Privacy Policy
The effective date of this Policy is <span class="text-style-link">17 June 2022</span>
This policy applies to information collected by Sorin Advisors LLP and its subsidiaries or affiliated companies (“Sorin”, “we”, “us” or “our”) on [website url], our website (“the Website”/ “our Website”) as well as otherwise.
For the users of the Website, your use of the Website signifies acceptance of the terms of this Policy.
Definitions
“Personally Identifiable Information” or “PII” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a corporate body, is capable of identifying such person.
The information we collect:
1. Information you provide directly to us:
We do not collect Personally Identifiable Information about you, unless you choose to fill out your information on this website through specific provided forms or otherwise provide it to us directly. In general, you may browse our Website without providing any Personal Identifiable Information about yourself.
2. Information we collect from third parties:
We may also collect PII about you from third parties, such as a CV received from a recruiting firm, fit-for-work information received from a physician, background information received from a background check provider. We also collect information from business partners and vendors to support our provision of investment services. The data we collect from such third parties is often in aggregate form and not individually identifiable, though at times may include personal data. For example, we may collect information from providers of market surveys and vendors who aggregate publicly available information. The extent to which we may obtain information from such sources is governed by the third-party source.
3. Information that is passively or automatically collected
We do automatically collect certain information when you visit our website such as IP addresses and other anonymous data including the type of operating system, the type of browser you are using, the time and duration of site visits and the pages visited to provide better usability and personalized experience.
How we normally use information about you
We will process your PII for our legitimate business interests. We may use your PII for the following purposes:
- For the purposes for which you provided it to us or a vendor;
- To establish and maintain contract with you
- For rendering you services;
- To provide the features and services available through the Website;
- To provide and improve our investment services, including evaluating potential investments and managing existing investments;
- To respond to your requests or to send you other communications;
- To process and respond to your inquiries or to request your feedback;
- To improve the content and features of the Website;
- For recruiting purposes
- To enforce the legal terms that govern your use of the Website;
- To administer and troubleshoot the Website
Further, we may use your Personally Identifiable Information solely to respond to your inquiry or to process an application form you have completed on our website or to respond to any legal process or as required by law in response to any court order, subpoena or a law enforcement agency or to take action against any illegal activity and to address any potential threat to the physical safety of a person.
Information sharing
We may share your Personal Identifiable Information with any of our subsidiaries or affiliated entities and our business partners, service vendors or authorized third-party agents located in any part of the world for the purposes mentioned above. We will take measures to safeguard the transfer of your PII to third parties in a manner that complies with the applicable data protection laws.
You acknowledge and agree that we may disclose your PII, if required to do so by law or in a good faith belief that such disclosure is permitted by this Policy or reasonably necessary or appropriate for any of the following reasons: ( a ) to comply with legal process; ( b ) to enforce this Policy, our Terms of Use, or other contracts with you, including investigation of potential violations thereof; ( c )to respond to claims that any content violates the rights of third parties; and/or ( d ) to protect our rights, and property and those of our advisory business units, agents, affiliates, and investors. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
Legal Basis To the extent needed under any applicable laws, our legal grounds for processing your personal data are as follows:
<span class="text-style-link">Legitimate Interests:</span> In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities, such as the following:
- Providing our investment services
- Providing and maintaining our Site
- Analyzing and improving our business and Site
- Communications, including responding to your inquiries about our services
- Addressing information security needs and protecting our investors, and others
- Managing legal issues
<span class="text-style-link">Legal Compliance:</span> We need to use and disclose personal data in certain ways to comply with our legal obligations.
<span class="text-style-link">Honor Our Contractual Commitments to You:</span> Much of our processing of personal data is to meet our contractual obligations to our investors, or to take steps at investors’ request in anticipation of entering into a contract with them
<span class="text-style-link">Protection of Interests:</span> It is necessary to protect your interests or those of someone else
<span class="text-style-link">Consent:</span> Where we collect personal data from a third party that has obtained your consent, we may process your personal data on the basis of consent
Your rights
EU’s General Data Protection Regulations grants the following rights to EU data subjects: Request access to your Personally Identifiable Information and the processing activities on the same.
- Request that your Personally Identifiable Information is rectified if it is inaccurate or incomplete.
- Request erasure of your Personally Identifiable Information in certain circumstances.
- Request restriction of the processing of your Personally Identifiable Information in certain circumstances.
- Right to object to direct marketing.
- Right not to be subject to automated decision-making and profiling
- Object to the processing of your Personally Identifiable Information in certain circumstances.
- Receive your Personally Identifiable Information provided to us as a controller in a structured, commonly used and machine-readable format in certain circumstances.
- Lodge a complaint with a supervisory authority.
- Withdraw your consent provided at any time by contacting us.
To the extent these apply to you, to exercise the rights outlined above in respect of your Personally Identifiable Information please contact the details available in the contact section below. We will endeavor to respond to you within appropriate time as required by the law.
Right to opt out and withdrawal
We respect your privacy considerations and hence provide you an option to refuse to provide your Personally Identifiable Information or information sought to be collected.
