Privacy Policy

This privacy policy is effective from 13 th March 2025

At Induscap Wealth Private Ltd (the “Company”), your privacy is very important to us. We also value transparency and want to be clear about how we collect, use and share information about you.

This policy is here to help you understand:

• 1. The categories of information we collect about you

• 2. How we use information we collect

• 3. How we share information we collect

• 4. How we store and secure information we collect

• 5. Other important privacy information

This Privacy Policy applies to you when you access or use any domains or subdomains of Induscap Wealth Pvt Ltd’s website at https://induscapwealth.com/

WHAT INFORMATION WE COLLECT ABOUT YOU

We collect the categories of personal information listed below:

• 1. Directly from you when you provide the information to us,

• 2. Indirectly from you when you use or access our Services, the Site, or the Application, and

• 3. From other sources like third-party service providers and partners.

Information you provide to us

We collect information from you when you input it or otherwise provide it directly to us.

Account Information: We collect information about you when you create an account or sign up for Services.

Depending on the Services you select, you provide your address, date of birth, and taxpayer ID, such as a PAN or other government issued ID number. We collect this information to verify your identity as required by Indian law. If you register or use the Services through third-party sites or applications, such as Google, we may gather information from them.

Bank, Brokerage and Other Payment Information: To transact with us, you provide your banking information, including bank account, to permit you to send funds to us or receive funds from us. You may also provide us other payment information when you elect to send funds to us using alternative payment methods.

Buyer Information: To make investments with us, when you submit your KYC documents you provide us information concerning whether you are investing on your own behalf or that of an institution, your investment objectives, risk tolerance, investment time-horizon, investment experience, and information concerning your income and/or net worth. You also provide certain commercial information and information about your investment preferences, which become a part of your investor profile, and may include how much you anticipate investing in certain asset classes, your target investment size per investment, the asset classes you have invested in, and sectors of interest.

For investments related to some issuers, you may also provide us employment information or representations that you are not affiliated with, or employed by, a competitor of that issuer. If you express interest in investing in a particular investment opportunity, you provide us information about your interest and preferences which may include the investment amount and other information regarding your interest in making an investment.

Seller Information: To sell private company equity with us, you provide us information and documents concerning your ownership of shares or options. For example, you provide information about the company in which you own the shares, ownership type, and the number of shares you want to sell. If you are a seller, you also provide us information and documents reflecting your vesting and other attributes applicable to your shares or options. You may also be asked to provide your spouse’s name and email address if you are married. You also provide information about your preferences, such as, for example, the price at which you desire to sell your shares.

Support Information and Other Communications: The Services include customer support, where you may choose to submit information or questions concerning a problem you are experiencing with a Service or questions you have about a Service. You may also provide, or be asked to provide, screenshots, documentation or information to help us address your problem or respond to your question. You may also provide us with feedback and survey responses when using the Service, as well as other information you voluntarily provide to us when communicating with us, such as via email, any chat bots available on the Site and/or the Application, or via other actions you perform when using the Services. You may also provide us with your marketing and email preferences in your account settings.

Trust Information: If you purchase or sell securities held in the name of the trust, you provide us with additional information and documents concerning the identity and contact information of individuals related to the trust.

Verification Information and Documents: If required to help us verify your identity, you may provide us a copy of your Aadhar card, Pan card, driver’s license, passport or other government issued ID. If required to help us verify your address, you may provide a copy of your Aadhar card, utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, Client Master List by your demat service provider. By providing the verification information and documents mentioned above, you also provide us information within those records, which may include characteristics of protected classifications like your sex, age, national origin, and citizenship status.

Voluntary Information: If you authorize your accountant, financial advisor, lawyer or relative to receive information about our Services on your behalf, or to take actions on the Site on your behalf, you provide us the name and contact information for the person you authorize. If you are a selling shareholder and have a preferred representative at your current or former company with whom you’d like us to communicate, you provide us the name and contact information of that preferred representative.

