Privacy Policy
Date : 21 – August-2024
General:
Thank you for choosing to be part of our community at ThinKuvate Investment Management LLP , a company incorporated under the provisions of Limited Liability Partnership Act, 2008, having its registered address at Flat-504, 5 floor, Savitri Cinema Complex, GK-II, Greater Kailash, Greater Kailash, New Delhi, South Delhi-110048, India, doing business as ThinKuvate. We are committed to protecting your Personal Information and your right to privacy. If you have any questions or concerns about this Privacy Policy or our practices with regard to your Personal Information, please contact us at compliance@thinkuvate.com.
This Privacy Policy describes how we might use your information if you visit our Website at https://www.thinkuvate.com/. The purpose of this Privacy Policy is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it.
By using our Website and/or by providing information, you agree and consent to us collecting, storing, processing, transferring, using and sharing of your Personal Information / data that you disclose on our Website or via third parties for the purposes as set out and in accordance with this Privacy Policy. You are advised to read and understand the Privacy Policy carefully since by accessing the Website, you are bound by the terms and conditions of the Privacy Policy and consent to the collection, storage, and use of information pertaining to you as specified in this Privacy Policy. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services or access the Website immediately. We act as a Data Fiduciary when we collect and process Personal Information / data about you.
In this Privacy Policy, if we refer to:
• “Applicable Law” it means the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000 or any rules or regulations made thereunder and as amended, modified or superseded, from time to time.
• “Services” we are referring to our Website, and other related services, including business mentorship or investment, etc.
• “Personal Information” it means information (whether individually or in combination with other information available or likely to be available with us) that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a natural person.
• “Privacy Policy” it means the privacy policy of the Website.
• “user(s)”, “you”, or “your” we are referring to any person or individual who uses / accesses the Website.
• “Website” we are referring to any website of ours that references or links to this Privacy Policy.
• “Data Fiduciary” shall have the meaning ascribed to such term as per the Applicable Law in force in India.
1. WHO ARE WE
ThinKuvate Investment Management LLP , a company incorporated under the provisions of Limited Liability Partnership Act, 2008, having its registered address at Flat-504, 5 floor, Savitri Cinema Complex, GK-II, Greater Kailash, Greater Kailash, New Delhi, South Delhi-110048, and engaged in the business of investing in early-stage start-ups via our CAT I Angel Fund.
2. COLLECTION OF INFORMATION
Personal Information you disclose to us
We collect Personal Information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or otherwise when you contact us.
The Personal Information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The Personal Information we collect may include the following:
Personal Information Provided by You
We collect names; phone numbers; email addresses; mailing addresses; job titles; usernames; passwords; contact preferences; contact or authentication data; and other similar information.
All Personal Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such Personal Information.
Information automatically collected
We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
• Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
Access to Website by minor / persons with disability
The Website and / or Services is not intended to be accessed / used by minors i.e., any person under the age of 18 (eighteen) years and / or persons with disability. By accessing the Website you affirm that you are above 18 (eighteen) years of age and are fully competent to understand this Privacy Policy and abide by the terms of this Privacy Policy. We do not knowingly collect any Personal Information from minors or persons with disability. In case you are below 18 (eighteen) years of age or a person with disability, you may access and use the Website only if enabled by a parent or legal guardian
3. USE OF INFORMATION COLLECTED
We use Personal Information collected via our Website for a variety of business purposes described below. We process your Personal Information for these purposes in reliance on our legitimate business interests, to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
• Request feedback-We may use your information to request feedback and to contact you about your use of our Website.
• To manage user accounts-We may use your information for the purposes of managing our account and keeping it in working order.
• To send administrative information to you-We may use your Personal Information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• To protect our Services-We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
• To enforce any terms, conditions, policies and /or any arrangement or agreement entered by us for our business purposes, to comply with legal and regulatory requirements .
• To respond to legal requests and prevent harm-If we receive a summon or other legal request from any court of law / tribunal / other statutory / similar body in India, we may need to inspect the data we hold to determine how to respond.
