Privacy Policy


Privacy Notice and Policy Transparent Capital, or any third party service provider, functionary, or agent appointed by Transparent Capital acting on its behalf (together, the "Transparent Capital managed Fund", "we", "us", "our") are committed to protecting your personal data and are required, by Data Protection Legislation (as defined below), to provide individuals with certain information about how we use your personal information. This privacy notice and policy ("Privacy Policy") explains what information we collect from you or you provide to us, how we use it and with whom we share that information. The Privacy Policy also sets out your rights and who you can contact for more information.

In this Privacy Policy:

● Your information is sometimes called "personal data";

● We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as "processing" such personal data; and

● The term "Data Protection Legislation" means the EU General Data Protection Regulation 2016/679, together with all other applicable legislation relating to privacy or data protection.

For the purposes of Data Protection Legislation the data controller is Transparent Capita.

What information we collect about you ?

We may collect, record and use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data Protection Legislation and as set out in this Privacy Policy.

The personal data we, collect and process may include:

● Information obtained from identification documentation (including your name, contact details, nationality and national identify numbers (where applicable));

● Your professional title, occupation and details of your employment;

● Your age and marital status;

● Financial information, tax status, account details and evidence of ownership of financial assets;

● Personal identifiers such as your social security number, national insurance number, tax file number, IP address or our internal electronic identifiers;

● Information which we or our service providers need to conduct 'know your client' checks such as details relating to your passport and credit history; and

● Other information you provide in the course of your dealings with us or which we require to provide you with products and services. In certain circumstances, we also collect and process what are known as 'special categories' of personal data (as defined by Data Protection Legislation). Money laundering, sanctions, financial crime and fraud prevention checks sometimes result in Transparent Capitalobtaining information about actual or alleged criminal convictions and offences. You are not obliged to provide us with your personal data where it is requested but we may be unable to provide certain products and services or proceed with your business relationship with Transparent Capitalif you do not do so.

How we collect your information?

The information we collect comes from:

● Application forms or other materials you or your authorised representative submits to us during the course of your relationship with the Transparent Capitalmanaged Fund;

● You or your authorised representative's interactions with us, transactions and use of our products and services (including the use of any our website);

● Your or your authorised representative's business dealings us, including via email, telephone or as stated in contracts with you;

● Depending on the products or services you or your authorised representative requires, third parties (including for credit and money laundering checks, among other things); and

● Recording and monitoring tools that we use for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, etc.).


The Transparent Capital shall obtain Your consent in writing (and includes electronic consent) before collecting Personal Information for providing Services. Personal information for purposes of this Policy includes information that identifies you, such as Your name, date of birth, bank account details or credit card or debit card, phone number, fax number or email address etc and include gender, marital status, city of residence. All Personal Information so provided will be on an ‘as on’ basis and Transparent Capital shall not be responsible for the authenticity of the Personal Information supplied by you. Personal Information which is provided or collected from you are solely for the purposes connected with the Terms of Use which has been agreed by you to provide various products or services or facilities by Transparent Capital / Facility Provider / Third Party Service Entity.

Services shall includes all provisions of services and facilities and connected activities which are provided in connection with offering of products and services as a customer of Transparent Capital

You have the option not to provide or agree to the collection of Personal Information. If you choose not to agree with the Policy, you will not be entitled to use the Services as per the Terms of Use. You can also anytime withdraw the consent you provided by writing to us at Address or e-mail at xyz and making a request for termination of the services agreed as per the Terms of Use.


Transparent Capital need this information to operate and provide various products and services. Transparent Capital use, transmit and disclose Your Personal Information only as follows:

● To fulfil Your requests for products and services offered and subscribed and accepted by you and to contact you either through Transparent Capital or their third party service providers through any channel of communication including but not limited to email, telephone, sms, etc.

● To deliver to you any administrative notices, alerts, advice and communications relevant to Your use of the Service

● To Transparent Capital /group companies and its authorised agents and other third party services providers in so far as required for joint marketing purposes, for providing information about products/services of other Transparent Capital/group companies and / or to offer similar services to provide you with various value added services and information including for authentication purposes to enable linking of Your products held with Transparent Capital

● To third-party contractors that provide services to Transparent Capital and are bound by these same privacy restrictions;

● For market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or identification of other criminal activity;

● To conduct check on Your credit information with any of the credit bureau or to conduct a background check either by their employees or through any third party vendor.

● With the abovementioned parties including with any regulatory, statutory or judicial authorities for compliance with any law or regulation in accordance with this privacy policy

● To enforce Terms of Use;.

All such Personal Information collected shall be retained so long as you are having account/product with Transparent Capital or by any of its third party service entities/service provider (“Third Party Service Entity”) and remain active to avail various services/product or as may be required under the law or as per applicable policy on data retention if any. In case of deactivation / termination of the account / services with Transparent Capital, the Personal Information provided may no longer be used for providing the services/facilities and the same may also get removed upon the expiry of the maximum tenure as may be prescribed under the provisions of the law as applicable or the policy on data retention if any. Unless the Personal Information is purged permanently, the Personal Information may remain on the servers and Transparent Capital may however use the Personal Information for data analytics purposes and procedures for improvingthe provisions of services/facilities by them in a non identifiable manner.

