user with any services related to such account;

      6. To update you about the status of the Website and provide you with any agreed assistance or support with respect to the Website;

      7. To verify whether you are entitled to access and use the Website, or any of the services made available through the Website;

      8. To provide any value-added services, either through itself or through a third party service provider in the Website;

      9. To prevent any abuse, trolling or other acts which may be contrary to law or detrimental to the interest of any other user of the Website or person;

      10. To prevent any illegal or unlawful acts or any misuse of the Website by you or any other user of, or by using, the Website;

      11. Analyze how the Website is used, diagnose service or technical problems, maintain security;

      12. To help you to efficiently access the Platform;

      13. Monitor aggregate metrics such as total number of viewers, visitors, traffic, and demographic patterns;

      14. To notify you regarding the account, to troubleshoot problems with the account, to resolve a dispute, to confirm your identity to ensure that you are eligible to use the Website;

      15. For advertising and marketing communications. We may also share non-personal information with third parties such as, our advertisers, sponsors, Investors, advisors, business partners;

      16. To carry out our obligations and to process transactions arising from any contracts entered into between you and us;

      17. Notify you, if possible, in the event we become aware of any breach of the security of information of any user and take appropriate action to the best of our ability to remedy such a breach; and

      18. To enable us to comply with legal and regulatory obligations.

2. Personal Information we collect

   1. If you are an Investor, in order to create an account on our Platform for you, and whilst you continue to use the Platform and related services, we will collect information about you which will include the following:

      1. Profile data: This will include information you provide to us by completing the registration process and other forms on the Platform, or information which we may receive from your AMC or your Distributor in order to create your account and your profile for fulfilling requirements of respective modules on the Platform. This could include (but is not limited to) your name, date of birth, postal address, mobile number, email address and certain tax and regulatory information. We only request and collect profile data that is necessary for us to process in order to operate our user accounts and facilitate reporting of your existing AIFs via the Platform;

      2. Financial data: We will only obtain information about your AIF investments through our Platform from your AMC with whom you have historic investments; and

      3. Transaction data: Details about your communication with your AMC and Distributor in relation to the digital reporting of their AIFs via the Platform.

   2. If you are using our Platform on behalf of a AMC or Distributor, for example as a member of their personnel nominated to access and use our Platform, the profile data we receive in order to set up your account will be limited to your name, email address, and any further relevant corporate details. This information is necessary for us to identify you as the user authorised to use our Platform and the particular AIFs to which your use of the Platform relates.

   3. Contact data: If you contact us via our Platform or our Website, by telephone or by email, we will collect information necessary to identify you and respond to your query.

   4. We also collect technical data about our users, which includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Platform. We collect this personal data by using cookies and other similar technologies. Please see our Cookies Policy for further details.

   5. Usage data collected by us includes information about how you use the Platform, our Website and related services.

   6. We also collect, use and share aggregated data such as statistical or demographic data ("Aggregated Data"). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity, and it cannot be used by us to identify you in any way. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Platform feature or the type of AIF investments.

   7. Other than information listed in Section 2, that we may receive from you, your AMC or Distributor, we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health or genetic or biometric data), or data relating to criminal convictions and offences.

3. How we use your personal information

   1. We may collect, store and use your personal information for fulfilling requirements of respective modules on the Platform:

      1. to create and manage your Platform account and update the records we hold about you from time to time;

      2. to pass onto and liaise with the relevant AMCs and Distributors in relation to the digital reporting of your AIF investments through the Platform;

      3. to manage your expression of interest in new AIF investments from your existing AMCs and/or Distributors;

      4. to provide and administer our Platform, our Website and related services;

      5. to contact you in relation to the use of our Platform, including to provide you reminders on important usage issues, and/or asking you to leave a review or take a survey;

      6. to respond to your queries;

      7. to detect and prevent unauthorised access;

      8. to conduct "know your customer" checks;

      9. to carry out anonymised statistical analysis and market research;

      10. to fulfil our regulatory duties, including our reporting obligations;

      11. to administer our contract with you;

      12. to develop and improve our services and products;

      13. to notify you about changes to our service, our terms and conditions and this Policy;

      14. to manage our business, including for accounting and auditing purposes;

      15. to maintain our IT systems and manage hosting of our data;

      16. to collect and recover money owed to us;

      17. to deal with legal disputes involving you, any relevant AMC and/or Distributor; and

      18. to provide you with information, services that you request from us or which we feel may interest you, when you have consented to be contacted for such purposes.

   2. We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and is permissible under applicable data protection laws. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

   3. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, to the extent permitted by applicable data protection laws.

