Privacy Policy

This Personal Data Privacy Policy (Privacy Policy) is applicable to True North Managers LLP and its Affiliates[1] (collectively, True North, we, us and our) and sets out measures to safeguard any information that relates to a natural person which, either directly or indirectly, in combination with other information available or likely to be available with True North, is capable of identifying such person (Personal Information[2]), and which is provided to us or which we obtain relating to an individual (Data Subject or you), including, without limitation:

(a) directors, officers, employees and other representatives of portfolio companies in which True North has made an investment or is considering making an investment;
(b) individual representatives of third party sellers, placement agents, finders, investment bankers, consultants, lawyers, accountants, advisers and other service providers, whether or not engaged by True North;
(c) partners, directors, officers, employees and other representatives of True North;
(d) individuals applying for or enquiring about employment with us;
(e) individuals who consider or do invest with us and their representative agents with whom we interact during the normal course of business; and

[1] ‘Affiliate’ means:

(a) any person that, either directly or indirectly through one or more intermediate persons and whether alone or in combination with one or more other persons, controls, is controlled by, or is under common control with True North Managers LLP (each, a Common Control Entity),
(b) any fund, trust, partnership, co-investment entity, subsidiary, special purpose or other vehicle or other person, which is managed and/ or advised by True North Managers LLP or any Common Control Entity,
(c) the investment manager or investment advisor of any Common Control Entity;
(d) any Common Control Entity of a Person referred to at (b) or (c); and
(e) any other person under common management with True North Managers LLP or any Common Control Entity,
but, notwithstanding any of the foregoing, in no case will any portfolio company in which a True North fund, trust, partnership, co-investment entity, subsidiary, special purpose or other vehicle holds an investment be considered to be an Affiliate of True North Managers LLP.

[2] Rule 1,
(i) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
(f) visitors to our websites and users of any digital services we provide.
We respect the privacy of individuals. We will comply with applicable data protection law which says that the Personal Information we hold about you must be:
(i) used lawfully, fairly and in a transparent way;
(ii) collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
(iii) relevant to the purposes we have told you about and limited only to those purposes;
(iv) accurate and to the extent appropriate, kept up to date;
(v) kept only as long as necessary for the purposes we have told you about;
(vi) disclosed to third parties after providing notice and seeking informed consent from you for such disclosure; and
(vii) kept securely.
This Privacy Policy describes how we collect, use, store, process, disclose and transfer information that we may collect from individuals.
We reserve the right to update this Privacy Policy at any time. We may also notify you in other ways from time to time about the processing of your Personal Information.

We use your Personal Information for a variety of reasonable and legitimate business purposes, i.e.:

(a) Complying with legal or regulatory obligations, such as our obligations regarding know-your-client, anti-money laundering and fraud monitoring;
(b) Performing a contract with you or to take steps at your request before entering into a contract, including to assist you and answer your requests;
(c) Performing a contract with your employer or a shareholder in your employer or to take steps at the request of your employer or a shareholder in your employer before entering into or performing a contract with them;
(d) Obtaining regulatory approvals required for exercise of rights relating to True North’s investments e.g. appointment of True North’s nominees as directors
(e) Other legitimate purposes, such as:
(i) Communicating with you;
(ii) Performing activities relating to client management, financial management and administration;
(iii) Creating, improving and developing our products and services;
(iv) Conducting market research, surveys, and similar inquiries to help us understand trends, client and website visitor needs;
(v) Investigating and resolving disputes and security issues and enforcing agreements;
(vi) Process payments to us or credits to you;
(vii) Monitoring and auditing compliance with internal policies and procedures, legal obligations and to meet requirements and orders of regulatory authorities;
(viii) Processing and considering applications for employment, including evaluating and confirming your suitability for the position and accuracy of any information submitted;
(ix) Arranging emergency medical treatment; and
(x) Providing employee benefits.
We will not use your Personal Information for any purposes inconsistent with those specified above without your permission. If you are uncertain of True North’s need for information that we request from you, please contact the True North representative asking for the information or contact us (see section 10 below) with your query.

We receive Personal Information in various ways, including:

(a) Directly from the Data Subject e.g., when you voluntarily submit information to our website, or send us an email or other written correspondence
(b) Indirectly from other sources e.g., from public records or from a counterparty in possession of the data, such as
(i) where we are conducting due diligence on prospective investee companies or deciding whether to invest in third parties we may also receive Personal Information concerning key personnel;
(ii) our employees may also give us emergency contact information as part of our emergency scenario planning and may give us details of their dependents and of other people in relation to their employee benefits arrangements;
(iii) your employer may provide your Personal Information to us in connection with a service they provide to us or in connection with services that we provide to our clients;
(iv) we may receive information from past employers and others concerning your employment history where you apply for a job with us;
(v) we sometimes collect information from third party data providers or publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations;
(vi) we may record details of emails, telephone conversations or other electronic communications you have exchanged with our employees and other staff members on our information technology systems; and
(vii) we may maintain closed circuit TV records if you visit our premises, for security and safety purposes.
(c) Using Automatic Collection Tools. In addition, we automatically collect certain data from Data Subjects who visit our website. To this end, we use data collection tools (Cookies) on our website to record certain usage information, such as the number and frequency of visitors to the website. This information may include the websites that you access immediately before and after your visit to our website, and which Internet browser you are using. Please see our Cookie Policy for further details on the usage of cookies on our website.

If you provide, or an organization you represent provides, Personal Information to us about someone else (such as one of your directors or employees or someone with whom you have dealings) you or your organization must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described above. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy and any additional statement provided to you, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our information use and disclosure practices, the individual's right to obtain access to and correct their information and to make a complaint, how we will deal with these and, where relevant, the consequences for the individual if the information is not provided.

