Last updated 9.26.23

Privacy Policy

This Privacy Policy ("Policy") describes how Bering Capital Management LLP ("we," "us," or "our"), the investment managers of the Bering Capital Fund collects, uses, discloses, and protects personal information obtained by its website, BeringCapitalFund.com (“Website”) in accordance with the applicable laws and regulations of India, including but not limited to the Digital Personal Data Protection Act, 2023 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

1. USER CONSENT
By using this Website and its services (for example, when you visit our Website and read news or browse through various other portions of our Website), you agree to provide consent to our collection, use and sharing of your personal information as described in this Policy.

2. COLLECTION OF PERSONAL INFORMATION

2.1. We may collect personal information from investors, potential investors, and other relevant individuals, including but not limited to:
> Name, address, contact details, and other identification information
> Financial information, including bank account details
> Tax identification numbers
> Information related to investments, transactions, and account balances
> Any other information required for compliance with legal and regulatory obligations

2.2. We may collect personal information through various means, including:
> Application forms and other documents provided by investors
> Communications, such as emails, letters, and telephone calls
> Online platforms and portals
> Third-party service providers, such as custodians, administrators, and distributors

3. PURPOSE OF COLLECTION

3.1. We collect personal information for the following purposes:
>To facilitate the investment process and manage investor accounts.
> To comply with legal and regulatory requirements, including anti-money laundering and know-your-customer obligations.
> To communicate with investors and provide updates on investments.
> To conduct due diligence and risk assessment.
>To improve our services and offerings.
> To protect our legal rights and interests.

3.2. We may also use personal information for other purposes compatible with the original purpose of collection, as permitted by the applicable laws.

4. USAGE OF INFORMATION

4.1. The personal information or any other data provided by you may be used and proceeded by us in the following ways:
> To contact you for queries posted by you on the Website or any other communications from us.
> To share information in aggregate form (i.e., that cannot reasonably identify a particular individual) with third parties for business purposes.
> To disclose your information to a third party if required to do so by law or if, in good faith, we believe that such action is necessary to:
- comply with the law, court order or with other legal process;
- protect and/or defend our rights and property or prevent fraud;
- protect us against abuse, misuse or unauthorized use our products or services; or
- protect the rights, safety and/or property of our personnel, affiliates, users of the Website or the public, including the enforcement of this Policy.

> To operate, maintain, provide features & functionality, and to notify about the enhancements to the Website.
> To provide you any information, products, or services that you may request from us, or which we feel may be of interest to you, where you have consented to be contacted for such purposes.

5. ACCESS AND DELETION

5.1. You retain the right to:
> request specific pieces of the personal information collected by us from you;
> request to entirely delete the personal information that we have collected from you;
> correct or update your personal information;
> object to the processing of your personal information; or
> withdraw consent, where applicable.

5.2. However, we reserve the right to your personal information in the following situations:
> Any situation where retention of such information is necessary to provide you with services you requested;
> if we use such data only for our internal analytical use;
> all in compliance with applicable laws; or
> if we are required under applicable law to retain certain information.

5.3. You may contact the grievance officer, details of whom are provided herein below, in relation to the above.

6. SECURITY MEASURES:
6.1. We implement reasonable security measures to protect personal information from unauthorized access, disclosure, alteration, or destruction. These measures include physical, technical, and administrative safeguards, such as encryption, access controls, firewalls, and regular security assessments.

6.2. We restrict access to personal information to authorized personnel who need to know the information for legitimate business purposes. We also ensure that our employees and third-party service providers are aware of their obligations to protect personal information.

7. LIMITATION OF LIABILITY
We shall not be liable to any party for any claims, liabilities, losses, costs or damages of any kind, including but not limited to any direct, indirect, punitive, special, incidental, or consequential damages arising out of or in connection with any access, use (or inability to use),reliance upon or distribution of the Website, or any content therein.

8. UPDATES TO PRIVACY POLICY
We may update this Policy from time to time to reflect changes in our practices or legal requirements. We encourage individuals to review this Policy periodically for any updates. The revised Policy will be effective from the date of publication on the Website or as otherwise communicated.

9. GOVERNING LAW
This Policy shall be governed by and construed in accordance with all applicable laws of India. All disputes arising out of or in connection with the Policy shall be submitted to the exclusive jurisdiction of the courts of [●], India.

10. GRIEVANCE REDRESSAL
We respect and are sensitive to the privacy of a user of the Website. If you have any questions about the Policy or collection of information, its use and disclosure practices, you may contact us at [● add email id]. We will endeavor to use reasonable efforts to respond promptly to requests, questions or concerns that you may have in relation to the Policy.

By using our website, you acknowledge that you have read, understood, and agreed to the Policy.