• To deliver and facilitate delivery of services to the user-We may use your information to provide you with the requested service.
• To respond to user inquiries/offer support to users-We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
• Deliver targeted advertising to you-We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
4. DISCLOSURE OF INFORMATION
We may process or share your data that we hold based on the following legal basis:
• Consent: We may process your data if you have given us specific consent to use your Personal Information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your Personal Information to fulfil the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with Applicable Law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your Personal Information in the following situations:
• Affiliates-We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. “Affiliates” include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• Business Partners-We may share your information with our business partners to offer you certain products, Services or promotions.
5. SECURITY AND STORAGE OF USER’S INFORMATION
We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this Privacy Policy will require us keeping your Personal Information for longer than the period in which users are associated or have account with us.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
We endeavour to protect the information provided by, or collected about its users from unauthorized access, alteration, disclosure, or destruction. In detail:
1. We review its information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to our systems and the information gathered.
2. We restrict access to the information collected to our employees, contractors, and agents who need to know that information for processing it for us. The employees, contractors, and agents are subjected to the obligation of strict confidentiality about the information accessed, and will face disciplinary action, including termination, if they violate this obligation.
We do not recommend transfer of sensitive data, Personal Information and bank account details via the Website to other users. You are recommended to do so offline, on the phone or via personal emails. Information provided by users to other users shall be done at their sole responsibility and risk.
Breach of Personal Information
In the event, there is a breach or unauthorized or accidental use or access to your Personal Information in our possession, we shall promptly intimate you of such breach and take necessary measures to address the issue as required by Applicable Laws.
6. DISCLAIMER
We cannot ensure that all Personal Information provided and communication with the user will never be disclosed in ways not otherwise described in this Policy. Although we are committed to protecting user’s privacy, we do not promise, and user should not expect, that user’s Information will always remain private. As a user of the Website, you understand and agree that you assume all responsibility and risk for usage of the Website, the internet in general, and the documents you post and access, and for user’s conduct on and off the Website.
7. REVIEW OF PERSONAL INFORMATION
You may at any time request our grievance officer in terms of paragraph 10 below to review the Personal Information that you have provided to us, and we will ensure that such Personal Information, if found to be inaccurate or deficient, shall be corrected or amended, as feasible. However, we will not be responsible for the authenticity of the Personal Information provided by you to us.
8. WITHDRAWAL OF CONSENT
You may at any time withdraw your consent for collection and use of your Personal Information. However, please note that if you withdraw your consent, we may no longer be able to provide you with the corresponding Services for which you have withdrawn your consent. It is hereby clarified that your decision to withdraw your consent will not affect the processing of the Personal Information based on your previous consent prior to the withdrawal and a separate request for removal will be required in such cases. If you wish to withdraw your consent under this Privacy Policy or remove your Personal Information possessed or stored by us, you can contact our grievance officer referred to in paragraph 10 below. We reserve the right to limit access to our Platform and/or Services based on such request. You will be notified by us prior to any actions taken in this regard.
9. UPDATES TO THE PRIVACY POLICY
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. If you continued the use of the Services and the Website it shall be deemed as your acceptance over the updated version of the Privacy Policy.
10. GREIVANCE REDRESSAL AND COMMUNICATION
If you have questions or comments about this Privacy Policy, you may email us at or by post to our grievance officer below:
Name: Ramesh B
Address: ThinKuvate Investment Management LLP , Flat-504, 5 floor, Savitri Cinema Complex, GK-II, Greater Kailash, Greater Kailash, New Delhi, South Delhi-110048, India
Contact number: +91 70089 27803
Email address: Ramesh.b@thinkuvate.com
We will try to resolve your complaint/ request expeditiously and get back to you within 1 (one) month. However, this is also subject to us receiving all pertinent information/ documents from you in a timely manner.
In the event your complaints/ requests are not resolved by our grievance officer within the said 1 (one) month. You may reach out to the Data Protection Board of India.
