Privacy Policy

1. Introduction

CELESTIAL CHAKRA TRUST (“Trust”, “we”, “our”, or “us”) is a Category II Alternative Investment Fund registered with the Securities and Exchange Board of India (“SEBI”) under the SEBI (Alternative Investment Funds) Regulations, 2012 and is managed by Bahutex Ventures LLP (“Investment Manager”).

The Trust is committed to protecting the privacy and confidentiality of personal information entrusted to us by investors, prospective investors, website visitors, business partners and other stakeholders.

This Privacy Policy explains how we collect, use, process, store, disclose and protect personal information when you visit our website or interact with us.

This Privacy Policy has been prepared in accordance with applicable laws including, where applicable:

• Digital Personal Data Protection Act, 2023;
• Information Technology Act, 2000;
• Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (to the extent applicable);
• SEBI (Alternative Investment Funds) Regulations, 2012;
• Prevention of Money Laundering Act, 2002 and related KYC/AML regulations; and
• other applicable laws and regulatory requirements.

2. Information We Collect

Depending on the nature of your interaction with us, we may collect information including:

Personal Information

• Full Name
• Residential Address
• Email Address
• Telephone Number
• Date of Birth
• Nationality
• PAN
• Aadhaar (where legally permissible)
• Passport Details (where applicable)
• Occupation
• Employer Details
• Income Information
• Financial Information
• Tax Residency
• FATCA/CRS declarations
• Nominee Details
• Bank Account Details
• Demat Details
• KYC Information
• Beneficial Ownership Information
• Investor Classification

Corporate Information

Where investors are entities, we may collect:

• Company Information
• Constitutional Documents
• UBO Information
• Board Resolutions
• Authorised Signatories
• Shareholding Structure
• Regulatory Registrations

Technical Information

When using our website, we may automatically collect:

• IP Address
• Browser Type
• Device Information
• Operating System
• Pages Visited
• Website Usage Statistics
• Cookie Information
• Session Information

3. How We Collect Information

We may collect information through:

• Website contact forms
• Investor onboarding documentation
• KYC documentation
• Subscription documents
• Private Placement documentation
• Emails
• Telephone conversations
• Meetings
• Video conferences
• Regulatory filings
• Service providers
• Publicly available information where legally permissible

4. Purpose of Processing Personal Information

We process personal information for legitimate business and regulatory purposes including:

• Investor onboarding
• KYC verification
• AML compliance
• FATCA / CRS compliance
• Due diligence
• Investor servicing
• Capital call administration
• Distribution notices
• Regulatory reporting
• Fund administration
• Investor communications
• Complaint resolution
• Internal record keeping
• Website administration
• Cybersecurity
• Fraud prevention
• Compliance monitoring
• Audit requirements
• Legal obligations

We process personal information only to the extent necessary for these purposes.

5. Legal Basis of Processing

Where applicable under law, we process personal information based on:

• your consent;
• compliance with legal obligations;
• performance of contractual obligations;
• legitimate business interests; or
• any other lawful basis permitted under applicable legislation.

6. Disclosure of Information

Personal information may be shared only where necessary with:

• Trustee
• Investment Manager
• Custodian
• Registrar & Transfer Agent (RTA)
• Fund Administrator
• Bankers
• Depositories
• Depository Participants
• Statutory Auditors
• Internal Auditors
• Tax Advisors
• Legal Advisors
• Valuation Agencies
• KYC Registration Agencies
• CKYC Registry
• Credit Information Agencies (where applicable)
• Technology Service Providers
• Cloud Hosting Providers
• Regulatory Authorities
• Government Authorities
• Courts and Tribunals
• Law Enforcement Agencies

All disclosures are made only where required by law, regulatory requirements, contractual obligations or legitimate operational purposes.

We do not sell or rent personal information to third parties.

7. International Transfers

Where operationally necessary, certain data may be processed using technology infrastructure or service providers located outside India.

Appropriate contractual and technical safeguards are implemented to ensure protection of personal information in accordance with applicable laws.

8. Data Security

We maintain reasonable administrative, physical and technical safeguards designed to protect personal information against:

• Unauthorized access
• Unauthorized disclosure
• Loss
• Misuse
• Alteration
• Destruction

Security measures may include:

• Encryption
• Secure Servers
• Access Controls
• Firewalls
• Multi-factor Authentication
• Audit Logs
• Regular Security Reviews
• Role-based Access Controls

9. Cookies

Our website may use cookies and similar technologies to:

• Improve website functionality
• Remember user preferences
• Measure website traffic
• Improve user experience
• Detect security incidents
• Generate analytical reports

Users may disable cookies through browser settings.

Certain website features may not function properly if cookies are disabled.

10. Data Retention

Personal information is retained only for as long as necessary to:

• fulfil the purposes described in this Privacy Policy;
• comply with legal and regulatory obligations;
• satisfy accounting and audit requirements;
• resolve disputes;
• enforce legal rights.

Where retention is no longer required, information will be securely deleted or anonymised, subject to applicable legal requirements.

11. Your Rights

Subject to applicable law, individuals may have rights including:

• Right to access personal information
• Right to request correction
• Right to request updating
• Right to withdraw consent where applicable
• Right to seek grievance redressal
• Right to nominate another person under applicable data protection laws
• Other rights available under applicable legislation

Certain rights may be limited where retention or processing is required under applicable law or regulatory requirements.

12. Third-Party Websites

This website may contain links to third-party websites.

The Trust does not control or endorse such websites and is not responsible for their privacy practices or content.

Users are encouraged to review the privacy policies of such websites independently.

13. Children’s Privacy

This website is not intended for individuals below 18 years of age.

We do not knowingly collect personal information from minors.

14. Updates to this Privacy Policy

We may revise this Privacy Policy from time to time to reflect changes in applicable laws, regulatory requirements, business practices or operational processes.

The revised version shall become effective upon publication on this website unless otherwise specified.

Users are encouraged to periodically review this page.

15. Contact Us

For any questions regarding this Privacy Policy, personal information or data protection matters, please contact:

16. Regulatory Statement

This Privacy Policy is intended solely to describe the Trust’s practices relating to the collection, processing and protection of personal information.

Nothing contained in this Privacy Policy shall be construed as an offer, invitation, solicitation, recommendation or advertisement for investment in any Alternative Investment Fund or any other financial product.

Any investment in the Trust may only be made through the applicable Private Placement Memorandum and definitive transaction documents, subject to applicable laws and regulatory requirements.