At Indus Capital Partners, LLC, we understand the importance of protecting your personal information. As a financial company, we are committed to maintaining the confidentiality and security of the information you entrust to us. This Privacy Policy explains how we collect, use, share, and safeguard your personal information. Please read this notice carefully to understand our practices.
We want to assure you that we do not disclose nonpublic personal information about our current or former clients to third parties, except as described in this policy. We adhere to federal law and prioritize the privacy of your information.
Personal Information We Collect
In order to provide you with tailored advisory services, we collect certain personal information. This information may include:
- Social Security number
- Assets details
- Account balances
- Transaction history
- Income information
- Wire transfer instructions
How We Collect Your Information
We gather this personal information through various interactions with you. This occurs when you:
- Provide us with your contact details.
- Enter into an investment advisory contract with us.
- Purchase securities (such as interests in a fund) from us.
- Inform us of your preferred money transfer methods.
- Initiate a wire transfer.
We may also obtain your personal information from affiliated companies (companies related to us through common ownership or control, which can be financial or nonfinancial) or non-affiliated companies (companies not related to us through common ownership or control, which can also be financial or nonfinancial).
How We Use Your Information
Like all financial companies, Indus Capital Partners needs to share personal information to operate effectively on a daily basis. We utilize the personal information we collect for essential business purposes, including:
- Providing you with our investment advisory services.
- Setting up and managing your account.
- Processing transactions related to your account.
- Informing you about relevant products and services.
- Responding to legal obligations such as court orders and investigations.
Disclosure of Your Information
To ensure seamless service and operations, we may share your personal information with:
- Our affiliates.
- Firms that assist us in servicing your account, such as brokers or fund administrators who require this information to perform their services.
- Service providers and financial institutions with whom we have joint marketing agreements (formal agreements between non-affiliated financial companies to jointly market financial products or services, such as placement agents).
We ensure that all third-party service providers and financial institutions with whom we have joint marketing arrangements are contractually obligated to protect the confidentiality of your information and use it solely for the purposes for which we disclose it to them. These information-sharing practices are in full compliance with federal privacy laws. It’s important to note that federal privacy laws are designed to give you the right to limit certain types of information sharing – types that Indus Capital Partners does not engage in. For example, you can limit the sharing of transaction history or creditworthiness information with affiliates for marketing purposes, or the sharing of personal information with non-affiliates for their marketing purposes, but these are not practices we undertake.
Protecting Your Personal Information
Protecting your personal information from unauthorized access and use is a top priority at Indus Capital Partners. We implement security measures that comply with federal law. These measures include:
- Advanced computer safeguards.
- Secure physical files and building access controls.
Additional Information for California Consumers: CCPA Compliance
If you are a resident of California, the California Consumer Protection Act (CCPA) grants you specific rights regarding your personal information. This section provides additional details as required by the CCPA.
Categories of Personal Information We Collect:
We may collect and use information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. This includes:
- Identifiers: Such as name, address, Social Security number.
- California Customer Records Personal Information Categories: Such as signature, physical characteristics, description, employment history.
- Protected Classification Characteristics: Such as age, gender, citizenship.
- Commercial Information: Such as records of personal property, purchasing or consuming histories.
- Biometric Information: Such as fingerprints, retina scans, keystrokes.
- Internet or Other Electronic Network Activity Information: Such as browsing history, search history, website interaction data.
- Geolocation Data: Such as physical location or movements.
- Sensory Data: Such as audio, electronic, or similar information.
- Professional or Employment-Related Information: Such as current or past job history.
- Non-Public Education Information: Such as grades, transcripts, student disciplinary records.
- Inferences: Drawn from any of the above to create a profile about a consumer.
Sources of Personal Information:
We collect this information from various sources:
- Directly from you: In person, via telephone, text, email, and our website.
- Publicly accessible sources: E.g., property records.
- Third parties: Such as sanctions screening providers, credit reporting agencies, customer due diligence providers.
- Third parties with your consent: E.g., your bank.
- Cookies on our website.
- Our IT systems: Including door entry systems, reception logs, automated monitoring of websites, Wi-Fi, internet browser, computer networks, CCTV, access control systems, communications systems, email, and instant messaging systems.
Purposes for Using Your Personal Information:
We use your personal information for various business purposes, including:
- To fulfill the purpose for which you provided the information.
- To provide, support, personalize, and develop our products and services.
- To create, maintain, customize, and secure your account.
- To process your requests, transactions, and payments, and prevent fraud.
- To provide customer support and respond to your inquiries.
- For testing, research, analysis, and product development.
- To comply with legal obligations and law enforcement requests.
- To count website visits and gauge views.
- To detect and prevent security incidents and illegal activities.
- For debugging and error repair.
- For short-term, transient uses not involving profiling.
- To perform services such as account maintenance, customer service, payment processing, marketing, and analytics.
- For internal research and technological development.
- To maintain and improve the quality and safety of our services and devices.
Sharing Your Personal Information:
We may share your information with:
- Our affiliates.
- Service providers who assist us in delivering services (e.g., fund administrators, payment processors).
- Third parties who help us run our business (e.g., website hosts).
- Third parties approved by you (e.g., consultants).
- Credit reporting agencies.
- Insurers and brokers.
- Banks.
Categories of Personal Information Shared:
In the past 12 months, we have shared the following categories of information with the parties listed above: identifiers, California Customer Records personal information, and commercial information. We do not sell personal information.
Your CCPA Rights:
As a California resident, you have the following rights:
- Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, the sources of the information, the purposes for collecting it, and the categories of third parties we share it with.
- Right to Delete: You have the right to request the deletion of your personal information, subject to certain exceptions.
- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
Please note that these rights are subject to certain legal limitations and qualifications.
Exercising Your CCPA Rights:
To exercise your rights under the CCPA, please contact us at [email protected]. To process your request, we will need to verify your identity. This may require you to provide us with:
- Sufficient information to identify you (e.g., full name and address).
- Proof of your identity and address (e.g., copy of driving license/passport and utility bill).
- A clear description of the right you wish to exercise and the information related to your request.
We will use any personal information collected for verification solely for verification purposes. You also have the option to appoint an authorized agent to exercise these rights on your behalf.
Further Questions:
If you have any questions regarding this Privacy Notice, including the CCPA, please contact Laura Ferchak, Chief Compliance Officer, at [email protected] or 212-909-2888. For individuals with disabilities who require this Privacy Notice in an alternative format, please also contact Laura Ferchak at the provided contact details.
This Privacy Policy is designed to be transparent and informative, reflecting our commitment to protecting your privacy at Indus Capital Partners.