You also have the option to subscribe/opt-in to receive newsletters, new alerts and marketing content. You can always opt-out of such options by writing to Connect@PepperSquare.com or click the “unsubscribe” link at the bottom of an email newsletter received by you from us.
Social Networking
We may maintain a presence on social networking and blogging platforms, some of which are operated by third parties, such as LinkedIn, Facebook, and Twitter. This Policy applies to our use of information you submit to us there, but it does not apply to what those third-party platforms do with your information. Those platforms have their own privacy policies, and we encourage you to read them.
Authenticity
We shall not be responsible for the authenticity of the information and it is your duty to ensure that the information provided by you about yourself and any other individual is accurate and updated. If a user provides any information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or we have reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, we have the right to suspend or terminate our relationship at our sole discretion.
Cookies and other technologies
A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that website can remember who you are. The Website may use temporary cookies to store certain data (that is not sensitive personal data or information) that is used by us for maintenance of the Website and its features, and for administration of your account. In the course of optimizing services, we may allow authorized third parties to place or recognize a unique cookie on your browser. We do not store personally identifiable information in the cookies.
Data storage and retention
We shall retain your PII pursuant to the business purposes and in line with our retention policies.
Your PII is stored in databases located on the servers of the cloud-based database management services that we engage.
We will hold your information for as long as necessary to fulfill the purposes set forth in this Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.
Protection of minor’s information
The website is not directed to children under the age of eighteen (18). We do not knowingly solicit PII from or market to anyone under eighteen (18).years of age. If you believe that we have received information from a minor, please notify us immediately and we will ensure that reasonable efforts will be made by us to delete such information from our database.
Links to third party websites
Our website may contain links to other sites including social media sites, whose information practices may be different from ours. You should read such third party’s websites privacy notices and we do not control those sites or their privacy practices. We do not endorse or make any representations about third-party websites.
Our commitment to security
We utilize appropriate physical, technical and administrative procedures to safeguard the information we collect. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
Changes to this Policy
We will continue to evaluate this Policy, and we may make changes to the Policy accordingly. Any changes will be posted here and you should check this page periodically for updates. If we make material changes to this Policy, we will provide you with notice as required by law.
Grievance Redressal
Any grievance or complaint, in relation to processing of information, should be sent to Sorin Advisors LLP in writing to the following contact email ID. Grievance shall be redressed as expeditiously as possible.
Name: Mandar Dandekar
Primary Email Address: info@sorininvestments.com
Address: Unit no. 301, 3rd Floor, Peninsula Chambers, Ganpatrao Kadam Marg, Lower Parel (West), Mumbai, Maharashtra, 400013
The effective date of this Policy is <span class="text-style-link">17 June 2022</span>
This policy applies to information collected by Sorin Advisors LLP and its subsidiaries or affiliated companies (“Sorin”, “we”, “us” or “our”) on [website url], our website (“the Website”/ “our Website”) as well as otherwise.
For the users of the Website, your use of the Website signifies acceptance of the terms of this Policy.
Definitions
“Personally Identifiable Information” or “PII” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a corporate body, is capable of identifying such person.
The information we collect:
1. Information you provide directly to us:
We do not collect Personally Identifiable Information about you, unless you choose to fill out your information on this website through specific provided forms or otherwise provide it to us directly. In general, you may browse our Website without providing any Personal Identifiable Information about yourself.
2. Information we collect from third parties:
We may also collect PII about you from third parties, such as a CV received from a recruiting firm, fit-for-work information received from a physician, background information received from a background check provider. We also collect information from business partners and vendors to support our provision of investment services. The data we collect from such third parties is often in aggregate form and not individually identifiable, though at times may include personal data. For example, we may collect information from providers of market surveys and vendors who aggregate publicly available information. The extent to which we may obtain information from such sources is governed by the third-party source.
3. Information that is passively or automatically collected
We do automatically collect certain information when you visit our website such as IP addresses and other anonymous data including the type of operating system, the type of browser you are using, the time and duration of site visits and the pages visited to provide better usability and personalized experience.
How we normally use information about you
We will process your PII for our legitimate business interests. We may use your PII for the following purposes:
- For the purposes for which you provided it to us or a vendor;
- To establish and maintain contract with you
- For rendering you services;
- To provide the features and services available through the Website;
- To provide and improve our investment services, including evaluating potential investments and managing existing investments;
- To respond to your requests or to send you other communications;
- To process and respond to your inquiries or to request your feedback;
- To improve the content and features of the Website;
- For recruiting purposes
- To enforce the legal terms that govern your use of the Website;
- To administer and troubleshoot the Website
Further, we may use your Personally Identifiable Information solely to respond to your inquiry or to process an application form you have completed on our website or to respond to any legal process or as required by law in response to any court order, subpoena or a law enforcement agency or to take action against any illegal activity and to address any potential threat to the physical safety of a person.
Information sharing
We may share your Personal Identifiable Information with any of our subsidiaries or affiliated entities and our business partners, service vendors or authorized third-party agents located in any part of the world for the purposes mentioned above. We will take measures to safeguard the transfer of your PII to third parties in a manner that complies with the applicable data protection laws.
