Privacy Policy

Your privacy is important to us. This
Privacy Policy explains how we collect
use, and protect your information.

PRIVACY POLICY SECTIONS

CBA India Emerging Opportunities AIF (the "Fund"), and its Investment Manager, CBA Asset Managers LLP (collectively referred to as "we", "us", or "our"), are committed to safeguarding the privacy and confidentiality of personal information entrusted to us. This Privacy Policy explains how personal information is collected, used, stored, disclosed, and protected when individuals visit our website or interact with us in the course of our business activities.

By accessing or using our website or services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of personal information in accordance with this Policy and applicable laws.

1. Introduction

2. Information We Collect

We may collect personal information directly from you and/or automatically through your interaction with our website or services, including:

(a) Personal and Contact Information:

Name, residential or business address, email address, telephone number, and other contact details provided through forms, correspondence, or inquiries.

(b) Investor and Financial Information:

Information necessary for onboarding, investor servicing, and regulatory compliance, including Bank account details, investment-related information, and transaction details.

(c) Identity and Regulatory Information:

Information required to comply with Know Your Customer (KYC), Anti-Money Laundering (AML), and other regulatory requirements, including government-issued identification documents, PAN, and other statutory identifiers.

(d) Technical and Usage Information:

IP address, browser type, operating system, device identifiers, and website usage data collected through cookies or similar technologies.

3. Purpose of Collection and Use

Personal information collected by us may be used for the following purposes:

onboarding and servicing investors;
processing transactions and maintaining investor records;
complying with legal, regulatory, and reporting obligations under applicable laws, including SEBI regulations;
responding to inquiries, requests, and communications;
monitoring and preventing fraud, misuse, or security incidents;
improving website functionality and user experience; and
internal record-keeping, risk management, and compliance monitoring.

4. Disclosure and Sharing of Information

We do not sell personal information. Information may be shared only in the following circumstances:

(a) Service Providers:

With third-party service providers, consultants, auditors, custodians, trustees, or technology vendors engaged to perform services on our behalf, subject to confidentiality and data protection obligations.

(b) Regulatory and Legal Disclosure:

Where disclosure is required under applicable laws, regulations, court orders, or requests from regulatory authorities, including SEBI or other statutory bodies.

(c) Business or Structural Changes:

In the event of restructuring, merger, or transfer of the Fund or Investment Manager, personal information may be transferred subject to applicable legal safeguards.

(d) With Consent:

Where disclosure is made with your explicit consent.

5. Data Security

We implement reasonable technical and organizational safeguards to protect personal information against unauthorized access, misuse, alteration, or loss. While we endeavor to use commercially acceptable means to protect personal data, no method of electronic transmission or storage is entirely secure, and absolute security cannot be guaranteed.

6. Rights of Individuals

Subject to applicable law, individuals may have the right to:

access personal information held by us;
request correction or updating of inaccurate or incomplete information;
request deletion of personal information, subject to legal and regulatory retention requirements;
withdraw consent, where processing is based on consent; and
raise concerns regarding the handling of personal information.

Requests may be made by contacting us using the details provided below.

7. Cookies and Website Technologies

Our website may use cookies or similar technologies to enhance functionality and analyze usage trends. Users may manage cookie preferences through browser settings; however, disabling cookies may limit certain website features.

8. Data Retention

Personal information is retained only for as long as necessary to fulfill the purposes for which it was collected or as required under applicable laws, regulations, or internal policies.

9.Children's Privacy

Our website and services are intended for use by adults only. We do not knowingly collect personal information from individuals below 18 years of age.

10. International Data Transfers

Personal information collected by the Fund and/or the Investment Manager may be processed, stored, or accessed in jurisdictions outside India, including where service providers, technology vendors, or professional advisors are located. Any such cross-border transfer of personal data shall be carried out strictly in accordance with applicable Indian laws, including the Digital Personal Data Protection Act, 2023, and subject to such countries or territories as may be notified by the Government of India from time to time.

The Fund and the Investment Manager shall ensure that reasonable safeguards are implemented to protect personal data during such transfers, including contractual confidentiality obligations and appropriate data protection measures, so as to ensure a level of protection consistent with this Privacy Policy and applicable legal requirements.

11. Changes to this Policy

This Privacy Policy may be updated periodically to reflect changes in legal, regulatory, or operational requirements. Any updates will be effective upon publication on the website.

12. Contact Information

For any queries or requests relating to this Privacy Policy or the handling of personal information, please contact:

CBA Asset Managers LLP

(Investment Manager to CBA India Emerging Opportunities AIF)

Email: gaurav@capbridge.in

Phone: +91-8153860231