Privacy Policy

Effective Date: October 26, 2021

Overview

Thank you for visiting the Elevar website. Elevar respects your privacy. Whether you deal with us as an investor, entrepreneur or member of the general public (referred to in this policy as “you” or “your”), you are entitled to the protection of your personal data.

The aim of this Privacy Policy (“policy”) is to describe how and why we collect your personal data.  We will also inform you of what we do with this personal data, with whom we share it, how we protect it, how we process it  and your rights in respect thereof.

This policy applies to the processing of your personal data in the framework of various  services, tools applications, websites and marketing actions which are provided or operated by us or on our behalf (collectively, the “Elevar Platform”). This policy does not apply to the privacy practices of companies / organizations we do not control (including any portfolio companies), nor to any information obtained or collected in connection with a separate business relationship with Elevar or its affiliates, including as an investor in an Elevar investment fund, an employee of Elevar’s portfolio companies or as a service provider. 

This policy applies to all your personal data collected by (or on behalf of) Elevar through the Elevar Platform, referred to in this policy as “Elevar”,“we”, “us” and “our”.

By visiting the Elevar Platform, and / or by registering with us, you signify that you have carefully read, understood, and agree to be bound by this policy.  If you disagree with any of the terms of or any part of this policy, you must refrain from using the Elevar Platform or our services.

Key Data Protection Principles We Follow

We value the personal data entrusted to us and are committed to processing your personal data in accordance with the applicable data protection laws and regulations to which Elevar is subject, including the EU General Data Protection Regulation 2016 / 679, the California Consumer Privacy Act, 2018, and the (Indian) Information Technology Act, 2000 (“Data Protection Laws”). The terms “personal data” and “personal information,” as used herein, refers specifically to information that identifies a visitor to the Elevar Platform (which may include contact information and also any information referred to as “Personal Information” or “Personal Data” under the applicable Data Protection Laws).

We will try our best to adhere to the following key data protection principles:

Lawfulness: We will collect your personal data in a fair, lawful and transparent manner.

Data minimization: We will limit the collection of your personal data to what is adequate, relevant, and necessary for the purposes for which they have been collected.

Purpose limitation: We will collect your personal data for specific, explicit and legitimate purposes and we will not process your personal data further in a way incompatible with those purposes.

Accuracy: We will try to keep your personal data accurate and up to date, where it is necessary.

Data security and protection: We will implement technical and organizational measures to ensure an appropriate level of data security and protection considering, amongst other things, the nature of your personal data.  Such measures are aimed to prevent any unauthorized disclosure or access, accidental or unlawful destruction or accidental loss, or alteration or any other unlawful form of processing.

Access and rectification: We will process your personal data in a lawful manner.

Retention limitation: We will retain your personal data in a manner consistent with the applicable Data Protection Laws, and no longer than may be required for the purposes for which they have been collected.

Protection for international transfers: We will ensure that any of your personal data transferred outside of your jurisdiction is adequately protected.

Safeguards towards third parties: We will ensure that personal data access by, and transfers to, third parties are carried out in accordance with applicable laws and with suitable contractual safeguards.

Collection of your personal data 

The personal data collected by Elevar may inter alia include the following:

Personal Data: For you to use certain features of the Elevar Platform, such as creating an account on the Elevar Platform, you would be required to register with us, which requires you to provide certain personal data such as your email address, phone number, name, date of birth etc., and certain sensitive personal data or information such as passwords, financial information etc. 

Automatically Collected Information: Elevar may collect information during your visit to the Elevar Platform through automatic data collection tools, which may include cookies (see below for more information on cookies) and other commonly used information-gathering tools. These tools collect certain information that your browser sends to our website such as your browser type and language, access times, and the address of the website from which you arrived at the Elevar Platform. They may also collect information about your Internet Protocol (IP) address and clickstream behavior (i.e., the pages you view, the links you click, and other actions you take in connection with the Elevar Platform), geolocation data, and information about your device.  Elevar may also share this information in aggregate form (i.e., that cannot reasonably identify a particular individual) with third parties for business purposes, such as service providers and consultants to Elevar.

Photography: For special events, Elevar may take photos and video recordings of you.  We will try our best to inform you if this is happening.

You have an option not to provide the aforesaid personal data if you wish not to avail the specific service on the Elevar Platform, for which the personal data is required.

How We Use / Process Your Data

Your Name and Contact Details: We use your name and contact details, such as email, postal address and contact number to continue communications with you.  We may also use your contact information to invite you to events we are hosting or to keep you updated about our services, achievements, etc.

Legal Basis for Processing: We will process your personal data lawfully and will explain the specific legal basis for which we process your data within this privacy policy. We will not process your personal data further in a way that is incompatible with those purposes.