By visiting our offices and/ or contacting us through our website, or otherwise engaging with us, such as for investor relations purposes, and submitting your Personal Information to us, you consent to:

(a) us collecting, using and transferring your Personal Information as set out in this Privacy Policy.
(b) the transfer, storage and processing of your Personal Information in accordance with this Privacy Policy, including by third parties who may receive and process your Personal Information.
When the Personal Information is pertaining to individuals under the age of 18, prior consent will be sought from the guardians of such an individual before such Personal Information is processed.
If you do not provide some or all of the information requested, we may not be able either to provide you with an appropriate level of service or to fulfil another applicable purpose of collection.

Sensitive Personal Information is Personal Information which consists of information relating to: (i) password; (ii) financial information such as Bank account or credit card or debit card or other payment instrument details; (iii); physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) biometric information; (vii) any detail relating to the above as provided to us for providing service; and (viii) any of the aforementioned information received by us for processing or stored or processed under lawful contract or otherwise.

If you provide us with Sensitive Personal Information, the provision of this information is entirely voluntary and subject to your express consent. However, we may be unable to carry out some activities without this information - for example, we may be unable to process application forms or similar requests. We will use any Sensitive Personal Information in accordance with the consent you give pursuant to section 5 and, where necessary, we may also process such information in the establishment, exercise or defense of legal claims.

Where we do receive Sensitive Personal Information, we will only keep such information for as long as strictly necessary in order to comply with our obligations under the law or contract.

True North will take reasonable steps to protect your Personal Information against unauthorized disclosure. Subject to the provisions of any applicable law, your Personal Information may be disclosed to the parties listed below (whether located in India or overseas) for in connection with processing such Personal Information for the purposes listed in section 2 to:

Rule 3, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

(a) entities within True North;
(b) insurance companies and brokers in connection with staff insurance;
(c) agents, contractors or third party service providers who provide operational services to True North , such as courier services, telecommunications, information technology, advertising, payment, payroll, processing, training, market research, storage, archival, customer support, investigation services or other services to True North ;
(d) any business partner, investor, assignee or transferee (actual or prospective) and their advisors to facilitate business or asset sale transactions (which may extend to mergers, acquisitions and debt or asset sale);
(e) local and overseas financial institutions and their respective service providers;
(f) our professional advisers such as our consultants, auditors and lawyers;
(g) business and charity partners in relation to events planning;
(h) relevant government regulators, government ministries, statutory boards, embassies, or authorities and/or law enforcement agencies, whether local or overseas, to comply with any directions, laws, regulations, rules, codes of practice or guidelines, or schemes issued or administered by any of them;
(i) any other party to whom you authorise us to disclose your Personal Information; and
(j) any person to whom we are required by law to disclose your Personal Information.

We may also disclose your Personal Information to third parties in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets.

In general, we will process and store your Personal Information for at least as long as it is necessary in order to fulfil our contractual, regulatory and statutory obligations. Subject to those qualifications, our goal is to keep such data for no longer than necessary in relation to the purposes for which we collect and use the Personal Information. However, you are responsible for, and we kindly request that you inform us of, any changes to Personal Information. If you have any specific questions in this respect, please feel free to contact us.

We take technical and organizational measures to protect the Personal Information that we hold from misuse and loss and from unauthorised access, modification and disclosure.

Your Personal Information may be stored either in hard copy documents or as electronic data in True North's software or systems or transferred to outside contractors for storage purposes.

We maintain physical security over our paper and electronic data stores and premises, such as locks and security systems. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer system.

Whilst True North takes appropriate technical and organisational measures to safeguard the Personal Information that you provide, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that the security of any Personal Information that you transfer over the Internet to True North cannot be guaranteed.

In case of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Information transmitted, stored or otherwise processed, we will notify details of such breach to relevant regulators and you, as required by law, and take measures to address such breach and mitigate its adverse effects.

You have the right to withdraw consent, request access to, and correction of Personal Information that True North holds about you in accordance with applicable laws.

If you withdraw your consent to any or all use of your Personal Information, depending on the nature of your request, True North may not be in a position to administer or comply with the relevant contractual agreement or arrangement in place. This may also adversely impact and affect your relationship or other agreements or arrangements with True North. True North’s legal rights and remedies in such event are expressly reserved.

All requests for the withdrawal of consent, access to, or correction of Personal Information held by True North shall be made by completing True North 's standard request form (form available here), and sending a copy of the duly completed form to True North at:
Attention: Data Protection Officer,
True North,
Suite F9C, Grand Hyatt Plaza,
Santacruz East, Mumbai,
Maharashtra 400055

You will ordinarily not have to pay a fee to access your Personal Information or to exercise any of the other rights under this Privacy Policy. However, we may, where the relevant law permits, charge a reasonable fee if your request for access is clearly unfounded or excessive (for example, for repeat copies).

We respect your legal rights not to be subject to decisions that are based solely on automated processing of your Personal Information, including profiling, especially where such processing has legal or other significant effects on you. In establishing and carrying out a business relationship, we generally do not use any automated decision making in relation to Personal Information. However, we may process some of your Personal Information automatically, with the goal of assessing certain personal aspects (profiling), such as to comply with legal or regulatory obligations to combat money laundering, terrorism financing, and offenses that pose a danger to assets.

The True North website contains links to third-party websites whose data protection and privacy practices may differ from ours. We are not responsible for the content and privacy practices of these other websites and encourage you to consult the privacy notices of those websites.

This Privacy Policy shall be governed in all respects by the laws of India.

Questions, comments, complaints and requests regarding your Personal Information or this Privacy Policy should be addressed to our Data Protection Officer at:
Data Protection Officer,
True North,
Suite F9C, Grand Hyatt Plaza,
Santacruz East, Mumbai,
Maharashtra 400055