You acknowledge and agree that we may disclose your PII, if required to do so by law or in a good faith belief that such disclosure is permitted by this Policy or reasonably necessary or appropriate for any of the following reasons: ( a ) to comply with legal process; ( b ) to enforce this Policy, our Terms of Use, or other contracts with you, including investigation of potential violations thereof; ( c )to respond to claims that any content violates the rights of third parties; and/or ( d ) to protect our rights, and property and those of our advisory business units, agents, affiliates, and investors. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
Legal Basis To the extent needed under any applicable laws, our legal grounds for processing your personal data are as follows:
<span class="text-style-link">Legitimate Interests:</span> In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities, such as the following:
- Providing our investment services
- Providing and maintaining our Site
- Analyzing and improving our business and Site
- Communications, including responding to your inquiries about our services
- Addressing information security needs and protecting our investors, and others
- Managing legal issues
<span class="text-style-link">Legal Compliance:</span> We need to use and disclose personal data in certain ways to comply with our legal obligations.
<span class="text-style-link">Honor Our Contractual Commitments to You:</span> Much of our processing of personal data is to meet our contractual obligations to our investors, or to take steps at investors’ request in anticipation of entering into a contract with them
<span class="text-style-link">Protection of Interests:</span> It is necessary to protect your interests or those of someone else
<span class="text-style-link">Consent:</span> Where we collect personal data from a third party that has obtained your consent, we may process your personal data on the basis of consent
Your rights
EU’s General Data Protection Regulations grants the following rights to EU data subjects: Request access to your Personally Identifiable Information and the processing activities on the same.
- Request that your Personally Identifiable Information is rectified if it is inaccurate or incomplete.
- Request erasure of your Personally Identifiable Information in certain circumstances.
- Request restriction of the processing of your Personally Identifiable Information in certain circumstances.
- Right to object to direct marketing.
- Right not to be subject to automated decision-making and profiling
- Object to the processing of your Personally Identifiable Information in certain circumstances.
- Receive your Personally Identifiable Information provided to us as a controller in a structured, commonly used and machine-readable format in certain circumstances.
- Lodge a complaint with a supervisory authority.
- Withdraw your consent provided at any time by contacting us.
To the extent these apply to you, to exercise the rights outlined above in respect of your Personally Identifiable Information please contact the details available in the contact section below. We will endeavor to respond to you within appropriate time as required by the law.
Right to opt out and withdrawal
We respect your privacy considerations and hence provide you an option to refuse to provide your Personally Identifiable Information or information sought to be collected.
You also have the option to subscribe/opt-in to receive newsletters, new alerts and marketing content. You can always opt-out of such options by writing to Connect@PepperSquare.com or click the “unsubscribe” link at the bottom of an email newsletter received by you from us.
Social Networking
We may maintain a presence on social networking and blogging platforms, some of which are operated by third parties, such as LinkedIn, Facebook, and Twitter. This Policy applies to our use of information you submit to us there, but it does not apply to what those third-party platforms do with your information. Those platforms have their own privacy policies, and we encourage you to read them.
Authenticity
We shall not be responsible for the authenticity of the information and it is your duty to ensure that the information provided by you about yourself and any other individual is accurate and updated. If a user provides any information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or we have reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, we have the right to suspend or terminate our relationship at our sole discretion.
Cookies and other technologies
A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that website can remember who you are. The Website may use temporary cookies to store certain data (that is not sensitive personal data or information) that is used by us for maintenance of the Website and its features, and for administration of your account. In the course of optimizing services, we may allow authorized third parties to place or recognize a unique cookie on your browser. We do not store personally identifiable information in the cookies.
Data storage and retention
We shall retain your PII pursuant to the business purposes and in line with our retention policies.
Your PII is stored in databases located on the servers of the cloud-based database management services that we engage.
We will hold your information for as long as necessary to fulfill the purposes set forth in this Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.
Protection of minor’s information
The website is not directed to children under the age of eighteen (18). We do not knowingly solicit PII from or market to anyone under eighteen (18).years of age. If you believe that we have received information from a minor, please notify us immediately and we will ensure that reasonable efforts will be made by us to delete such information from our database.
Links to third party websites
Our website may contain links to other sites including social media sites, whose information practices may be different from ours. You should read such third party’s websites privacy notices and we do not control those sites or their privacy practices. We do not endorse or make any representations about third-party websites.
Our commitment to security
We utilize appropriate physical, technical and administrative procedures to safeguard the information we collect. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
Changes to this Policy
We will continue to evaluate this Policy, and we may make changes to the Policy accordingly. Any changes will be posted here and you should check this page periodically for updates. If we make material changes to this Policy, we will provide you with notice as required by law.
Grievance Redressal
Any grievance or complaint, in relation to processing of information, should be sent to Sorin Advisors LLP in writing to the following contact email ID. Grievance shall be redressed as expeditiously as possible.
Name: Mandar Dandekar
Primary Email Address: info@sorininvestments.com
Address: Unit no. 301, 3rd Floor, Peninsula Chambers, Ganpatrao Kadam Marg, Lower Parel (West), Mumbai, Maharashtra, 400013