Privacy Policy

01Who We Are

This Privacy Policy explains how Fundamentum VC Advisors LLP (“Fundamentum”, “we”, “us” or “our”), the Investment Manager of The Fundamentum Partnership Fund III, collects, uses, shares and protects personal data when you visit www.fundamentumvc.com (the “Website”) or contact us through it.

For the purposes of the Digital Personal Data Protection Act, 2023 and the rules made under it (together, the “DPDP Law”), Fundamentum is the Data Fiduciary for the personal data described in this policy. We also follow the Information Technology Act, 2000 and the rules made under it, to the extent they apply.

02Scope

This policy applies to personal data collected through the Website, and to emails or other communications you send us using the contact details published on the Website.

It does not cover personal data that investors provide when subscribing to, or holding units in, any fund we manage (for example, KYC and anti-money laundering records). That data is handled under the relevant fund documents and the separate privacy notices given to investors.

03Personal Data We Collect

Information you give us. When you email or call us using the contact details on the Website, we may collect:

• your name;
• your email address and contact number;
• the name of your company or organisation; and
• the purpose of your enquiry and any other information you choose to share, such as a business plan or pitch material.

Information collected automatically. When you browse the Website, we and our service providers may collect technical information such as your IP address, browser and device type, operating system, pages visited, time spent on pages, the referring website and your approximate location (derived from your IP address). We collect this through Google Analytics, as described in Section 06.

Third-party content. The Website embeds a Google Map and loads fonts from Google Fonts. When these load, Google may receive your IP address and browser information under its own privacy policy.

Please do not send us sensitive personal data (such as financial account details, health information or government identification numbers) through the Website.

04How We Use Your Data

We use personal data only for the following purposes:

• to respond to your enquiry and keep a record of our correspondence;
• to evaluate investment opportunities, partnership proposals and other business requests you send us;
• to communicate with existing and prospective investors, portfolio companies, co-investors and other stakeholders;
• to operate, secure, maintain and improve the Website and understand how visitors use it; and
• to comply with applicable law, regulatory requirements (including those of the Securities and Exchange Board of India), and lawful requests from authorities, and to establish, exercise or defend legal claims.

We do not use your personal data for automated decision-making that produces legal or similarly significant effects on you, and we do not sell your personal data.

05Consent and Legal Basis

When you contact us of your own accord and share personal data with us, we process it for the purpose for which you shared it, as a legitimate use permitted under the DPDP Law, unless you tell us you do not want us to use it. Where we rely on your consent, that consent is free, specific, informed and limited to the purposes stated in this policy.

You may withdraw your consent at any time by writing to us at the address in Section 13. Withdrawing consent is as easy as giving it. It will not affect processing already carried out, and we may be unable to respond to your enquiry if you withdraw. Where the DPDP Law allows us to process data for certain legitimate uses without consent (for example, to comply with a legal obligation), we will do so only to the extent permitted.

06Cookies and Analytics

The Website uses cookies and similar technologies set by Google Analytics to measure traffic and understand how visitors use the Website. These cookies collect information in aggregated or pseudonymised form and do not tell us who you are.

You can block or delete cookies through your browser settings, and you can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on. Blocking cookies will not stop you from using the Website. For more information, see how Google uses information from sites that use its services.

07How We Share Data

We share personal data only where necessary and only with:

• service providers who help us run the Website and our business, such as website hosting and management, email and analytics providers, who act on our instructions and are bound by contract to protect your data;
• our professional advisers, such as lawyers, auditors and consultants, under duties of confidentiality;
• the trustee, sponsor and other service providers of the funds we manage, where your enquiry relates to those funds; and
• regulators, courts, law enforcement or other authorities, where required by law or to protect our legal rights.

If Fundamentum is involved in a reorganisation, merger or transfer of business, personal data may be transferred as part of that transaction, subject to this policy.

08Transfers Outside India

Some of our service providers, including Google, may store or process personal data on servers located outside India. Any such transfer will be made in compliance with the DPDP Law and any restrictions notified by the Government of India.

09How Long We Keep Data

We keep personal data only for as long as needed for the purpose for which it was collected, or for longer if required by law, regulation or for the establishment, exercise or defence of legal claims. When it is no longer needed, we erase it or anonymise it so that it can no longer identify you.

10Security

We use reasonable technical and organisational security safeguards to protect personal data against unauthorised access, use, disclosure, alteration and loss, including access controls, encrypted (HTTPS) transmission and limits on who can view enquiries.

No method of transmission over the internet or electronic storage is completely secure. If a personal data breach occurs, we will notify affected individuals and the Data Protection Board of India as required by the DPDP Law.

11Your Rights

Subject to the DPDP Law, you have the right to:

• obtain a summary of the personal data we hold about you and the processing activities carried out on it;
• ask us to correct, complete or update inaccurate or incomplete personal data;
• ask us to erase personal data that is no longer necessary for the purpose for which it was collected, unless we must keep it by law;
• withdraw your consent at any time;
• have your grievances addressed by us; and
• nominate another individual to exercise these rights on your behalf in the event of your death or incapacity.

To exercise any of these rights, contact us as set out in Section 13. We may need to verify your identity before acting on your request. When using these rights, please provide accurate information and do not file false or frivolous complaints.

12Children's Data

The Website is intended for adults and is not directed at anyone under the age of 18. We do not knowingly collect personal data from children. If you believe a child has submitted personal data to us, please contact us and we will delete it.

13Contact and Grievances

If you have a question, request or complaint about this policy or how we handle your personal data, please write to us with the subject line “Privacy”:

We will acknowledge your request and respond within the timelines prescribed under the DPDP Law. If you are not satisfied with our response, you may file a complaint with the Data Protection Board of India.

14Changes to This Policy

We may update this policy from time to time to reflect changes in law or in how we handle personal data. The updated version will be posted on this page with a new “Last updated” date. Where the changes are significant, we will take reasonable steps to bring them to your attention.