Interpretation

The terms as may be used in this document would be in accordance with “The Information Technology Act 2000 as amended till date, Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011” and such other rules/regulations and Circulars as may be applicable.

All references to the masculine shall include the feminine and all references, to the singular shall include the plural and vice-versa. All references to client/customer/investor whether masculine or feminine include references to non-individuals also unless repugnant to the context thereof.

Any reference to any statute or statutory provision shall be construed as including a reference to any statutory modifications or re-enactment therein from time to time.

Headings are for ease of reference only.

UTI Alternatives Pvt. Ltd. (‘UAPL’, formerly known as UTI Capital Pvt. Ltd.) is Investment Manager of Category II Alternative Investment Fund(s), under Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012, it is also registered as the co-investment portfolio manager under Securities and Exchange Board of India (Portfolio Managers) Regulations, 2020. UTI Alternatives Private Limited is a multi-asset class alternative investment management platform of UTI AMC – India’s oldest mutual fund company.

UTI Alternatives manages private market investment strategies across various segments in India – Credit, Real Estate, Distress Assets and Equity.

We appreciate the importance of keeping the information collected confidential. We take due care to protect client information.

UAPL recognises that the lawful and correct treatment of personal data is very important to maintain investor's confidence in ourselves. It is our endeavor to ensure that any personal data that we collect, process, record or use in any way whether it is held on paper, on computer or other electronic media will have appropriate safeguards in place to comply with our obligations of confidentiality and privacy. This policy, “Policy on Privacy and Security of Information” is applicable to all channels of your communication with UAPL that include physical (e.g., paper forms),

In this regard, investors/clients/customers should carefully read the “Policy on Privacy and Security of Information” available on company’s website

In the course of using the UTI ALTERNATIVES PRIVATE LIMITED (“UAPL”) website for availing the products and services of UAPL (hereinafter referred as “UAPL” / “We”/ “Us”) and its affiliates/agents/service providers may become privy to the personal information of its investors, vendors, distributors (hereinafter “Provider of Information/ Provider”), including information that is of a confidential nature.

We are strongly committed to protect the privacy of the provider of Information and have taken necessary and reasonable measures to protect the confidentiality of the customer information. This Policy (as amended from time to time) describes how we handle and deal in personal information that we may collect and retain, vide various avenues including but not limited to usage of the various services both in the physical (offline) and online/electronic mode.

Personal Information collected by us vide the physical (offline) and online/electronic mode may be converted and stored in an electronic form at our sole discretion for the purposes mentioned hereunder.

We shall not be held liable, in any manner whatsoever, for disclosure of the confidential information when in accordance with this privacy commitment or in terms of the agreements, if any, with the Provider of Information.

Personal Information:

The Personal Information that we collect from the Provider of Information may include information that is confidential in nature and shall mean and include any information that relates to a person, which either directly or indirectly, in combination with other information that is available or likely to be available to us, is capable of identifying the Provider of Information (“Personal Information”).

The type of Personal Information collected from the Provider and covered under this Policy shall include the following, relating to:

• Full name
• Address
• Telephone/mobile number(s)
• Permanent Account Number (PAN)
• Date of Birth
• Gender Identity
• Bank Account details, change of bank account details or registration of multiple bank accounts etc. through application forms;
• Payment instrument details at the time of submitting application at the time of investment or as proof for carrying out change of bank account or any other details of debit card obtained (if any);
• Demat Account details like beneficiary account no. etc.;
• Annual Income and savings profile; and
• E-mail address
• Any other information as defined under Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, as may be required by Us from time to time in order to provide services to the Provider of Information.

Provided that, any information that is available or accessible in public domain shall not be regarded as sensitive personal data or information for the purposes of this policy. The Provider of Information

herein shall have the right to approach and modify the Personal Information that has been retained with Us. We shall not be responsible for the accuracy of the Personal Information that is being provided by the Provider of Information.

Collection of Personal Information:

You provide personal information while getting onboarded in any of the funds managed by UAPL

In addition to personal information, you provide to us, we may receive information about you that you authorize third parties such as distributors to provide to us.

