Privacy Notice

• In the course of using this website or any of the websites under the ‘Shuru-Up’ domain or availing the products and services vide the online application forms and questionnaires, online consents and such other details required from time to time on any of Shuru-Up’s (and/or its affiliates) web platforms or mobile applications, Shuru-Up and/or its affiliates may become privy to some of Your personal information, including which may or may not be of confidential nature. Shuru-Up is strongly committed to protecting the privacy of its users/clients and has taken all necessary and reasonable measures to protect the confidentiality of any customer information.

• For the purpose of these Privacy Policy, wherever the context so mentions “Covered Persons”, "Client", "You" or "Your”, it shall mean any natural or legal person who has visited this website/platform and/or has agreed to or has enquired to open an account and/or initiated the process of opening an account with Shuru-Up (also defined as “Covered Persons”).

•Shuru-Up allows any person to use/visit/browse the website without registering on the website. The term "We", "Us", "Our" and "Team Shuru-Up" shall mean Shuru Ventures LLP.

•This Website is owned, operated and maintained by Shuru Ventures LLP. Access to Your Shuru-Up account and the usage of Your account is subject to Your compliance with all the terms and conditions set forth herein, read along with all documents, including but not limited to; applications forms and undertakings, signed by you during account opening, and any terms/consents/policies included on Shuru-Up’s website/domain, i.e. www.Shuruup.com, including its Terms of Service, Membership Agreements, Investment Agreements and other Policies.

Scope of this Policy

Any natural or legal person who has visited the Shuru-Up website/platform and/or the mobile application, and/or who may or may not have further agreed to initiate the process of opening an account with Shuru-Up shall come under the purview of the scope of this Privacy Policy. Shuru-Up shall at all times follow all rules prescribed under the Information Technology Act, 2000, and rules thereof.

 

  • Collection and Use of information

Information you give us

Shuru-Up may or may not collect your Personal Information to provide services on its web-based platform or mobile application. While opening an account with Shuru-Up, you may be asked for certain Sensitive Personal Data or Information (as defined under the Information Technology Act, 2000) to complete your KYC as per the Prevention of Money Laundering Act, 2002.

Shuru-Up, may or may not, request for sensitive information from You at the time of account opening, which would include but not be limited to, (i) setting a password; (ii) financial information such as Bank account or credit card or debit card or other payment instrument details; (iii) information such as name, contact number, gender, date of birth, residence and employment addresses, father’s/mother’s and spouses names, bank account details, scans/copies of document proofs of address & identity such as Photograph, PAN, passport, drivers license, Aadhaar (voluntarily) etc. (iv) uploading signature proof/photo (v) biometric data, etc. All such information would be for the purpose of: identity verification and background checking for account opening as per KYC & AML Rules, personalising services offered to you, keeping you updated of our products and services relevant to you, information pertaining to our services you’ve subscribed to, and for any legal and regulatory / audit purposes.

Under Regulation 5 of the Information Technology (Reasonable Security and Procedures and Sensitive Personal Data or Information) Rules, 2011, Shuru-Up is obliged to provide every registered user of Shuru-Up with a readable copy of the personal information they have provided us. We would save such information as required by the law, and as directed by the regulators along with such intermediaries regulated by them, for the purpose of offering You our services, and for such further regulatory, audit, and business purposes. We collect Personal Information from you only when you voluntarily use the services provided by Shuru, and/or enquire to begin an association with Shuru-Up and/or complete the process of opening an account with Shuru-Up.


Information we get from your use of our services

Shuru-Up may from time to time collect information, i.e. Non-personal information which cannot be used to identify you personally, while You are using the website or mobile application. Shuru-Up may from time to time collect information such as Non-personal information such as IP (internet protocol) addresses, browser types, the name of your ISP (internet service provider), information about a third party link/URL from where You arrive to our website/mobile application, which pages/URLs do You click on the Shuru-Up website / mobile application, and the amount of time spent on each.

