PRIVACY POLICY
Introduction
The privacy of your Personal Information (defined below) is important to us. We are committed to maintaining and protecting its confidentiality. We only share your Personal Information with others as the law permits or requires.
This privacy policy (“Privacy Policy”) has been designed to help you understand our practices in relation to Personal Information that we collect from individuals (“User”, “you”, “you”, “your”, “your”) who interact with us in India through our public-facing website (“Website”), online platforms, and digital portals, offline channels, including events that we host or participate in, and current or prospective business relationships including investments, and the manner in which we may collect, use, hold, transfer and process the Personal Information you provide.
This includes:
Visitors to our Website and other digital platforms;
Individuals associated with current or potential portfolio companies/investee companies;
Prospective and existing investors;
Individuals interacting with us via emails, phone calls, texts etc.;
Job applicants applying through our Website, email, or other means;
Visitors to our physical office location(s) in India;
Vendors, suppliers, and service providers (including their personnel); and
Any other individuals with whom we communicate for the conduct of our business or in the course of our operations.
This Privacy Policy is an electronic record under the Information Technology Act, 2000 (“IT Act”) and the rules made thereunder. It does not require any physical, electronic, or digital signature by us and has been published in accordance with the provisions of the IT Act and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (“SPDI Rules”), and is to be read in addition to the provisions of the same.
This Privacy Policy forms an integral part of the Terms of Use (“Terms”) which govern your access to and/or use of our Website. For the purposes of this Privacy Policy, unless defined hereunder, all capitalized terms shall have the meaning ascribed to them in the Terms available at http://skegen.com/terms-of-use.
By giving us your Information (defined below) and checking the box below, you confirm that you have the capacity to enter into a legally binding contract as per applicable laws, have read, understood, and agree with the privacy practices described in this Privacy Policy and the collection, storage and processing of your Information in accordance with this Privacy Policy. Please go through this Privacy Policy in detail and contact our grievance officer if you have any questions or require any clarifications.
By checking the box below, you consent to our collection, storage, processing, use, sharing, disclosure, or transfer of your Information as described in this Privacy Policy. We reserve the right to amend, modify, vary, or update this Privacy Policy, at our sole discretion from time to time, as and when the need arises. In the event of any material changes, we will notify users through appropriate means, including by prominently posting a notice on our Website or through other reasonable communication channels.
You are encouraged to check this Privacy Policy from time to time, including at least once a year, to stay informed of any changes. The most recently published version shall prevail over any previous versions.
Our Website is offered in compliance with the laws of India. If you are accessing or using our Website from an overseas location, you are requested to independently validate the impact of any applicable local laws.
Definitions
For the purposes of this Privacy Policy, the following capitalized terms shall have the meaning assigned to them below:
“User Information” or “Information” shall mean information collected from Users as per Clause 3 of this Privacy Policy.
“Personal Information” with reference to any natural person, is any information that relates to such person, or which, either directly or indirectly, in combination with other information available to us, is capable of identifying that person.
“Sensitive Personal Data or Information (SPDI)” is defined under the SPDI Rules to mean Personal Information about a person relating to their:
password(s);
financial information (e.g., bank account, credit or debit card or other payment instrument details);
physical, physiological and mental health condition;
sexual orientation;
medical records and history;
biometric information;
any detail relating to the above as provided to a company for providing services or, storing or processing such information;
Any information that is freely available or accessible in the public domain or information which can be obtained by a governmental agency under the Right to Information Act, 2005 (legislation which requires public authorities to disclose certain kinds of information) or any other law in force is not SPDI.
Information Collected
Depending on your relationship with us (for example, as an investee/investor contact, visitor to our websites or facilities in India, vendor representative, job applicant), we may collect various categories of Personal Data (including SPDI) from and/or about you:
Contact Information: Name, photograph, signature, phone number, email, address, date of birth, age, marital status, location, nationality, government ID (such as PAN, Aadhaar).
Investee Ecosystem Information: Information we receive in connection with evaluating, executing, monitoring or managing investments (including information about founders, directors, officers, key managerial personnel and other representatives of investee/portfolio companies).
Investor and Transaction Information: Information relating to investor onboarding and fund/scheme participation, including application/subscription details, commitment amount, capital calls, contributions, distributions, unit holdings, nominee details, communications relating to investor relations, and other information required for fund administration and regulatory compliance.
Candidate/Recruitment Information: Resume, employment history, education details (degrees, certifications etc), salary slips, professional license or registration details.
Visitor and Security Information: Date/time of office visit; CCTV footage; visitor ID.
Financial Data: Bank account details, billing address/payment terms information.
