LAST UPDATED: May 5, 2020
This statement sets out how Nitya Capital, LLC (“Nitya”) is committed to protecting the privacy and security of your personal data (“personal information”). This notice gives individuals information on how their personal information (i.e. information which directly or indirectly identifies you) is processed.
This statement also sets out why we use your personal information (as a controller) and how you may contact Nitya in relation to the use of your personal information.
Nitya conducts the firm’s business in accordance with the highest ethical standards, respecting the firm’s customers, suppliers, and other business counterparties, dealing responsibly with the firm’s and clients’ assets, and complying with applicable legal and regulatory requirements.
COLLECTING YOUR PERSONAL INFORMATION
We may collect certain personal information with respect to institutional clients, other business relationships and employees/applicants, including by way of example:
• Name and contact details
• Tax information
• Nationality, passport or other identification documents
• Details of role responsibilities
• Information on investigations, litigation, court proceedings, civil liabilities or criminal convictions against you
• Employee information required for HR purposes (including payroll, job history) and
• Where permitted, information received from credit reference agencies, fraud prevention agencies and from other public sources.
HOW WE WILL USE YOUR PERSONAL INFORMATION
We will use your personal information for:
• The provision of products and/or services to our investors,
• Managing business relationships with you,
• Archiving documents (electronic and paper based),
• Detecting and preventing fraud and/or money laundering,
• Statistical analysis and assessment,
• Job applicants, employee and training records,
• Communicating with you, and
• Otherwise as is necessary to comply with applicable laws, regulations and/or codes of practice.
The provision of personal information by you may be necessary in order for us and third parties (to which personal information may be disclosed) to provide you with the requested services, for the performance of any contractual relationship with you and for the other purposes as described in this notice.
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose certain personal information:
• To Nitya and its affiliates and subsidiaries,
• To courts, governmental and non-governmental regulators, including tax authorities,
• To law enforcement agencies or as otherwise required under law or regulation,
• To any third party that acquires, or is interested in acquiring, all or part of our assets or projects, or that succeeds us in carrying on all or a part of its business, whether by merger, acquisition, reorganisation or otherwise,
• To credit reference agencies who may use it to perform credit reporting and affordability checks for us and to verify your identity (e.g. age and residence), and to prevent and detect criminal activity, fraud and money laundering,
• To fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity, and
• To our agents, advisers or outsource providers in order to provide agreed products or services.
SECURITY AND DATA RETENTION
Nitya strives to maintain the reliability, accuracy and completeness of all personal information it holds to protect privacy and security at all times. The security measures in place on our websites and computer systems aim to prevent the loss or misuse of the information we hold.
We update and test our security and technology on an ongoing basis. Access to personal information is restricted to those employees responsible for providing benefits or services to you. Employees at Nitya are regularly trained on the importance of confidentiality and keeping your information is kept private and secure.
Subject at all times to applicable laws, we will retain your personal information for a period up to 7 years from the end of the relationship.
Nitya reserves the right to monitor, restrict, delay, intercept and/or record your communication with us. All types of communication such as mails, voicemails, telephone calls or emails can be monitored to comply with regulatory obligations. Nitya may reject, restrict, delay or remove communications which may disrupt our system or pose a security risk. Offensive, unwanted content or spam will be filtered out or destroyed.
HTTP COOKIES IN USE ON THIS SITE
Our cookies help us:
• Make our website work as you’d expect,
• Improve the speed/security of the site,
• Continuously improve our website for you,
• Make our marketing more efficient,
• Collect any personally identifiable information (without your express permission),
• Collect any sensitive information (without your express permission),
• Pass data to advertising networks,
• Pass personally identifiable data to third parties,
• Pay sales commissions.
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TURNING COOKIES OFF
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We may revise and/or supplement our privacy notice from time to time to reflect (including but not limited to), any changes in our business, law, regulation, markets and/or the introduction of any new technology.
ENQUIRIES, REQUESTS OR CONCERNS
All enquiries, requests or concerns regarding this notice or relating to the processing of your personal information, should be sent to Nitya Capital, LLC, 8901 Gaylord Drive, Suite 100, Houston, Texas 77024, Attention: Investor Relations or via e-mail to email@example.com.