Privacy Policy.

1. Information We Collect

We collect information you voluntarily provide to us, information we collect automatically when you visit our website, and information from third-party sources in connection with our investment activities.

Information You Provide Directly: When you contact us through our website (e.g., through the “Pitch to Us” or investor relations channels), we may collect your name, email address, phone number, company name, LinkedIn profile, pitch deck, and financial projections. If you are a Limited Partner (LP) or a prospective LP, we may collect additional information required for compliance with applicable securities laws, KYC/AML regulations, and our internal due diligence processes.

Information Collected Automatically: When you visit this website, we may automatically collect your IP address, browser type, operating system, pages visited, time spent on pages, referring URLs, and device identifiers. This is done through cookies and similar tracking technologies as described in Section 8.

Information from Third Parties: We may receive information about you from publicly available sources, professional networking platforms such as LinkedIn, data providers, and regulatory databases to verify identities, conduct due diligence, and fulfill our legal obligations.

2. How We Use Your Information

We use personal information collected for the following purposes:

• To evaluate investment opportunities and startup pitches submitted to us
• To communicate with prospective and existing portfolio founders
• To manage our relationship with Limited Partners and prospective investors
• To comply with applicable legal, regulatory, and fiduciary obligations under SEBI (AIF) Regulations, FEMA, and other relevant statutes
• To conduct KYC (Know Your Customer) and AML (Anti-Money Laundering) verification
• To send fund updates, quarterly reports, and other communications to authorised LPs through the Investor Portal
• To improve and maintain the security and functionality of this website
• To respond to inquiries and provide customer support

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

3. Legal Basis for Processing

Our processing of your personal data is based on one or more of the following legal grounds: (a) your consent, where explicitly given; (b) the performance of a contract or pre-contractual obligations; (c) compliance with a legal obligation under applicable Indian law, SEBI regulations, or other regulatory frameworks; and (d) our legitimate interests as a venture capital fund manager, provided such interests do not override your fundamental rights and freedoms.

4. Information Sharing and Disclosure

We do not disclose personal information to third parties except in the following circumstances:

• Service Providers: We may share data with trusted service providers (fund administrators, legal advisors, auditors, compliance consultants, and technology providers) who are bound by confidentiality obligations and process data only on our behalf.
• Portfolio Companies: With your consent, we may share relevant founder and company information with our portfolio ecosystem or co-investors in connection with a specific transaction.
• Regulatory Authorities: We may disclose information to SEBI, RBI, income tax authorities, FEMA compliance authorities, or other regulatory bodies as required by applicable law.
• Business Transfers: In the event of a merger, acquisition, restructuring, or dissolution of the fund, personal data may be transferred to a successor entity subject to equivalent privacy protections.

5. Data Retention

We retain personal information for as long as necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required by applicable law (e.g., SEBI record-keeping requirements, income tax obligations). For startup pitch applications that do not result in an investment, we typically retain information for up to three (3) years. For LP-related data, we retain records for the duration of the fund's existence and for a minimum of eight (8) years thereafter as required by SEBI (AIF) Regulations.

6. Security Measures

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These include encrypted data storage, access controls, secure communication protocols (TLS/HTTPS), and periodic security assessments. The Investor Portal is protected by authentication credentials and access is restricted to authorised LPs only.

While we take reasonable steps to protect your data, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Your Rights and Choices

Depending on applicable law, you may have the following rights with respect to your personal information:

• Right of Access: To request a copy of the personal information we hold about you.
• Right of Correction: To request rectification of inaccurate or incomplete information.
• Right of Erasure: To request deletion of personal information, subject to applicable legal and regulatory retention obligations.
• Right to Withdraw Consent: Where processing is based on consent, to withdraw consent at any time without affecting the lawfulness of prior processing.
• Right to Object: To object to processing based on legitimate interests, where applicable.

To exercise any of these rights, please contact us at legal@induckt.vc. We will respond to all valid requests within thirty (30) days. Note that certain rights may be limited by legal or regulatory obligations.

8. Cookies and Tracking Technologies

This website uses essential session cookies required for its technical operation and certain analytical tools to understand aggregate usage patterns. We do not deploy third-party advertising cookies. You may configure your browser to refuse cookies, though this may affect the functionality of certain parts of the website, including the Investor Portal.

9. Third-Party Links

This website may contain links to third-party websites (including LinkedIn, regulatory portals, and portfolio company websites). We are not responsible for the privacy practices of such external sites and encourage you to review their respective privacy policies.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. We will post the revised policy on this page with an updated “Last Updated” date. For material changes, we will provide notice to LPs through the Investor Portal. Your continued use of this website following any changes constitutes your acceptance of the revised policy.

11. Contact Us

For any privacy-related queries, requests, or complaints, please contact our designated Privacy Point of Contact:

Induckt Global Venture Manager LLP
7th Floor, Pearl Best Heights, 703/704
Netaji Subhash Place, One, Delhi — 110034, India
Email: legal@induckt.vc
Investor Relations: ir@induckt.vc