With regard to security, we respect all information provided to us, and take all reasonable steps towards protection of the same. We have implemented technology and policies, with the objective of protecting your privacy from unauthorized access and improper use, and periodically review the same. We maintain procedural safeguards to protect the confidentiality and security of personally identifiable information transmitted to us.

 

  • Aadhaar user consent policy

Voluntary Act

The act of providing your Aadhaar is voluntary in nature, which will only be required for completing your account opening procedure online and for digitally signing the membership agreements (while opening your account with Us) or any investment agreements (While making an investment in any of the Start-ups through our platform). Your Aadhaar may also be used as a proof of address as an alternative choice to drivers license or Passport copy, which is a voluntary decision to be made by You.


Shuru-Up does not store any Aadhaar information

During your account opening process, you do not input any Aadhaar details on the Shuru-Up platform. You would be issuing your Digital Aadhaar to Digilocker, from where Shuru-Up (Shuru-Up is registered as a Requester on the Digilocker platform) would receive information, based on your consent to allow Digilocker to share such information with Shuru-Up, limited to: (1) The last four digits of your Aadhaar / VID (Virtual ID created on the UIDAI website), (2) Full Name, (3) Date of Birth, (4) Gender, (5) Address, and (6) Your Photo. Digilocker is a part of the National eGovernance Division under the Ministry of Electronics & Information Technology (MeitY), Government of India. The Digital Aadhaar issued within DigiLocker is the same as the eAadhaar issued by UIDAI (https://eaadhaar.uidai.gov.in). DigiLocker has partnered with UIDAI to make it available automatically to its users when they link their DigiLocker account with Aadhaar. This act of issuing an eAadhaar within Digilocker and subsequently Digilocker sharing the information limited to the above points, leads to behaving as a physical KYC. Shuru-Up only receives information limited to the above points for the purposes of completing KYC of clients online.

During your account opening process and while making an investment through Our platform, you would also be sharing your Aadhaar with Digiotech Solutions Private Limited. for the purpose of digitally signing the Membership and Investment Agreements. Digiotech Solutions Private Limited. does not share your Aadhaar with Shuru-Up. After the required agreement has been digitally signed by you, a copy of the digitally signed Agreement would be emailed to you and to Shuru-Up for reference/audit purposes. Digiotech Solutions Pvt. Ltd. is a licensed e-Sign ASP (Application Services Provider) with CDAC, compliant with the guidelines laid down by the Controller of Certifying Authorities (CCA), India and UIDAI, to enable you to eSign the any agreements online.


Protection of Data

Shuru-Up is committed to protecting the privacy and security of your Personal Data. Shuru-Up is a "data controller", meaning that we are responsible for deciding how we hold and use your Personal Data. We will comply with data protection law, which says that Personal Data must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.


How We Use Information That We Collect

We use the Personal Data that we collect for the following purposes.

To comply with our legal or regulatory obligations, we may use your Personal Data (and if you do not provide this Personal Data we may not be able to provide our services to you):

• To confirm your identity in order to create your account and ensure that you are eligible to use the services provided on the Website.
• To conduct required anti-money laundering checks on you, and associated financial crime and fraud monitoring, in connection with transactions you may conduct through the Website.
• In the case of investors, to confirm that you are eligible to make investments through the Website in accordance with relevant legislation.
• To enable us to comply with our regulatory obligations, including transaction recording, updates on your investment and fundraising activity on the Website, other compliance responsibilities, and reporting to regulators and governmental authorities.