How we use your information

Our primary purpose in collecting your personal information is to facilitate and record your holding of shares in Transparent Capitalmanaged Funds, the management and administration of your holding in Transparent Capital managed Funds and any related administration on an on-going basis. Additionally, we use your information for the following specific purposes:

● To process transactions and to improve the quality of the service that we provide to you;

● To disclose information to other third parties such as service providers of Transparent Capita, auditors, regulatory authorities and technology providers for the purposes outlined in this Privacy Policy (as set out in more detail below)

● To communicate with you as necessary in connection with the proper running of the Fund;

● To update and maintain records and carry out fee calculations;

● To monitor and record calls and electronic communications;

● In connection with Transparent Capita’s or Transparent Capita’s managed Funds internal management and reporting;

● To report regulatory and tax related information to regulatory and tax authorities in order to comply with a legal obligation, including any obligation arising under legislation implementing the U.S. Foreign Account Tax Compliance Act of 2010, as amended, and the Organisation for Economic Co-operation and Development's Common Reporting Standard;

● To permit, administer and record your investment in Transparent Capital managed Funds;

● Verifying the identity of the prospective investor to comply with statutory and regulatory requirements in relation to anti-money laundering procedures;

● In order to carry out actions which are necessary to comply with legal obligations in relation to the prevention of fraud, money laundering, terrorist financing, bribery,corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis; ● For prudential and risk management purposes;

● To provide you with any products and services that you request from us; and

● If it is necessary to use it for another reason and that reason is compatible with the primary purpose.

Legal grounds for using your personal information

Data Protection Legislation permits us to process your personal data in the way that we do because the processing is:

● Necessary for the purposes of the legitimate interests that we pursue, which are to run and administer the Fund, to discharge our legal obligations, to store and disclose information where necessary and to evaluate, develop and improve our services; or

● Necessary for the performance of a contract with you; or

● Necessary in order to comply with a legal obligation to which we are subject.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that personal data; (ii) you have made the personal data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.

Providing your information to third parties

The following categories of recipients may receive your personal information and process it for the purposes outlined in this Privacy Policy:

● Third parties such as auditors, regulatory authorities, technology providers, agents, contractors, other service providers or related companies (including payment processors) if this is necessary to administer your investment in Transparent Capital managed Funds, respond to your enquiries or for any other related purposes;

● Any regulatory, supervisory or governmental authorities to the extent we are required by law to do so, and in certain other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud);

● Tax authorities.

The Fund does not undertake marketing activities for third parties, nor does it provide information to third parties for their own marketing purposes.

Your rights

At any time, you have the right:

● To be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences); ● To request access to or a copy of any personal data which we hold about you;

● To rectification of your personal data, if you consider that it is inaccurate;

● To ask us to delete your personal data, if you consider that we do not have the right to hold it;

● To withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);

● To restrict processing of your personal data;

● To data portability (moving some of your personal data elsewhere) in certain circumstances;

● To object to your personal data being processed in certain circumstances; and

● not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information of which we are aware and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.

Retention of Personal Information:

Transparent Capital or any Third Party Service Entity shall not retain Personal Information longer than the Purpose for which it is sought is served or is otherwise required under any other law for the time being in force or in accordance to the data retention policy if any. The Personal Information so collected shall be used only for the Purpose for which it is collected and in the manner agreed by you. Personal Information however may remain on the servers unless otherwise deleted or purged permanently.

How we protect your information

We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect your personal details from unauthorised access.

Third Party Services:

Transparent Capital or its Third Party Service Entity may sometimes permit third parties to offer subscription and/or registration-based services through its Website. Transparent Capital are not responsible for any actions or policies of such third parties and You should check the applicable privacy policy of such party when providing personally identifiable information. Further, Transparent Capital will not be responsible if You do not get the benefits announced if any, by the said third parties permitted to offer subscription or services on its site.

Use of Cookies:

Transparent Capital / its web sites may use "cookies" (information stored on Your computer/Your Computer Resources which include mobiles phones and also APPs) by your browser at our request). "Cookies" is a term generally used for small text files a web site can use to recognize repeat users, facilitate the user's ongoing access to and use of the site, allow a site to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising, preferences etc. Cookies themselves do not personally identify you, but they do identify Your computer, computer resources and devices connected with computer resources and include Mobile phones. Generally, cookies work by assigning a unique number to the computer that has no meaning outside the assigning site. You are also being made aware that Transparent Capital cannot control the use of cookies or the resulting information by advertisers or third parties hosting data on respective Transparent Capital website. If You do not want information collected through the use of cookies, you may change the settings in the browsers that allows to deny or accept the cookie feature as per Your discretion and in the manner agreed by you.

Use of APP

In case of use of facilities/products/services through any APP of Transparent Capital, additional terms and conditions governing the manner of usage of APP including collection and disclosure of Personal Information shall be applicable and to be read along this Privacy Policy.

Links to Other Sites

Our website(s) has links to other website(s) in the World Wide Web. The privacy policies of these website(s) is not under our control. Once you leave our servers, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting. It is advisable to read their privacy policies for further information.


This website is not intended for use by children and minors. Parents are requested to ensure that Personal Information is not provided by minors.

Blocking IP Addresses

Transparent Capital uses the help of Internet Protocol ("IP") addresses to diagnose any problems with its server and to administer its web site including by blocking certain addresses that it feels are inappropriately using its website. IP addresses are used to gather broad demographics information, such as browser types, visitor's country, visiting frequency, operating systems, etc.

Security of Data

Transparent Capital could be subject to verification by a third party for its use of SSL encryption technologies and may also audited by third party auditor for security practice as deemed fit.

Changes to Privacy Policy

This Privacy Policy may be amended from time to time without notice, in which case the date of this Privacy Policy will be revised. If our Privacy Policy changes in any way, we will place an updated version on our website. Regularly reviewing the Privacy Policy ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.


This Privacy Policy is for your information and should not be used as the basis for any decision to purchase or redeem investments in Transparent Capitalmanaged Funds. The views and information expressed in this policy do not constitute and may not be relied upon as constituting any form of investment advice or inducement to invest, and prospective investors must obtain appropriate independent professional advice before making investment decisions