Privacy Policy

This Privacy Policy applies to the Internet sites of Vikram Advisory Services Private Limited and its affiliates ("VIkram Advisory Services" or "we"), including www.vikramadvisory.com and affiliated sites. We are committed to protecting the privacy of visitors to our websites (collectively, the "Site"). Vikram Advisory Services Private Limited is the data controller in relation to personal information collected through the Site. This Privacy Policy describes the information we collect about you when you visit the Site, and how we use such information. This Privacy Policy does not address our privacy practices concerning any nonpublic personal information we collect as to our investors; we address those practices in separate notices sent to our investors or potential investors.

Any update to this Privacy Policy will be effective upon posting a notice of the modified Privacy Policy here. We encourage you to periodically consult this Privacy Policy to learn about any modifications and updates.

If you have any questions or comments about this Privacy Policy, you can contact us as described in the “How to Contact Us” section below.

Personal Information We Collect

We do not collect any personal information from you through the Site except as described in the Privacy Policy. Personal Information is information that personally identifies you, directly or indirectly, such as your name, postal address, e-mail address, or credit card information (or other information that is associated by us with such above information). We may collect personal information that you choose to provide to us through the Site, including, but not limited to, your first and last name, physical address, e-mail address, or telephone number, such as when you:

• Fill out a form on the Site;
• Sign-up to a feature that we offer on the Site and you provide your personal information in connection with that feature;
• Attend an event that we have organized;
• Communicate with us (for example, on a social media platform or by sending us an email;
• Provide personal information to us on Vikram Advisory Services's social media pages; or
• Voluntarily provide personal information to us through the Site.

We also may obtain personal information about you from third parties acting on our behalf, such as the frequency with which you visit our Site and the links you use, including in order to enhance the utility of our Site.

Personal Information We Obtain By Automated Means

When you visit our Site, we, or third parties on our behalf, may collect certain information by automated means, such as web server logs, as well as cookies, web beacons or tracking pixels, JavaScript and other code that may run on your computer. The information we collect in this manner includes or may, in the future, include dates and times of Site visits, IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, and information about actions taken on the Site. We may use third-party analytic tools and technologies to analyze this information, including how visitors use the Site, to research our visitors’ demographics, interests, and behavior, to improve the Site, to provide visitors with customized services and information and for other similar purposes.

Server Logs: We use server logs, which automatically record certain information from Site visitors, such as the number and frequency of visits, as well as IP addresses, time spent on the Site and pages viewed.

Cookies: Cookies are small text files that store information, such as your preferences and account settings, on the hard drive of your computer. Similar to many websites, if you have enabled cookies in your browser, Vikram Advisory Services, independently and through enabled third-party tools and programs, has the ability to collect certain technical information, such as originating IP address, browser type, browser language, how a user got to the Site (i.e., the URL of the last website the user visited), the next website the user visits, what pages are visited, the length of each site visit, and the date and time of the user’s visit. This information helps us track trends and improve user experiences when visiting the Site. Internet browser settings may be modified to have your computer warn you each time a cookie is being sent, or you can choose to disable all cookies. If you choose to disable cookies, the Site may not work as it is intended. If you continue using the Site without changing your settings, we will assume that you have accepted receipt of all cookies on the Site.

Social Media Widgets: The Site includes, or may in the future include, social media functions, such as the Blog, Twitter, LinkedIn, and Facebook widgets. These widgets may collect information about which pages you visit on the Site and the IP address of the device you use to connect to the Internet. The widgets may also set a cookie to ensure the features are functioning properly.

Social media functions and widgets are hosted either by a third party or directly on the Site. Your interactions with the social media functions and widgets located on the Site are governed by the privacy policies of the companies that provide them. If you use any of the social media functions or widgets on our Site, we strongly suggest you review the privacy policies of the companies that provide those functions and features.

Other Tracking Technology: We may send instructions to your device using web beacons or tracking pixels (which are similar to cookies), JavaScript or other computer languages which, in conjunction with third-party tools, would enable us to gather the sorts of information described above and other details about your interactions with the Site. We also may use third-party plug-ins and widgets on our Site, such as social media sharing tools which may use automated means to collect information regarding your use of the Site and your interactions with the plug-ins and widgets. This information is subject to the privacy policies or notices of the providers of the plug-ins and widgets. We encourage you to review the privacy policies of such providers to understand their policies that apply to their collection and use of information.

How We Use the Information We Collect

We may use personal information that you provide to us to respond to your inquiry, for example, to contact you about your request, ask a question, provide announcements about future events and opportunities, conduct surveys, and contact you for other reasons related to offering and improving our services.