To carry out our obligations under our contracts with you or others, we may use your Personal Data:

• To process and administer payments and investments in connection with the services provided on the Website.
• In the case of entrepreneurs seeking capital and certain individuals connected to the fundraising business, to assess your suitability for and application to fundraise on the Website, to verify and approve the disclosures you make in your campaign to potential investors, to provide you with any campaign marketing and PR services, to facilitate the investment transactions, and exercise any rights that Shuru-Up may have as nominee.
• In the case of investors, to facilitate any investments you may make, to exercise any rights you may have in connection with those investments including by Shuru-Up as nominee, and to provide fundraising businesses with information about the progress of their campaigns and your investments in their businesses.
• In the case of investors who have completed investments in fundraising businesses, to provide those businesses with information to fulfill obligations to you, and ensure compliance with their corporate or regulatory requirements, such as tax and shareholder reporting.
• In the case of investors who have been referred to Shuru-Up by an independent financial advisor or wealth manager, to share information that we hold about you with your financial advisor or wealth manager.
• To provide you with information about your account, including any campaigns you have created and any investments or payments you have made or have indicated an interest in making.
• To facilitate the participation of you or your business in any supplemental programmes that Shuru-Up may offer such as the Alumni Club, Leedrs Club and Anchor Investor Programme.

We have a legitimate interest in ensuring that the Website and our services operate effectively, and to do this we may use your Personal Data:

• To monitor, improve and administer the Website and the services provided on the Website.
• To contact you to ensure customer satisfaction in respect of our role as a service provider and assist you in getting the best value from our services.
• To respond to customer support or other enquiries requesting information. We may also intercept, record and/or monitor any communication(s) (including telephone calls or other electronic communications) between you and us. We may do so in order to resolve queries in the future and for the purposes of ensuring security, staff training and complying with our regulatory and legal responsibilities. In the case of communications by email you should note that, as emails are not encrypted (and may therefore be intercepted by third parties) and as the identity of the sender cannot be confirmed, you must NOT provide your security details by email.

We also have a legitimate interest in communicating with you and others, facilitating communications between you and others, publicising our business, supporting industry research, and making sure that marketing, advertising, PR, and content we provide is effective, so we may use your Personal Data:

• To enable us to conduct surveys and analysis, aggregate user profiles, identify other potential customers, or enable us or third party academics to conduct research.
• To advertise, publicise and promote our business, and to measure, understand, or improve the effectiveness of advertising we provide to you and others.
• In the case of individuals or businesses that have indicated an interest in Shuru-Up or the businesses fundraising on the Website, to contact you to provide you with information about us or fundraising businesses, and on other selected products and services that we think may be of interest to you (unless you have asked us not to do so).
• To create and share informative content about our business or the industry in which we operate, including contacting you about reports we publish and new products we launch.
• In the case of our commercial and investment partners providing goods or services to investors or entrepreneurs, to pass on information in relation to those goods or services.
• In the case of journalists who are working in the sector in which we operate or related sectors, to provide you with news and updates about our business, businesses that are fundraising on our Website and other relevant industry information.
• In the case of referred investors, to inform the party that has referred you that you have joined Shuru-Up.
• In the case of investors who have completed investments in fundraising businesses, to enable those businesses to contact you with news of developments in the business and keep you informed as to your investment.

We may seek your consent to collect biometric information to verify your identity. We will not collect or use this special category data without seeking your consent first.

In certain other circumstances we may seek your consent to use your Personal Data. In this case we will ask you to confirm your agreement to your Personal Data being processed for a specific purpose, either through the Website or by another means.

 

  • Disclosure and transfer of collected information

Shuru-Up does not share any of your information with third parties except:

1) Disclosure for regulatory compliances: Shuru-Up will share your information with judicial, administrative and regulatory entities to comply with any legal and regulatory requirements.

2) Disclosures with your prior consent: If, at any time, you choose to utilise the integrated services of third party service partners through us, we will share your information with these third party service partners with your prior consent.

3) Disclosure for provision of services: Shuru-Up will share your information with third party vendors of Shuru-Up as necessary for the provision of services. Authorized third party vendors are bound by the same standards of data security practices and procedures as we are under law and contract. They are subject to the same penalties as we are for the unauthorised disclosure of your personal information.