UAPL may, also call you to inform the other products or services offered by the UAPL. The personal information may also be collected to be compliant with the Know Your Client (KYC) norms under the Prevention of Money Laundering Act, 2002, (PMLA), the rules issued thereunder, and guidelines and circular on Anti- Money Laundering issued by SEBI and SEBI (Alternative Investment Funds) Regulations, 2012 as amended till date.

The aforesaid information is the basis of our ability to provide investors/clients/customers with good, qualitative, timely and efficient service, while also keeping the information and data provided totally secure and confidential.

The Provider of Information agrees and understands that the Personal Information collected by us shall be processed, stored and used by us, and the same may also be passed to, transmitted to and processed by our affiliates and other data processors, agents or service providers acting under a contract with us for the purposes identified herein. Such affiliates, data processors, agents and service providers are also subject to protection and sharing of the Personal Information only for the purpose for which it was shared or with our/your consent and prohibiting use of Personal Information/data for cross marketing.

We permit the Provider of Information, as and when requested by them, to review the information they had provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be rectified, corrected or amended as feasible, provided we shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by the Provider of Information Us or any other person acting on behalf of Us. Further, the following rights are always available to the Provider of the Information:

1. The right to be informed: You are having the right to be informed about the processing of your Personal Information as to how it is processed and whom else the data may be passed to.

2. The right of protection and access: You have the right to the protection of Personal Information and see/access what Personal Information/data is held about you.

3. The right to update/review or rectification: You may ask us to have your Personal Information/data updated or corrected or amended if what is held has undergone change or is incorrect in any way.

4. The right to withdraw/erasure/forget: Under certain circumstances you can ask for your Personal Information /data to be deleted. This would apply if the Personal Information /data has been unlawfully processed and/or shared.

5. The right to restrict processing: You may request for a temporary halt to processing of Personal Information/data, such as in the case where a legal case has to be concluded, or the data is being corrected.

6. The right to data portability: You have the right to ask for your Personal Information /data supplied directly to be provided to you.

7. The right to object: You have the right to object to further processing of the Personal Information /data which is inconsistent with this policy.

In case you wish to exercise any of your rights as laid down in this Policy, you may approach Us in a manner as mentioned in this Policy.

Please note that any of your rights/requests as mentioned in this Policy shall be subject to applicable obligations including laws, rules and regulations, directions of the statutory authority/regulatory body/law enforcement authorities, courts or for reporting purposes. Kindly note that we may share/report your Personal Information/data or any other information without any restriction where such sharing/reporting is in the aggregate without any specific information relating to an identifiable/you.

Please note that on exercise of such rights/requests, we may not be able to provide you the services or the services may be suspended, interrupted, delayed or may not be error free or may not be to the desired level of satisfaction.

Security Standards and Measures:

We have adopted reasonable security practices and procedures and have implemented such reasonable security practices and safeguards which are appropriate to the sensitivity of the Personal Information. These security practices and standards are consistent with generally accepted standards of commercial business practice, which includes technical, operational and physical security control measures which commensurate with the Personal Information being protected from any unauthorized access and/or disclosures while the same is with Us.

The Provider of Information, especially the investors agree and understand that trusted third parties who act on our behalf for performing certain functions such as processing of transactions, issuing account statements etc. are under contractual obligations to ensure reasonable security safeguards commensurate to the sensitivity of the Personal Information being handled by them.

UAPL endeavours to have suitable technical, operational and physical security controls, safeguard and ensure the security of the information provided by the Provider of Information and uses encryption technology wherever applicable, for the storage and transmission of the information, and such encryption technology is currently permitted in India. We would ensure to enter into suitable terms with third party service providers in order to protect client confidentiality and follow a non-disclosure or restricted disclosure policy.

We need to provide access to information about you to those employees/third parties who need to know the information in order to perform their work, such as servicing your accounts, providing you with information you request, or notifying you of new products and services. To protect your personal information, we maintain physical, electronic, and procedural safeguards in keeping with reasonable industry standards and practices, and we review and adjust these safeguards in response to advances in technology.