Please note that in accordance with applicable Data Protection Laws, your personal data can be processed if:

• You have given us your consent for the purposes of the processing; or

• It is necessary for the performance of a contract to which you are a party; or

• We have a legitimate interest that is not outbalanced by your privacy rights; or

• It is required under a legal obligation to which we are bound

For the avoidance of doubt, you will always have the right to withdraw your consent at any time.

How Long Do We Retain Your Personal Data?

We will retain your personal data for as long as necessary for the purposes for which we process your personal data or to comply with the applicable law.  For information on how long certain personal data is likely to be kept before being removed from our systems and databases, please contact us at dataprivacy@elevarequity.com.

How Do We Protect Your Personal Data?

We implement certain reasonable technical and organizational security measures to protect your personal data against unlawful or unauthorized access or use, as well as against accidental loss or damage to its integrity. The security measures have been designed by taking into account our IT infrastructure, the potential impact on your privacy, the costs involved, the Data Protection Laws and the current industry standards and practice.

Our data security procedures include: access security, backup systems, monitoring, review and maintenance, management of security incidents and continuity. Your personal data will only be processed by a third party data processor if they agree to comply with those technical and organizational data security measures.

This policy and the security controls and practices implemented by Elevar to protect your personal data shall be the reasonable security practices and procedures under section 43A of the Information Technology Act, 2000.

Use of Cookies or Similar Technologies

We use cookies on our website. This helps us to understand and save your preferences for future visits and to compile statistical data about our website traffic and interactions. This also allows us to provide you with a better experience when you browse our website and allows us to make improvements to our site. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. If you click on a link to a third party website or service, a third party may also transmit cookies to you. This policy does not cover the use of cookies by any third parties, and we are not responsible for their privacy policies and practices.

Disclosure of Personal Data and Third Parties

Depending on the purposes for which we collect your personal data, we may disclose it to the following categories of recipients, who will then process your personal data only within the framework of these purposes:

• Authorized staff members of Elevar

• Entities and persons affiliated with the Elevar family of funds, and their related management companies and other affiliated entities

• Third parties, being companies that provide services for or on behalf of Elevar. These companies are required to always act in compliance with applicable laws and this privacy policy

We do not sell or rent your personal information for valuable consideration.

Transfers Outside the European Economic Area (“EEA”)

Elevar has offices in the USA, India and Mexico. Data is routinely shared between these locations. If you are a citizen of the European Union and when there is any transfer of your personal data to countries outside the EEA that do not generally offer the same level of data protection as that within the EEA, Elevar implements appropriate measures to ensure an adequate level of protection of that personal data, in accordance with applicable Data Protection Laws. 

Your Privacy Rights

We want to be as transparent as possible with you, so that you can make meaningful choices.

Depending on your place of residence, individuals whose personal data is processed by Elevar may be entitled to the following:

• A right of access to your personal data;

• A right to object to the processing of your personal data in certain circumstances;

• A right to rectify any information which is inaccurate;

• A right to the erasure of your personal data (also known as the “right to be forgotten”); provided that Elevar may retain your information only if it is necessary (a) to provide you with services you requested; or (b) for our internal analytical use; or (c) under the applicable Data Protection Laws;

• A right to data portability when the processing activity is based on consent or under a contract with the you, i.e. the right to receive your data or to have the data transmitted to a third party;

• A right to ask us to restrict the processing of your personal data if you have challenged the accuracy of your data, or if you have objected to the use of your data.  You may also ask us to limit the use of your data where you feel we may have processed your data unlawfully, or where you want us to keep your personal data in order to create, exercise or defend legal claims; and

• A right to not be discriminated against for exercising your rights under the Data Protection Laws.

Contact Us?

Our compliance officer and counsel will handle any questions or requests relating to this policy, any specific privacy notice or your personal data and its processing.

For any questions, requests, complaints concerning the application of this policy, or to exercise your rights, as described in this policy, you may contact us at our address in India listed above, or email us at dataprivacy@elevarequity.com 

Complaints

If you are not happy with the way we manage your data, disagree with a decision we have made in respect to your individual rights, or you have any other type of concern, you may submit a complaint by contacting us.

Changes to This Policy

We may occasionally make changes to this policy which will reflect how we process your personal data.  This is to ensure we honor our commitment to you to protect your personal information and uphold your rights.  Please check this page regularly to ensure you are familiar with the latest version of the policy. If important changes are made to this policy, we will draw your attention to them by making this clear on our website, through our services or by another means of communication, such as email.  This will allow you to assess the changes in light of the data that we might be holding. 

THE PRIVACY POLICY BEING AN ELECTRONIC RECORD IS GENERATED BY A COMPUTER SYSTEM AND DOES NOT REQUIRE ANY PHYSICAL OR DIGITAL SIGNATURES.