We may also tell you in one of the agreements that you enter into with us (for example the Membership Agreement that you will enter into when signing up to the Website, the Engagement Letter and Campaign Terms & Conditions that you will enter into when you wish to raise funds for your business, or the Investment Agreement that you will enter into when making an investment) or otherwise on the Website that we will disclose certain of your Personal Data in connection with a transaction you conduct through the Website. We may also tell you how we will use or disclose your Personal Data when you provide information to us in certain other circumstances (for example if we are collecting information about a potential fundraise on behalf of a fundraising business

4) Disclosure for research purpose: We may disclose certain of your Personal Data to third party academics to conduct research.

5) Disclosure in case of Corporate restructuring: In the event that we intend to enter into a major corporate transaction, such as a sale of control of our or another business on a stock exchange, we may disclose certain of your Personal Data to potential buyers, underwriters or advisors. If we do this, we will take reasonable precautions to ensure that the recipients of your Personal Data are obliged to keep it secure and confidential, in compliance with relevant legal requirements.

We may also, from time to time, expand, reduce or sell our business, and this may involve the transfer of certain divisions or the whole business to other parties. Your Personal Data will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use your Personal Data for the purposes for which it was supplied by you.

Under no circumstances will we sell or rent your personal information to anyone, for any reason, at any time. Shuru-Up has taken best and reasonable steps to ensure prevention of any unauthorised disclosure of your sensitive personal information.

 

  • Cookies and E-mail notifications

Users of the Website can manage the kinds of emails received from us by visiting the "Notifications"[A1]  tab in your Shuru-Up account. To unsubscribe from emails you can also use the 'unsubscribe' link on the emails we send you. For non-users of the Website, please notify us using the contact details below if you no longer wish to receive our updates. If you have enabled push notifications about businesses fundraising on the Website, you may disable these in your browser settings.

Shuru-Up may from time to time use cookies. Cookies are small data files that a website stores on Your computer. Shuru-Up may use persistent cookies which are permanently placed on your computer to store non-personal (Browser, ISP, OS, Clickstream information etc) and profiling information (age, gender, income etc). While cookies have unique identification numbers, personal information (name, a/c no., contact numbers etc) shall not be stored on the cookies. We will use the information stored in the cookies to improve Your browsing experience on our website, by throwing up relevant content where possible. We will also use the cookies to store visitor preferences to ease visitor navigation on the site.

You may, through the Website, alter your cookie preferences and your preferences for other monitoring, analysis or tracking activity we conduct, based on industry-standard classifications. This can be accessed by visiting the "Cookies & Marketing Preferences"[A2]  tab in your Shuru-Up account. The categories are: 'strictly necessary', 'performance', 'functionality and profile', and 'targeting' cookies. Making alterations to these preferences will determine which category of cookies we may place and access on your computer and the other monitoring, analysis or tracking activity we conduct. It is important to note that disabling or making changes to these preferences may prevent you from using the full range of services available on the Website.

You may also refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

 

  • Accuracy and Retention of Personal Data

If you see that any of your Personal Data that is included in the "Profile" section of your Shuru-Up account is inaccurate, please revise or update it using the Website. Alternatively, if you believe that any of the Personal Data we hold about you is inaccurate, you may notify us using the contact details below in order to correct it.

It is your responsibility to ensure that any Personal Data you have provided to us remains accurate and to notify us (either through the Website or using the contact details below) if there are any changes in your Personal Data.

We will retain your Personal Data to fulfill the purposes outlined in this Privacy Policy as long as you use the Shuru-Up platform, and for at least six years after that to comply with the legal and regulatory record keeping obligations we have.