Cookies, Web Beacons, Pixel Tags and Other Similar Technologies: Induscap Wealth Private Ltd and its third party service providers, such as our analytics and advertising partners, collect certain information using cookies, web beacons, pixel tags and other similar technologies to provide functionality, enable and support security features, recognize you across different devices, improve our offerings, understand how you use and interact with our Services, improve performance of Services, and otherwise manage and enhance Services. “Cookies” are simple text files stored on your device for use by a browser. “Web Beacons” or “pixel tags” are small images, often transparent, on a website or email that are used to observe if you have accessed content. Using cookies, web beacons or pixel tags, or other tracking technologies are standard practices on internet web sites.

Some web browsers transmit “do-not-track” signals to websites. At this time, our Services are not designed to respond to these signals or similar mechanisms from browsers.

We use session cookies to make it easier for you to use our Services and to identify you while you are on the Site or Application. We also use persistent cookies to make it easier for you to navigate the Site and track whether you are logged into the Site. A persistent cookie remains on your device’s hard drive for an extended time. You can remove persistent cookies by following the directions provided in your internet browser’s “help” file. If you reject persistent cookies, you will still be able to view the Site, but your ability to use some areas of the Site, such as automatically-generated recommendations, will be limited.

Information we receive from other sources

We receive information about you from third-party services and business partners.

Third-Party Identity Verification Service Provider: We receive information about you from a third party identity verification service provider to help us confirm your identity, prevent fraud, money laundering and other illegal activity, and to satisfy legal requirements relating to the Services.

Marketing and Advertising Services and Partners: We receive information about you and your activities on and off the Services from third-party service providers, such as Google, LinkedIn and other advertising, social media and market research partners who provide us with information about you, and/or your engagement with and interest in our Services.

Business Partners: We may receive information about you from our third-party partners, under referral programs, partnership agreements and/or under joint marketing arrangements.

HOW WE USE INFORMATION WE COLLECT

We use the information we collect based on the Services you choose to receive. The specific purposes are described below.

To Communicate With You About the Services: We use your contact information to send communications to you (typically via email/whatsapp/call) about your transactions, including confirming the terms on which you purchase or sell securities, updating you on the status of transactions and related deadlines, responding to your questions or comments, and providing information received from the issuer or, when applicable, other parties to your transactions.

To Operate the Services: We share information about you as needed with our own service providers, including financial institutions, fund administrators, accountants, auditors, lawyers, payment providers, information technology staff, advisors and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Site and the Services.

For Research and Development: We strive to make our Services better, smarter, faster, more secure and easier to use. We collect information about how people use the Services and feedback provided directly to us to identify trends and problems, usage and activity patterns, and areas for integrating and improving our Services. We may also test and analyze certain new features with some users before rolling out the features to all users.

To Market, Promote and Drive Engagement With the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of interest to you, including by email and by displaying our content on other websites and applications, such as on platforms including Google, twitter, LinkedIn or Facebook. These communications are intended to increase engagement and what you get out of the Services, including information about new features, new content, and events we think may be of interest to you. We also communicate with you about new products and services and promotions.

We do not – and do not plan to – rent or sell personally identifiable information about you to other people or to non-affiliated companies.

As Required by Law or Regulations: We retain information about you that is required by law or regulation, including those applicable to the sale of securities. In general, we are required to retain these records for at least three years, and up to seven years (and in some circumstances, longer).

We may keep some information longer to meet our needs and those of our customers, even after you close or deactivate your account, including for backup, archives, contract enforcement, dispute resolution.

For a Merger, Sale or Other Asset Transfer: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, creation of a trust or other affiliated entity, receivership or sale of Induscap Wealth Pvt Ltd’s assets, or other corporate transaction affecting us, your information may be shared, transferred or sold under a duty of confidentiality as part of a transaction as permitted by law or by contract.

HOW WE SHARE INFORMATION WE COLLECT

We buy & Sell of Unlisted / Private companies & other financial products & services. This means sharing information through the Services and with certain third parties. We share information we collect about you with third parties in the ways discussed below, including in connection with possible business transfers.

