1. Purpose and Scope
We, Iron Pillar Holdings Limited (“Company” or “we” or “our” or “us”), are committed to protecting the privacy of the information provider including the customers, vendors, employees and consultants and users visiting the website www.ironpillarfund.com, of the Company (“you” / “your” / “yourself“). We consider privacy and protection of your data/ information to be of high importance. Our practices and procedures in relation to the collection and use of your data/ information have been set out below in this privacy policy (“Privacy Policy”).
For the purpose of this Privacy Policy, sensitive personal data or information of a person (“Sensitive Personal Data or Information”) is as defined under the Information Technology Act 2000 (“IT Act”) and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules 2011 (“SPDI Rules”). Words and expressions used in this Privacy Policy which are not defined herein but defined in the IT Act or SPDI Rules will have the meaning assigned to them thereunder. Please note that usage of the term Personal Information in this Privacy Policy includes Sensitive Personal Data or Information, wherever appropriate and/or mandated under the IT Act and the SPDI Rules.
The aim of this Privacy Policy is to ensure that you understand what personal information we collect about you, the reasons for collection and use, and entities we share it with. By providing your consent to this Privacy Policy, you agree to the collection, use and transfer of your personal information as set out in this Privacy Policy.
2. Collection of information
a. We collect the following Personal Information and Sensitive Personal Data or Information:
Users of the Website
Others including employees
b. You represent that the information or data you provide from time to time is and shall be correct, current and updated and you have all the rights, permissions and consents to provide such information or data. Your providing the data/ information and the Company’s consequent storage, collection, usage, transfer, access or processing of the same shall not be in violation of any third-party agreement, laws, judgments, orders or decrees.
3. Use and Processing of data/ information
a. The personal information collected by the Company may be used for a number of purposes connected with our business operations which may include the following:
i. dealing with requests, enquiries and complaints and related activities, as may be applicable;
ii. legitimate business purposes;
iii. for employment purposes such as payrolling and recording attendance;
iv. for the purpose of payment to vendors/ suppliers;
v. responding to judicial process and provide information to law enforcement agencies or as permitted by law.
b. We may use social media platforms such as LinkedIn and Twitter. If you connect with us through the abovementioned platforms, then such engagement will be subject to the terms of service and privacy policy of the relevant social media platform and you should review the same before connecting with us on such social media platform(s).
4. Disclosure and transfer of your Personal Information (Including Sensitive Personal Data or Information)
a. We do not sell or rent any Personal Information (including Sensitive Personal Data or Information).
b. We may disclose/ transfer your Personal Information (including Sensitive Personal Data or Information) to our partners, associates, advisors, service providers and third parties as necessary or appropriate:
i. to comply with any legal process whether local or foreign;
ii. to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
iii. to our advisors such as lawyers, chartered accountants and financial advisors in connection with business transactions; and
iv. to enforce our policies.
c. The Company may also disclose or transfer the Sensitive Personal Data or Information, to another third party as a part of reorganization or a sale of the assets or business of the Company. Any third party to which the Company transfers or sells its assets will have the right to continue to use such Sensitive Personal Data or Information.
5. Information provider’s rights in relation to their Sensitive Personal Data or Information collected by the Company
a. All Sensitive Personal Data or Information provided to the Company by you have been voluntarily provided to us. You have the right to withdraw your consent at any time in writing by sending an e-mail to us at [email protected], in accordance with the terms of this Privacy Policy. However, please note that withdrawal of consent will not be retrospective in nature and shall be applicable prospectively. In case you do not provide your consent for usage of Sensitive Personal Data or Information or subsequently withdraw your consent for usage of the Sensitive Personal Data or Information so collected, the Company reserves the right to discontinue the services for which the said information was sought.
b. You may write to us at [email protected] to access, review, modify or correct your Sensitive Personal Data or Information or withdraw your consent to provide Sensitive Personal Data or Information. However, we are not responsible for the authenticity of the Sensitive Personal Data or Information provided by you.
c. You agree and acknowledge that your right to access, modify and/or withdrawing your consent to provide Sensitive Personal Data or Information as aforementioned, may be denied or limited by us, as may be required under any applicable law, law enforcement requests or under any judicial proceedings.
6. Security Practices and Procedures
a. We use reasonable security measures to safeguard and protect your Sensitive Personal Data or Information.
b. Notwithstanding anything contained in this Privacy Policy or elsewhere, we shall not be held responsible for any loss, damage or misuse of your data/ information, if such loss, damage or misuse is attributable to a Force Majeure Event. A “Force Majeure Event” shall mean any event that is beyond our reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.
7. Grievance Redressal
Any discrepancies and grievances with respect to processing of Sensitive Personal Data or Information shall be informed to the designated Grievance Officer as mentioned below:
Name: Ashok Ananthakrishnan
Designation: Partner
Email ID: [email protected]
8. Changes to this Privacy Policy
The Company reserves the right to revise and update this Privacy Policy at its sole discretion. Any such revisions will be effective on and from the date of posting the same on the Company’s website and will apply to all information collected both prior to and following the effective date.
© 2023 Iron Pillar