Location Information: We do not collect precise information (such as, GPS data; latitude and longitude) concerning the location from which you access our Website, but we collect information on your region or postal code to help us gather information useful for improving the relevance of our content and securing access to our Website.
Communications Information: Information you share with us when you contact us or interact with us (e.g., emails, letters, phone calls, meeting notes, feedback, and other correspondence).
Usage Data: When you access or use our Website, we may track certain information to analyse your usage, including your IP address; browser and device information; log data; date and time of your visit; name of your Internet service provider; third party websites or pages you visit; and other analytical data.
Purposes of Collection and Processing
We ensure that your Personal Data (including SPDI) is collected and processed in a lawful manner. We may process your Personal Data (including SPDI) for the following purposes:
Website, communications and engagement: To operate, administer and improve our website/portals and communications; respond to queries and requests; manage newsletter/updates (including your subscription preferences) and analyse engagement with such communications.
Investor relations, onboarding and fund administration: To evaluate, onboard and service prospective and existing investors/unitholders (and their authorised representatives), including processing applications/subscriptions, maintaining investor records, issuing notices and communications, and maintaining related documentation and registers.
KYC, due diligence and compliance screening: To carry out KYC/AML checks and other onboarding and ongoing diligence (including verifying identity, beneficial ownership and authority), and to undertake compliance screening where required or considered appropriate as part of our compliance framework.
Investment evaluation, execution and portfolio management: To source, assess and evaluate potential investment opportunities; conduct due diligence; execute transactions; and undertake ongoing portfolio monitoring, value creation, governance, stakeholder engagement, and reporting in relation to investee/portfolio companies.
Business operations, contracting and vendor management: To engage, administer and manage vendors, advisers, service providers, contractors and business partners; negotiate and perform contracts; process invoices and payments; manage relationships and communications in the ordinary course of business.
Recruitment: To receive and evaluate applications from applicants/candidates, conduct recruitment processes (including interviews/assessments), carry out reference and background checks, communicate with candidates, and make hiring decisions.
Security, access control and business continuity: To manage physical and information security (including visitor management, CCTV and access controls), maintain business continuity, and protect our premises, systems, personnel and information assets.
Technology administration and troubleshooting: To maintain and administer our IT systems and infrastructure; monitor performance and usage trends; detect, prevent and address technical issues; and secure our website and systems (including preventing unauthorised access and abuse).
Legal, regulatory and governance requirements: To comply with applicable laws, regulatory requirements, SEBI/AIF-related obligations (as applicable), accounting and audit requirements; maintain records; respond to lawful requests from regulators, courts or authorities; and manage internal governance processes.
Risk management, dispute management and enforcement: To prevent, detect and investigate fraud or wrongdoing; enforce our terms, policies and contractual rights; protect our legal rights and interests; manage complaints, disputes and claims; and exercise or defend legal claims.
To conduct internal/external audits, quality checks, compliance reviews and risk assessments, including to maintain appropriate internal controls.
For any other purposes that are: (i) compatible with the above purposes; (ii) specifically notified to you at the time of collection; or (iii) otherwise required or permitted under applicable law.
How we collect your information
We collect Personal Information from and/or about you in the following ways:
Directly from you (such as, when you visit our premises, contact us through our Website, or subscribe to our newsletter);
Automatically when you use our IT systems, security tools, or Website (such as, CCTV at facilities, cookies and web beacons);
From third parties, including KYC/background verification agencies, recruiters, insurers, regulators, investees, portfolio companies, and our affiliates; and
At other touchpoints including events which you attend, and third-party services or web fronts that you access.
Sharing
Our Third-Party Providers. We may share your Personal Information with service providers to perform tasks on our behalf. For example, we may use third-party service providers for background verification, security, and website analytics. We require our service providers to maintain confidentiality and comply with applicable laws in relation to the processing of Personal Information.
In connection with a corporate merger, sale, divestiture, consolidation, restructuring, or other corporate change, including, without limitation, during the course of any due diligence process.
We may disclose Personal Information about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process, or governmental request; (ii) enforce our terms of use, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address actual or suspected fraud or security issues; or (iv) protect against harm to our or third parties’ rights, property or safety.
Where we transfer your Personal Information to third parties (including group companies) located outside India, we will ensure that the recipient offers an adequate level of protection that is at least comparable to that which is provided under this Privacy Policy and applicable Indian laws.
Retention of Information
We will retain your Personal Information only for the period necessary to fulfil the purposes for which it has been collected as described in this Privacy Policy, unless a longer retention period is required by law or for compliance with legal or regulatory requirements. After this timeframe, we will take the necessary steps to destroy or permanently delete your Personal Information or retain it in a form that does not permit identifying you.
