Last updated on: 10/05/18
This Policy explains how we at Oxane Partners collect, use, retain and disclose Personal Information collected from you on our website.
Oxane Partners is an advisory firm that supports alternative investment managers across their investment lifecycle. We support investment teams through all the phases of an investment including pre-screening, investment analysis, and portfolio monitoring. You can find more about us at http://www.oxanepartners.com/about-us.php.
We are the data controller for the information we get from you on your visit to our website.
Our information handling practices are continually reviewed to ensure that they comply with the European Union General Data Protection Regulation (GDPR), 2018 as well as “Reasonable Security Practices and Procedures and Sensitive Personal Data or Information Rules, 2011” under Section 43A of the Indian Information Technology (Amendment) Act, 2008.
As customers, you provide data to us for processing as part of usage of Oxane's services and platforms.
Customer Data may be processed by us as a result of customer’s use of the Services when our customers, or their end-users, provide us the information or upload the information in our platforms. For example, customers who use our <Asset Management> platform may upload Customer Data about their customers
How we use your personal data will depend on which Services you use and how you use those Services.
Customer Data will be used by Oxane in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. Oxane is a processor of Customer Data and Customer is the controller.
Other Data is used by us to for:
We establish lawful basis to process your personal data. We also use your consent as bases for lawfully processing your personal data.
We process your personal data only when we have a lawful basis. Presently, we use the Performance of Contract (i.e. to deliver the services to our customers) and consent as the lawful basis for processing. For certain processing, we may also use legitimate interests as provided under the Data Protection Regulations.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where you have consented to a particular processing, you have a right to withdraw the consent at any time.
Oxane will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. When you decide to close your account, we delete all personal information about you.
On our website, every page that collects Personal Information from you, states the purpose of collection of information. If you agree to the purpose, you can provide your information and thus give your consent to us to use the information provided for the stated purpose.
If, at any point, we decide to use your Personal Information for a different purpose, we will notify you and obtain your consent.
You can withdraw your consent at any point in time by reaching out to us as at details mentioned in the “Contact Us” section. Consequences of withdrawal will be communicated to you and, on your agreement, your request for withdrawal will be processed.
Yes. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
Our website uses Google Analytics. Cookies on our website collect information about how you use our website, for example which pages are visited most often. These cookies don't gather information that identifies you. All information the cookies collect is anonymous and is primarily used to analyse how you interact with the website and improve your website experience.
Below is a list of Google Analytics cookies used on our website along with a description of what they are used for. For more information on these cookies visit: https://support.google.com/analytics/answer/6004245
|Sl. No.||Name of Cookie||Expiry period||Purpose|
|1||_ga||2 years||Used to distinguish users visiting our website|
|2||_gid||24 hours||Used to distinguish users visiting our website|
|3||_gat||10 minute||Used to throttle request rate, i.e., control usage of application interfaces by users|
Personal Information collected from you will not be disclosed to any third parties without your consent. Exception to this is when such disclosure is necessary for compliance to any legal and/or law enforcement obligations. We will do so after following necessary due processes.
We will make every effort, where possible, that such mandated disclosures are communicated to you.
When Personal Information is directly collected from you, you can communicate any update or correction to your Personal Information by reaching out to us as at details mentioned in the “Contact Us” section. We will verify your identity before we update or correct your Personal Information.
We are committed to protecting your Personal Information in our custody.
We take reasonable steps to ensure appropriate physical, technical and managerial safeguards are in place to protect your Personal Information from unauthorized access, alteration, transmission and deletion.
Your data will be stored and processed in countries including outside of the European Union (EU) Region
Since we are an international company, your data will be processed outside of the EU region. Your data will be processed from our office in India.
Oxane offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. These clauses are contractual commitments between parties transferring personal data (for example, between Oxane and its customers, suppliers or data processors outside the EU), binding them to protect the privacy and security of the data.
Our website has links to third-party websites. We will not be held responsible for compliance with data protection requirements or the content of such websites.
Our website is not designed to be used by children aged below 16. Personal Information of children will not be knowingly collected by us.
If you are under the age of 16, you are not permitted to use the Sites and Services or to disclose Personal Information. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.
In case you are accessing the website from within the European Economic Area, we are committed to providing you with the following additional rights where you can:
|Rights under GDPR||How we facilitate your rights|
|Right to be informed||
|Right of access||You can contact us to get access to your Personal Information along with information regarding its purpose, disclosure, categories of Personal Information, storage period, source of collection of Personal Information, confirmation whether or not they are being processed|
|Right to rectification||You can contact us to get your Personal Information corrected or updated|
|Right to erasure||You can contact us to get your Personal Information deleted or erased|
|Right to restriction of processing||
You can contact us and request restriction of further processing in case:
|Right to data portability||You can contact us to get your Personal Information in a structured, machine-readable format and if you want, can have it transmitted to another organisation|
|Right to object||
You have a right to object to direct marketing.
You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation ("GDPR"), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation.
|Right not to be subject to Automated individual decision-making, including profiling||We do not process your Personal Information for automated decision making including profiling|
|Right to lodge a complaint with the Supervisory Authority||
You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of an alleged infringement of the General Data Protection Regulation
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available at: https://ico.org.uk/global/contact-us/
We will verify your identity when you exercise these rights. For exercising your rights and getting information about any limitations which apply on them, you can reach out to us at the contact details given below.
You can opt-out of direct marketing communications sent from us by clicking on the ‘Unsubscribe’ link provided in the e-mail. Also, you can contact us and request objection to such processing.
We implement security controls to prevent breaches and unauthorised access to your data.
We maintain reasonable and appropriate security measures to protect Customer Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Examples of security measures include physical access controls, HTTPS, restricted access to data, monitoring for threats and vulnerabilities etc.
Our Sites and Services uses commercial efforts to maintain safeguards for protection of your Personal Information
Oxane takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.
For any further queries and complaints related to privacy, or exercising your rights under GDPR, you could reach us at:
Name of Person: Nikhil Garg
Contact No.: +44 (20) 7993-6893
Kemp House, 152 City Road
London, England EC1V 2NX
Your queries will be addressed within one month of receipt of such requests. In case of any delay in addressing such requests, the delay will be communicated to you within the same month of receipt of request.