In addition to the uses discussed above, we may also use the personal information you provide on our Site to:

• operate, evaluate, and improve our business;
• administer the Site;
• develop new products and services;
• perform market research;
• analyze our products, services, and websites;

We use the personal information for the purposes described above because we have a legitimate business interest in providing services to our customers and other interested individuals that are not overridden by your interests, rights and freedoms to protect personal information about you.

Disclosure of Information

We may share your personal information with our affiliates, portfolio companies and our advisors, for the purposes described in this Notice.

We may share personal information with third-party service providers to facilitate our services and perform functions on our behalf, such as sending postal mail and e-mail and providing us with technical, analytical and hosting functions for the Site. As required by applicable law, we do not permit them to use or disclose personal information only as necessary to perform services on our behalf or comply with applicable legal requirements.

In addition, we may disclose personal information about you (a) if we are required to do so by law or legal process, for example due to a request from a law enforcement authority, a subpoena, court order or discovery request; (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) when we believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts and privacy) or may expose us to liability; (d) in connection with the investigation of suspected or actual fraudulent or other illegal activity; and (e) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Protection of Personal Information

The security of your personal information is important to us. We employ technical, administrative and physical security measures to protect any personal information you provide through the Site from unauthorized access or use. You should be aware, however, that "perfect security" does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information. You use the Site and send us such information at your own risk.

Other Websites, Links and Third-Party Technologies

Please note that this Privacy Policy applies only to the Site, and not to any other website that may link to or may be linked from it. We do not control the privacy policies or practices of other websites. If you follow links to websites not affiliated or controlled by Vikram Advisory Services, you should review their privacy and security policies, as this Privacy Policy no longer applies – i.e., the policies and practices of other websites and other parties are governed by their respective privacy policies. Vikram Advisory Services does not guarantee and is not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of their information. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.

Please be advised that the virtual data room portals that can be accessed through links on the Site by investors in funds managed by Vikram Advisory Services are maintained by third-party service providers, whose privacy policies apply to those portals and to the personal information you provide in activating and using your account to access those portals; the third party service providers inform us of who has access to the portals they operate and each user’s usage of the portals. We encourage you to review those privacy policies.

Transfers of Your Personal Information

If you are located in the European Economic Area (“EEA”), we comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA and Switzerland. In all such cases, we will only transfer your personal information if:

• The country to which the personal information will be transferred has been granted a European Commission adequacy decision;
• The recipient of the personal information is located in the U.S. and has certified to the US-EU Privacy Shield Framework; or
• We have put in place appropriate safeguards in respect of the transfer, for example the EU Model Contracts.

If you are located in the EEA you also may request a copy of the safeguards that we have put in place in respect of transfers of personal information by contacting us as described in the How to Contact Us section below.

How Long We Keep Your Personal Information

The time period for which we keep personal information depends on the purpose for which we collected it. In all cases we keep it for as long as necessary to fulfil the purposes for which we collected it. We will then delete the personal information, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).

Subject to any applicable legal requirements, we typically retain personal information as follows:

• Personal information you provide to us through our Site: we keep this personal information for as long as necessary in order to fulfil the purpose for which you provided it to us, and for a short further period in case you send us further requests.
• Personal information you provide when you sign-up to receive direct marketing communications: we keep most of this personal information for the duration of our relationship with you until you opt-out or we do not have any contact with you for a long period of time.
• Personal information collected for analytics purposes: we keep this personal information for a short period of time necessary for us to carry out the analytics.
• Website logs: we keep Site audit logs, which may contain your personal information, for several months.

Your Rights

If you are located in the EEA or Switzerland, subject to applicable law, you may have the following rights in relation to personal information that we hold about you:

• To request confirmation of whether we process personal information relating to you and, if so, to request a copy of that personal information;
• To request that we rectify or update your personal information that is inaccurate, incomplete or outdated;
• To request that we erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw your consent;
• To request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal information;
• Where you have given us consent to process your personal information, to withdraw your consent; and
• To request that we provide a copy of your personal information to you in a structured, commonly used and machine readable format in certain circumstances.
• To object to certain of our data processing, such as for direct marketing purposes.

If you are located in the EEA and you wish to exercise any of your data protection rights or if you consider that we have processed your personal information in violation of applicable law, please contact us as detailed in the “How to Contact Us” section below.

If you consider that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.

How to Contact Us

If you have any questions regarding this Privacy Policy, or wish to notify us of any errors or changes as to any personal information you provide us through the Site, you can write to us at Privacy Matters, Vikram Advisory Services Private Limited, Fourth Floor, Nikumbh Complex, CG Road, Ahmedabad, Gujarat, INDIA or email us at aditya@vikramadvisory.com.

Last Updated and Effective As Of: April 9, 2020