Your Rights
You are entitled to exercise certain rights in relation to your Personal Information, including the right to:
access the Personal Information we hold about you;
correct or update any Personal Information that is inaccurate, incomplete, or outdated; and/or
withdraw your consent for the processing of any SPDI.
All such requests must be submitted in writing to the Grievance Officer (contact details below), providing sufficient details to enable identification of the relevant records. We will assess and respond to each request within a reasonable period.
Your Obligations
Accuracy of your Information: It is important that the Information we hold about you is accurate and current. Please keep us informed if your Information changes during the period for which we hold it. If you provide any Information that is untrue, inaccurate, not current, or incomplete, we have the right to suspend or terminate your account and refuse any and all current or future use of our Website (or any portion thereof).
Unauthorized Access: You are responsible for taking reasonable steps to protect the devices used to access our Website from unauthorized access. We shall not be responsible for any loss arising from unauthorized access to your devices or systems. If you become aware of any security vulnerability affecting our Website, please notify us at vignesh.s@skegen.com.
. Reasonable Security Standards
We implement appropriate administrative, technical, organizational and physical measures, consistent with requirements under applicable laws, to protect Personal Data from loss, theft, misuse and unauthorized access, corruption, disclosure and against unlawful forms of processing. These measures will be appropriate to the nature of Personal Data processed and potential identifiable threats.
Some of these measures include encryption; access controls; backup and restoration; strict adherence to privacy and security practices; periodic security assessment and reviews to upgrade our practices; and restriction of access to personnel who have a need to know such data.
We regularly adapt controls to respond to changing requirements and advances in technology and we review our SPDI collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
Children’s privacy
Our Website is not directed at minors. We do not knowingly collect Personal Information from individuals under 18 (eighteen) years of age. If you are under 18, please do not submit any Personal Data to us through our Website. If you are a parent or guardian and you believe that a minor has provided Personal Data to us, please contact the Grievance Redressal Officer so that we may take appropriate steps to delete such information, subject to applicable law.
Third-Party Links
Our Website may include hyperlinks to various external websites, and may also include advertisements, and hyperlinks to applications, content or resources (“Third-Party Links”). We have no control over such Third-Party Links, which are provided by persons or companies other than us. You acknowledge and agree that we are not responsible for any collection or disclosure of your Information by any external websites, applications, companies or persons thereof. The presence of any Third-Party Links on our Website cannot be construed as a recommendation, endorsement or solicitation of any material or content on such Third-Party Links, or any other material on or available via such Third-Party Links. We are not liable for any disputes arising from or in connection with such transactions between you and the aforementioned third parties.
Such third-party websites, and external applications or resources, accessible via the Third-Party Links may have their own privacy policies governing the collection, storage, retention and disclosure of your information that you may be subject to. We recommend that you exercise reasonable diligence, as you would in traditional offline channels and practice judgment and common sense before committing to any transaction or exchange of information, including reviewing the third-party website or application’s privacy policy.
Grievance Redressal
We have designated a Grievance Officer to address any questions, concerns, or complaints relating to the collection, processing, storage, or disclosure of your Personal Information. You may contact the Grievance Officer using the details provided below:
Name: Vignesh Sagadevan
Designation: IT Department
Address: Lake View Farm, Varthur Main Road, Siddapura, Bengaluru, Karnataka 560066.
Email: vignesh.s@skegen.com
Phone: 6360158539
Consent
By submitting Personal Information to us, you acknowledge that:
You have read and understood this Privacy Policy and agree to the collection, use, processing and transfer of your Personal Information, including SPDI, as set out herein.
All information and representations provided by you are, to the best of your knowledge, accurate and complete, and you have not knowingly omitted any relevant information that may affect our ability to engage with or provide services to you.
By consenting to this Privacy Policy, you hereby provide your express and explicit consent to the aforesaid collection, transmission, publication, storage, retention, and any other usage of Personal Information (including SPDI) by Us as per this Privacy Policy and as may be notified to you, from time to time. In case you do not consent to any of the usage, transmission, and/or publication of your Personal Information as detailed hereinabove, you may opt to not share your Personal Information and/or access/use our Website.
In the event of a change in applicable law regarding data protection in India, including by way of implementation of the Digital Personal Data Protection Act, 2023 and rules thereunder, you expressly consent to our continued collection, use, storage, and disclosure of your Personal Information. you may be required to provide additional consents or approvals in the form and manner prescribed by us to comply with such changes. Should you choose to not provide us with such additional consents and approvals, you may not be able to use and/or access our functionalities and services.
