Privacy policy
March 1, 2024
This privacy notice sets out how certain funds (“Funds”), managed by Vy Capital Management Company Limited (the “Management Company”) as well as other parties like its advisory entities and fund administrators, collectively referred to as ('we', 'us', or 'our'), might collect, store, use, and/or share ('process') your personal information when you: (a) visit our website at www.dharana.com, or any website of ours that links to this privacy notice, (b) engage with us in other related ways, including any sales, marketing, or events, (c) share any information with us on our official email channels, including contact@dharana.com (collectively, our “Sites”).
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Sites. If you still have any questions or concerns, please contact us at contact@dharana.com.
'Personal information; means any information that identifies or relates to a particular individual and includes information referred to as ‘personal information’ or ‘personal data’ under applicable data privacy laws, rules, or regulations.
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Sites, when you participate in activities on the Sites, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make, and the products and features you use.
The personal information we collect may include the following: names, phone numbers, email addresses, job titles and contact preferences and other fields you might provide to us voluntarily.
Sensitive Information. We do not process sensitive 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 may automatically collect certain information when you visit, use, or navigate the Sites. 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 Sites, and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.
The information we may collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers may automatically collect when you access or use our Sites 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 Sites (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 Data. We may collect device data such as information about your computer, phone, tablet, or other device you use to access the Sites. 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.
Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Sites. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device.
Other sources of personal information
In course of forming, managing and operating the Funds, the Management Company and the Sites, we may collect and maintain personal information from the following sources:
information we or our representatives receive from you in conversations, including over the telephone, in voicemails, through written correspondence, via e-mail, or information set out in any subscription agreements, questionnaires, applications or such other forms and documents as we may request to be completed in relation to the business of the Funds;
personal information provided by you by way of correspondence or interactions with us by phone, e-mail or otherwise; due diligence documentation we obtain or hold as part of our regulatory obligations; information we obtain or hold about your transactions with us or others;
information we receive from you or third party sources, including as necessary to comply with law and regulations that apply to us, or entities which may include, among others: (i) entities in which you or someone connected with you has an interest; (ii) your legal and/or financial advisors; (iii) other financial institutions who hold and process your personal data to satisfy their own regulatory requirements; (iv) credit reference agencies and financial crime databases.
2. HOW DO WE PROCESS YOUR INFORMATION?
We process your personal information for a variety of reasons, depending on how you interact with our Sites, including that we may process your personal information:
to respond to your inquiries and correspond with you.
to send you communications notifying you of fundraising initiatives and investment opportunities via email and other means.
to send you details about us, changes to our terms and policies, and other similar information.
for administering the business of the Funds or the Management Company or related entities in a suitable manner, including conducting audits, implementing risk management processes, corporate governance, maintaining and monitoring IT systems and management of third party service providers, or for providing, operating, maintaining or improving the Sites.
detecting, investigating and preventing internal and external breaches of internal policy and applicable law and regulation and establishing, exercising and defending legal rights or fulfilling our reporting obligations to regulatory authorities.
for identify verification and other anti-money laundering and financial crime checks.
to disclose information to other third parties such as service providers of the Management Company or Funds, including auditors, legal counsel, regulatory authorities, advisers or technology providers.
to carry out statistical analysis and market research.
to monitor and record calls for quality, business analysis, training and legitimate business purposes.
We do not sell or otherwise disclose your personal information for monetary or other valuable consideration. Nor do we process your personal information for cross-context behavioral advertising purposes.
Your personal information may be processed outside your jurisdiction. We ensure that the recipient of your personal information offers an adequate level of protection and security, for instance by entering into the appropriate back- to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time by writing to us at contact@dharana.com.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Sites or at your request prior to entering into a contract with you.
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
Finance & Accounting Tools
CRM Tools
Communication & Collaboration Tools
Data Storage Service Providers
Website Hosting Service Providers
We also may need to share your personal information in the following situations:
We may share your personal information over the course of a business transaction, such as with counterparties and others assisting with a merger, acquisition, financing, reorganization, bankruptcy, receivership, dissolution, asset sale, or similar transaction, including formation or operation, and with successors or affiliates as part of or following that transaction. .
We may share your information with Google Analytics to track and analyze the use of the Sites. To opt out of being tracked by Google Analytics across the Sites, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. 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.
We may share your information with our business partners to offer you certain products, services, or promotions.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice, if applicable.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
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.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the Sites within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at contact@dharana.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision- making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
We will consider and act upon any request in accordance with applicable data protection laws.
Withdrawing your consent: If we are relying on your consent to process your personal information (which may be express or implied depending on applicable law), you may withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying 'STOP' or 'UNSUBSCRIBE' to the SMS messages that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
If you are a resident of California, Connecticut, Utah or Virginia, you are granted specific rights regarding access to your personal information. The rights are not absolute and may not be applicable in specific instances. We reserve all of our rights available to us at law in this regard. If you wish to exercise any of the rights, please email contact@dharana.com.
We may have collected the following categories of personal information in the past twelve (12) months, if provided voluntarily by you.
We will use and retain the collected personal information as needed to provide the Sites or for 1 year.
CCPA Disclosure: If you are a California resident, you may be entitled to request access to the categories or specific pieces of personal information that we collect about you, to request that we delete or correct your personal information and to opt out of the sale and/or sharing of your personal information. Although California residents may have the right to opt out of the sale and sharing of personal information, we do not sell or share personal information as the terms “sell” and “share” are used under the CCPA to third parties, including personal information of individuals under 16 years of age, and we have not sold or shared such personal information in the last 12 months. The CCPA prohibits us from discriminating against you for exercising your applicable CCPA rights. If you wish to exercise any of the rights described in this CCPA Disclosure section, please email contact@dharana.com.
In order to respond to a request, you will be required to supply a valid means of identification as a security precaution. Depending on the sensitivity of the information in question, we may require additional proof of identification. We will not disclose or delete any information until the individual’s identity is verified. We will maintain records of consumer requests made under CCPA and how we responded to those requests in accordance with the CCPA.
California Shine the Light Disclosure: Under California Civil law, Californians are also entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. If you are making a request for access, we may not be able to provide specific pieces of personal information if the disclosure creates a substantial, articulable and unreasonable risk to the security of your personal information , your account with us or our systems or networks. If you are making a request for erasure, we will ask that you confirm that you would like us to delete your personal information again before your request is submitted. To make a request, please email contact@dharana.com.
11. DO WE MAKE UPDATES TO THIS NOTICE?
We may update this privacy notice 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 notice, 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 notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at contact@dharana.com.
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To make a request, please email contact@dharana.com.
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