With Affiliates of Induscap Wealth Private Ltd: If you are a party to a prospective or actual transaction, we share information about you with our affiliates to provide you Services relating to that transaction.

With Parties to a Transaction, Companies and Service Providers: If you are a party to a prospective or actual transaction, we will give the other party (or other parties) to the transaction the information they need to evaluate and enter that transaction. If you enter into a transaction with a third-party company, such as by becoming a shareholder, that company will receive information about you subject to its own privacy policy, and may be required to disclose that information to its own board members, officers, investors or shareholders.

We also provide your information where necessary for a transaction or to comply with legal requirements. For example, we may provide certain aspects of your information to financial institutions, payment processors, fund administrators, accountants, auditors, lawyers, payment providers, third-party hosting service, email and technology service providers, information technology staff, advisors, affiliates, marketing and analytics partners, or third-party verification services.

As part of providing their services to us, our marketing and advertising service providers mentioned above may use cookies and other technologies. This may include, for example, a device's IP address, device type (unique device identifiers), browser information, and geographic location (region and/or country only).

We do not and will not sell your personally identifiable information. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or services in exchange for your data.

We may share aggregated, deidentified and/or anonymized information that does not specifically identify you or any individual user of our Services for any purpose with any third-parties, including but not limited with advertisers, national industry organizations, and prospective affiliates, or as permitted or required by law, or to protect our rights.

With Regulators: We may share information about you with regulators where we believe doing so is required or appropriate to comply with any laws, regulations or other legal processes or law enforcement requests, such as court orders or subpoenas.

We may also share information about you to protect the security and integrity of our Services, to protect Induscap Wealth Private Ltd interests, or those of other persons or the public.

With Business Partners: We may share information about you with our third-party partners under referral programs, partnership agreements or under joint marketing arrangements.

With Third-Party Sites: The Site may contain links to third party web sites and may redirect you to third party web sites ("Third Party Sites"). These sites include, among others, service providers who have a relationship with the Company. Third Party Sites are not under our control, and we are not responsible for any Third Party Sites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes or updates. The inclusion or access to Third Party Sites does not imply an endorsement thereof by the Company, or of the provider of such content or services, or of any third party web site. The Company reserves the right to terminate any link or linking program at any time. Please be aware that when you enter a third party web site, any information you provide, including financial information, is subject to the terms of use and privacy policy of that site.

With Your Consent: We share information about you where you have given us consent to do so for a specific purpose. For example, we may disclose information to your financial advisor, accountant , respective Investment company, our Partners, attorney or spouse, or other individual or company you authorize to receive information about you.

Business Transfers: We may share or transfer information we collect under this privacy policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Services if a transaction takes place, as well as any choices you may have regarding your information.

HOW WE STORE AND SECURE INFORMATION WE COLLECT

We take steps to ensure that your information is treated securely and in accordance with this policy. While we use industry-accepted security principles, practices, and tools, the internet is not 100% secure and we cannot ensure or guarantee the security of data, during transmission through the Internet or while stored on our systems or otherwise in our care. We do not accept liability for unintentional disclosure.

By using the Service or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service.

If we learn of a security breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice in writing.

Children’s Privacy: The Site and our Services are not directed to any person under the age of 18. If you become aware that your child has provided us with personal data without your consent, please contact us at info@induscapwealth.com. We do not knowingly collect or solicit information from, market to, or accept services from children.

Lost or Stolen Information: You must promptly notify us if you become aware that any information provided by or submitted to the Site is lost, stolen or used without permission.

Changes to this Policy: Each time you visit the Site or use the Services, the current version of the Policy will apply. When you use the Site, you should check the date of this Policy (which appears at the top of the Policy) and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. Unless stated otherwise, our current Policy applies to all information that we have about you. We may require you to affirmatively assent to a revised version of this Policy as a condition of continuing to use the Site or our Services.