 

  • Your Rights

You may have the right to request the following actions regarding your Personal Data, which will be fulfilled in accordance with applicable data protection law:

• If you wish to raise an objection to the processing of your Personal Data or wish it to be deleted you may do so by notifying us using the contact details below. It may be possible for us to restrict processing of your Personal Data, or to delete it so long as we can still comply with our legal, regulatory and contractual obligations.
• If you wish to object to direct marketing please notify us using the contact details below or, in the case of emails, if you are a user of the Website you can go to the "Profile" section as set out above and you may also use the 'unsubscribe' feature which you can find on our emails. To ensure that we respect your request we may retain your contact details on a suppression list.
• Where we have processed information with your consent then you may notify us using the contact details below to withdraw that consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
• If you would like to receive a portable copy of the Personal Data you have provided to us, please notify us using the contact details below.
• If you have created a Shuru-Up account, you can see some of the Personal Data we hold about you in the "Profile" section of your account. If you wish to see a copy of all of your Personal Data that we hold, please notify us using the contact details below. A request for a copy of your Personal Data will generally be fulfilled free of charge, but we may charge a reasonable fee if the request is manifestly unfounded, excessive, or repetitive, or if you request multiple copies of the same information.

 

  • Security

Our hosting services and servers maintain its systems in accordance with industry standards and best practices to reasonably secure the information of its customers, such as using SSL encryption in certain places to prevent eavesdropping, and employing up-to-date software on the server.  You can read more about here[A3] . However, no data transmission over the Internet can be guaranteed to be 100% secure. “Perfect security” does not exist on the Internet, and therefore You use the website and mobile application at your own risk.

Your data is transmitted between your device and our servers using HTTPS protocol for encryption. HTTPS is the technology used to create secure connections for your web browser, and is indicated by a padlock icon in your browser.

Shuru-Up follows industry best practices, using open and known principles when transferring and storing your data. We believe the biggest threat to the security and privacy of your data is if someone gains access to any of your devices. Remember to keep your password safe and secret to prevent unauthorised access to your Shuru-Up account. If you think that the security of your Shuru-Up account has been compromised, change your password and contact us immediately for further assistance.

  • Contact Details

If you wish to make a notification to us, or have any questions about this Privacy Policy, you can send a letter or email, in readable format, to our Grievance Officer Mr. _________ at:

1) “_________[@]Shuruup[.]com”; or

2) Shuru Ventures LLP, ________________________________________[Address].

 

  • Revisions

This Privacy Policy is subject to change and may be updated or revised from time to time, without any prior notification to the User, at the sole discretion of Shuru-Up. It is the responsibility of the User to periodically review the Privacy Policy to determine whether there have been any revisions or updates. The last updated date of the Policy has been mentioned above for the reference of the User.

If you do not agree with the terms of this Privacy Policy or any changes made to this Policy, please stop using all products and services provided by Shuru-Up immediately and write to us at email ID stated above.

 

  • Cookie Preferences

Cookies are text files containing small amounts of information, which your computer or mobile device downloads when you visit a website. When you return to websites - or visit websites that use the same cookies - they recognise these cookies and therefore your browsing device.

The type of cookies used on Shuru-Up can be put into 1 of 4 categories, based on the International Chamber of Commerce guide to cookie categories: Strictly Necessary, Performance, Functionality & Profile and Targeting.

Performace

These cookies are not used to target you with online advertising. Without these cookies we can't learn how our website is performing and make relevant improvements that could better your browsing experience.

Functionality

These cookies may be used to ensure that all our services and communications are relevant to you. The information these cookies collect cannot track your browsing activity on other websites. Without these cookies, a website cannot remember choices you've previously made or personalise your browsing experience.

Profile and Targeting

Without these cookies, online advertisements you encounter will be less relevant to you and your interests.

Strictly Necessary

These cookies are essential, as they ensure your security and privacy when you use our secure sites, as well as enabling you to move around a website and use its features. This category cannot be disabled.

 

  • Marketing Analytics Preferences

Occasionally your personal data may be used to allow Shuru-Up to better understand our audience and deliver more relevant advertising to you or people like you.

This may mean securely sharing some of your data with other advertisers or platforms. Your information will be fully encrypted and used strictly in line with our Privacy Policy.    

Marketing analytics permission

 

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