Use of Personal Information:

The Provider (s) expressly agree and understand that:

1. UAPL may use the Personal Information of the Provider for the purposes of Processing of commercial and non-commercial transaction of the Provider, providing him with the services to which he has subscribed and any service- related activities such as processing instructions, responding to service requests, resolve any grievances etc. The same may also be used to contact you whenever required and also to seek your feedback in relation to the offered services.
2. The Contact information (like postal address, e-mail id, mobile /phone number, etc.) may be used to contact/ send periodic information on the services or upcoming events or announcements.
3. The Personal Information may be used to generate statistics and reports for both internal use and for sharing with affiliates, intermediaries, successors, vendors, agents, service providers and advertisers. Such statistics and reports will not contain Personal Information that could identify the Provider of Information, personally.

Disclosure of Personal Information:

You agree that UAPL may disclose the Provider’s information (other than which cannot be disclosed under applicable Indian laws, rules and regulations),

• In order to Conform to legal and/ or statutory requirements or comply with legal process;
• with statutory/regulatory authorities, Government authorities/bodies/agencies mandated under the law to obtain information including sensitive personal data or information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences,
• In order to protect and defend UAPL or its affiliates' rights, interests or property;
• In order to enforce our legal rights, terms and conditions or provisions of the Private Placement Memorandum (PPM) of AIF or any other products or services which the Provider avails/intends to avail.

Sharing of Personal Information with Third Parties:

To the extent required or permitted under law, we may share the Investor’s Personal Information for the uses mentioned here with the following third parties:

• Registrar and transfer agent (s), KYC agencies , Banks, custodians, depositories and/ or authorized external third parties who are involved in transaction processing, , etc., of investors’ investment with Us and/or who are vendors/ service providers/ distributors to whom commission is paid;
• Distributors through whom applications are received;
• Any other organization for verifying the identity of investors for complying with anti-money laundering requirements;
• Any governmental & judicial authority including but not limited to the Reserve Bank of India and/ or the Securities and Exchange Board of India;,
• Certain Personal Information (Address details of the investors, Bank details of the investors, Statement of Account, Unit Holding Details) may be shared with banks, post office, depositories, local & international courier service providers, agents and other intermediaries for correspondence with the Provider of Information and for making payments to the Provider by cheques, drafts, warrants, through electronic clearing services, NEFT etc.

We will advise the third parties, to take reasonable and appropriate steps to maintain the required level of data protection in respect of the Personal Information.

The Personal Information so collected shall be communicated to third parties / third persons only for the reasons consistent with the purposes for which such Personal Information was originally collected or such purposes as authorized by law.

Nevertheless, it is our foremost endeavor to ensure that the Provider’s Privacy is protected at all points in time. The investors/customers/clients (whether existing/prospective) must ensure to recheck the information or data being provided to the UAPL or any person acting on its behalf. Incase if any of the data/information is found to be inaccurate or incorrect, the same should be informed to the UAPL for immediate amendment. The UAPL and any person acting on its behalf shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by the customers/clients (whether existing/prospective).

Retention of Personal Information:

We may retain Provider’s Personal Information for as long as required to provide our services to the Provider of Information or otherwise if required under laws, rules or regulations.

Grievance Redressal:

Any grievance relating to your Personal Information including any concern/issue regarding this policy concerning you may be addressed to rajveer.singh@utialternatives.com with Subject Line: “Grievance relating to your Personal Information”

We shall address any requests/discrepancies and grievances of the Provider of the Information including with respect to processing of information in a time bound manner.

The Grievance Officer shall redress the grievances of Provider of Information expeditiously but in any case within one month from the date of receipt of grievance.

Further, despite our efforts to protect investors/customers/clients privacy, if unauthorized persons breach security control measures and illegally use such sensitive/personal data or information, the UAPL and its affiliates and directors shall not be held responsible/liable.

This Policy is a lawful contract and is supplemental to the terms and conditions agreed to between us and the Provider and is subject to the applicable Indian laws, rules and regulations that have been enacted in this regard. In case of any conflict, including due to any amendments, the applicable Indian laws, rules and regulations shall prevail. UAPL reserves the right to update or amend this Policy from time to time and the Providers of Information are advised to visit this page regularly in order to view the same. No Provider or any other person shall have any right or benefit under any other laws, rules or regulations other than Indian laws, rules or regulations.

By accessing or availing the services/website or provide any information while transacting with us, the Provider/other persons expressly agree to the terms of this Policy.