4. Lawful processing

   1. We are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:

      1. Legitimate interest: Where applicable data protection laws allow us to collect and use personal information for our legitimate interests, and the use of your personal information is fair, balanced and does not unduly impact your rights. We may rely on this ground to process your personal information when we believe that it is more practical or appropriate than asking for your consent, to the extent permissible under applicable data protection laws. For instance, we rely on the legitimate interest ground to process your personal information in order to protect the security of our networks e.g., when we receive external emails, we will scan such emails for any threats. We will also rely on the legitimate interest ground to communicate with you in most instances and if we need to process your personal data to conduct our business in an efficient, compliant, and profitable manner. It may also be necessary to process your personal data for legitimate interest of a third party, such as your AMC or Distributor, to the extent permissible under applicable data protection laws.

      2. Contractual relationship: Where it is necessary for us to process your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract). For instance, we will process your personal data in order to enable you to use our Platform.

      3. Legal obligation: Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject, to the extent permissible under applicable data protection laws.

      4. Consent: Where we ask for your consent for our use of your personal information for a specific purpose. You always have the right to withdraw your consent.

   2. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your personal information. Please contact us at [email protected] if you need details about the specific legal ground we are relying on to process your personal information.

5. Will we disclose your personal data to anyone?

   1. We may need to share your personal information with third parties for fulfilling requirements of respective modules on the Platform:

      1. your relevant AMC or Distributor;

      2. regulators;

      3. law enforcement agencies in connection with any investigation to help prevent unlawful activity; and

      4. in the context of the possible sale or restructuring of our business.

   2. You hereby consent that the disclosure of any personal information or any other information as disclosed under this Policy shall not cause any loss or wrongful gain to you if the same is used for the purposes stated in this Policy.

   3. We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.

6. Keeping your personal data secure

   1. We take generally accepted industry security measures in order to protect the loss, misuse and alteration of the non-public personal information we collect from you, your AMC and/or Distributor; both during transmission and once we receive it. When you enter non-public personal information on our site, we encrypt such information in transit via HTTPS with TLS v1.2. Additionally, all non-public personal information is encrypted when stored on our servers. Finally, passwords are hashed (one-way "encrypted") when stored in our database. You agree that such measures are secure and adequate. While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us on [email protected].

   2. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We are committed to keeping your information secure and using it appropriately. We have adopted this Policy to ensure that your personal information is handled safely and responsibly, and we will:

      1. Respect your trust and the confidential nature of the information you provide through your financial relationship with us;

      2. Limit the collection and use of client information to that which we believe is necessary to serve you, administer our business or tell you about our services;

      3. Restrict employee access to client information to those who need to know in order to provide services to you. They will only process your personal information on our instructions and are subject to a duty of confidentiality and client privacy; and

      4. Maintain appropriate security standards and procedures to protect information about you.

   3. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

7. Transfers of your information

   1. You authorize us to transfer, share, part with your personal information, across borders and from your country and jurisdiction to any other countries and jurisdictions across the world (including India), with our affiliates / agents / third party service providers / partners and other agencies for purposes specified under this Policy or as may be required by law. We will ensure that any transfer of your data will be subject to appropriate safeguards, that will ensure you have appropriate remedies in the unlikely event of a security breach.

8. Changes

   1. In the future, we may make changes to this Policy, without prior notice. If we decide to change our Policy, we will post those changes to this Policy on the Website so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Policy at any time, so please review it frequently. You agree to accept posting of a revised Policy electronically on our Website as actual notice to you. Any dispute over our Policy is subject to this notice.

9. Choice/Opt-Out/Deletion/Correction

   1. AIFMetrics provides all its users with the opportunity to opt-out of receiving non-essential communications from us or on behalf of our partners after setting up an account.

   2. If the user wants to remove the user's contact information from all our lists and Website, please write to us at [email protected] with "unsubscribe" as the subject or any button provided on the Platform, as the case may be.

10. Exclusion

    1. This Privacy Policy does not apply to any information other than such information collected by AIFMetrics through the Platform. This Privacy Policy shall not apply to any unsolicited information the user provides us through this Platform or through any other means. This includes, but is not limited to, information posted to any public areas of the Platform. All such unsolicited information shall be deemed to be non-confidential and AIFMetrics shall be free to use, process or disclose such unsolicited information without any limitations. We make no representation that the content contained on the Platform is appropriate. AIFMetrics's responsibility with respect to such information shall be as per the applicable laws. If the user intends to use or access the Platform from outside territory as may be defined by AIFMetrics from time to time, the user may do so at the user's own risk and is responsible for compliance with the laws of such jurisdiction.

11. Severability

    1. We have taken every effort to ensure that this Privacy Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Privacy Policy. This Privacy Policy does not apply to any information other than the information collected by the AIFMetrics through the Platform.

Waiver
Any rights or remedies under this Privacy Policy may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

Governing law and Jurisdiction
This Privacy Policy is governed by and construed in accordance with the provisions of our Terms of Use.

Questions and Grievances
The user's grievances, questions or feedback regarding this Privacy Policy should be directed to our email id [email protected].