Date of last revision: 25th Feb, 2021

By using this application/website (link) and/or signing up for the Services (as defined under the Terms of Use) offered by iCapital Finance Pvt Ltd Advisors Private Limited, (“iCapital Finance Pvt Ltd”), or providing us with your personal information for any other purpose, you agree to this Privacy Policy.

This policy will help you understand the types of information we collect from you, the purpose for which the information is collected; how the information is used; the intended recipients of such information; and how the information is protected. If you would like more details, please contact us at(contact link).

For the purposes of this policy, “personal information” means any information that can be used to identify you personally and shall not include information that is freely available or accessible to the public.

1. Using iCapital Finance Pvt Ltd as a Visitor

   If you are a first-time visitor to iCapital Finance Pvt Ltd:

   • We don’t know who you are.
   • We collect technical data about your interaction with the Services. This is data we get from your use of our services. We collect certain data about your interaction with our website, such as pages visited and average time spent on the website, your internet protocol address, the unique identifier of your device and device information such as operating system, operating system version, browser plugins, crashes, system activity, hardware settings, date and time of your request and referral URL, and cookies that may uniquely identify your browser and mobile application.
   • We use this data to analyse how you use our website and improve the services provided through the website;

2. Using iCapital Finance Pvt Ltd as a Registered User

   If you have provided us your email address:

   • You are a registered user of iCapital Finance Pvt Ltd.
   • You may be asked to give us additional information in order to use certain features of the Services.
   • You have the choice to use your social media accounts like Facebook or Google to login to iCapital Finance Pvt Ltd (“Social Login”). If you choose Social Login, iCapital Finance Pvt Ltd will have access to your name and email address only.
   • We collect technical data about your interaction with the Services.
   • We use all the collected data to:
   • Respond to your queries about the Services;
   • Deliver to you any notices, alerts, or communications relevant to your use of the Services;
   • Offer you other products or services that we believe may be of interest to you. You have the option to opt-out of receiving such communication;
   • Aggregate the anonymised information from registered users to perform market research, project planning, product development, troubleshoot problems, analyse user behavior, marketing purposes, and promotions;
   • Enforce our Terms of Use.

3. How We Use Your Data

   Your email address and phone number is used to send you updates regarding the Services. You can select what communication you’d like to receive from us by modifying your account settings after you login to your iCapital Finance Pvt Ltd account.

   We may also use your information to verify your identity in the event you contact us for assistance with the site or services.

   We use cloud-based software tools to perform certain business-related functions. Examples of such functions include, maintaining databases and servers, processing text messages, phone calls, chats and emails, and marketing and sales analytics. A full list of our third-party vendors is available at(link for vendors). Please note that these vendors are bound by the same standards of data security practices and procedures as we are under law and contract.

4. How We Use Technical Data

   iCapital Finance Pvt Ltd uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses first-party cookies to report on user interactions with our web-based services. These cookies store non-personally identifiable information.

   Google Analytics aggregates technical data (non personally identifiable data relating to your usage of our website) with data collected from other iCapital Finance Pvt Ltd users. We use this information to identify the most popular areas of the Services and how to best present and customize them.

   For more information about how Google handles technical information, please visit the site, “How Google uses data when you use our partners’ sites or apps”, (located at: www.google.com/policies/privacy/partners ).

   We may use the unique identifier of your device for security purposes to track suspicious activity. For instance, if we detect that your iCapital Finance Pvt Ltd account is being accessed from multiple devices, we may contact you to ensure that you have authorized such access. Under no circumstances will your email, password, any personal financial data be collected by or shared with Google Analytics.

5. Access Your Information

   Your personal information is yours. Under Indian law, you have the right to ask us for a readable copy of all your personal information stored with us.

   If you have any questions about the accuracy or safety of your information, please do contact us at the address given below:

   (Address

   Email)

6. Disclosure of Information

   Under no circumstances will we sell or rent your personal information to anyone, for any reason, at any time. iCapital Finance Pvt Ltd has taken best and reasonable steps to ensure prevention of any unauthorised disclosure of your sensitive personal information.

   Disclosure for regulatory compliances: iCapital Finance Pvt. Ltd will share your information with judicial, administrative and regulatory entities to comply with any legal and regulatory requirements.

   Disclosures with your prior consent: If, at any time, you choose to utilize the integrated services of third party service partners through us, we will share your information with these third party service partners with your prior consent.

   Disclosure for provision of Services: iCapital Finance Pvt Ltd will share your information with third party vendors of iCapital Finance Pvt Ltd as necessary for the provision of Services. Authorized third party vendors are bound by the same standards of data security practices and procedures as we are under law and contract. They are subject to the same penalties as we are for the unauthorized disclosure of your personal information.

7. Security Practices and Procedures

   iCapital Finance Pvt Ltd follows industry best practices, using open and known principles when transferring and storing your data.

   We believe the biggest threat to the security and privacy of your data is if someone – probably someone you know – gains access to any of your devices. Remember to keep your password safe and secret to prevent unauthorized access to your iCapital Finance Pvt Ltd account.

   If you think that the security of your iCapital Finance Pvt Ltd account has been compromised, change your password and contact us immediately for further assistance.

8. How Your Information is Transmitted

   Your data is transmitted between your device and our servers using HTTPS protocol for encryption. HTTPS is the technology used to create secure connections for your web browser, and is indicated by a padlock icon in your browser.

9. Our Legal Obligation to You

   We are bound by the (Indian) Information Technology Act, 2000, and comply with all its provisions. Under Section 43A of the (Indian) Information Technology Act, 2000, iCapital Finance Pvt Ltd and all its vendors are obliged to maintain reasonable security procedures to safeguard your data.

   Under Regulation 5 of the Information Technology (Reasonable Security and Procedures and Sensitive Personal Data or Information) Rules, 2011, we are obliged to provide every registered user of iCapital Finance Pvt Ltd with a readable copy of the personal information you have provided us.

10. Changes to this Privacy Policy

    This Privacy Policy is published on the application/website in compliance with Regulation 4 of the (Indian) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.

    We update this Privacy Policy periodically. The date of last revision appears at the top and all changes take effect immediately upon posting. Your continued use of the Services shall imply your acceptance to any such modifications.

    If you do not agree with the terms of this Privacy Policy or any changes made to this Policy, please stop using all Services immediately and write to us at the address mentioned above.