OBJECTIVE AND APPLICABILITY OF THE POLICY
The purpose of this privacy policy is to describe how Northpoint (“Firm”, “Fund”, “us”, “we”, “our”), acting as a Data Fiduciary (as defined under the Digital Personal Data Protection Act, 2023 ("DPDPA")), collects, uses, processes, stores, discloses, and maintains Information (as defined hereinafter) about the users of the Website. In accordance with industry practice, this website occasionally uses terminology that may be interpreted to suggest that our Firm is a single entity. However, there is no such single entity and all of the entities that comprise our Firm have their own separate legal existence. Capitalized terms not defined herein shall have the same meaning as ascribed to them in the Terms of Use available at https://www.northpointcapm.com/.
The terms “you” or “your” or “user” or “Data Principal”, shall include any individual or legal entity (represented by such individual) who accesses or uses the Website.
This Privacy Policy describes the types of information that the Firm may collect from you or that you may provide in relation to the use or access of the Website and the manner in which such information is collected, used, shared, processed, disclosed and maintained.
Please read and understand this Privacy Policy carefully. If you do not agree with our policies and our practices in the way we treat your information including without limitation, Information and any other information, your choice is to not use or access the Website. Your use or access of the Website, thus, shall constitute your agreement to this Privacy Policy.
Under the DPDPA, you have the right to access this Privacy Policy in English or in any other language specified in the Eighth Schedule of the Constitution of India. If you require this Policy in another language, please contact us at legal@northpointcapm.com.
The materials contained on the Website are protected by applicable copyright and trademark law.
APPLICABILITY OF THE POLICY
This Privacy Policy shall apply to all Information you provide on the Website and all Information that the Firm collects on the Website.
This Privacy Policy does not apply to, nor does the Firm take any responsibility for, any information that is collected by any third party either using the Website or through any third-party links on the Website.
TYPES OF INFORMATION COLLECTED
We collect the following information (“Information”) from you:
(i) “Personal Data” - information that could be used to identify you, such as, your name, age, gender, date of birth, telephone number, IP address, location data, email address, and/or other related information which may be used to identify you;
(ii) “Non-Personal Information” - information that cannot be used to identify you such as the webpages that you have viewed and your usage patterns; and
(iii) “Device Information”- information which is automatically collected about the device from which the Website is accessed or used.
MANNER OF COLLECTION OF THE INFORMATION
In the use of the Website, as you navigate through the Website, the Firm may collect different types of Information as detailed above.
You understand that the Information collected by the Firm may be collected directly or through tracking of your usage of the Website. The usage details may include IP addresses, details of your computer equipment, browser, location, connections, and any information that the Firm may collect through the use of Cookies (as defined below) and other tracking technologies. The collection of data may, in most cases, be automatic.
“Cookies” are files that would be placed in your system’s hard drive and are intended to improve and personalize your user experience, by enabling the Firm to track your usage and preference. These Cookies may track your usage of the Website, advertisements and links that you visit, and other user data. Most Cookies that the Firm uses are limited to a session, which means that they will be automatically deleted when your session closes. You may decline these Cookies by changing your browser settings, if permitted, however, do note that this may impact certain features of the Website or your user experience in using the Website.
USE OF YOUR INFORMATION
The information (including any Information) that we collect on the Website will be used for the purposes of operating the Website, facilitating your use of the Website, to provide you with communications, information about the services that you request to procure from us, or for other business purposes of the Firm. The information including any Information will be made available to Firm’s affiliates and/or group entities, and its and their respective directors, partners, officers, agents, employees, consultants, advisors and other third party service providers, including auditors, accountants, legal advisors and IT support service providers (each, a “Disclosee”). We may also share the Information with government agencies, regulators (including SEBI, IFSCA and RBI), adjudicatory bodies and other such entities (in order to respond to law enforcement requests or where required to be provided under applicable laws, court orders, or government regulations).
Except as otherwise provided herein, no Personal Data will be disclosed or shared with any third party without your express consent.
Please do not include any personal information or Personal Data unless specifically requested by the Firm. If the Firm determines that any information you have provided or uploaded violates the terms of this Privacy Policy, the Firm has the right, in its absolute discretion, to delete or destroy such information without incurring any liability to you.
You agree that your Personal Data may be used to contact you and deliver information, including but not limited to sending emails, SMS or any other communication through electronic medium on the various products and services offered by the Firm, administrative notices, and any other communication relevant to your use of the Website. If you do not wish to receive these communications, you can intimate the same to us via legal@northpointcapm.com.
DISCLOSURE OF YOUR INFORMATION
The Information you provide on the Website may be disclosed by the Firm to Disclosees who require the Information for the purposes of communicating with you, responding to requests made by you, or otherwise for operating and/or maintaining the Website.
The Firm will comply with requests and directions of all governmental, law enforcement or regulatory authorities, which it believes in good faith to be in accordance with any applicable law. Such compliance may include providing Information, Personal Data or any other information to such agency or authority. By providing any Information, Personal Data, or other information on the Website, you consent to the Firm providing such Information, Personal Data or other information to any governmental, law enforcement or regulatory authorities who exercise jurisdiction over the Firm and the Website.
INTERNATIONAL PRIVACY RIGHTS
The Firm’s Website is operated and managed on servers that may be located and operated in different jurisdictions. By using or accessing the Website, you consent to the transfer and processing of your Information including any Personal Data, on servers that may be located in a jurisdiction different from where you are located, and that the protection of such Information may be different than required under the laws of your residence or location.
DATA RETENTION
The Firm may retain Information, for such length of time as may be required in order for Firm to provide you the services, comply with legal obligations, resolve any disputes that may arise, enforce its rights arising out of any agreements with you, and/or for such period as may be required by legislations/orders of regulatory authorities to which the Firm is subject.
DATA SECURITY
As a user of the Website, you have the responsibility to ensure data security. You should use the Website in a responsible manner.
Given the nature of internet transactions, the Firm does not take any responsibility for the transmission of information (including any Information) to the Website. The Firm does not take any responsibility for you or any third-party circumventing the privacy settings or security measures contained on the Website.
While the Firm will use all reasonable efforts to ensure that your Information and other information submitted by you is safe and secure, it offers no representation, warranties or other assurances that the security measures are adequate, safe, foolproof or impenetrable.
UNSUBSCRIBING, UPDATING AND DELETING INFORMATION
In the event you have subscribed for newsletters, you may at your discretion, unsubscribe at any time by clicking “unsubscribe” in the e-mail received.
You may also request to change and/or delete any of the Information that you have submitted. Do note however, that the Firm, subject to applicable law, reserves the rights to save any usage information and you are not entitled to seek the deletion of the same.
The Firm at its sole discretion may permit or deny the change or deletion of any information, if it believes that the same is required for compliance with applicable laws.
AGE RESTRICTIONS
The Website is only intended for users who are of 18 years of age or older and otherwise competent to enter into binding contracts. If you are not of the requisite age or otherwise unable to enter into binding contracts, you are not to provide any Information or other information. If it comes to the Firm’s attention that any Information or information pertains to or is provided by an individual under the age of 18 years or otherwise not eligible to enter into binding contracts, such Information or information will be deleted without notice to you.
AMENDMENTS TO THE PRIVACY POLICY
This Privacy Policy is subject to change from time to time, at the Firm’s sole discretion. Such changes will be posted on this page. You are requested to review this page frequently.
NOTICE FOR COLLECTION OF PERSONAL DATA AND CONSENT
You hereby acknowledge that:
(i) this Privacy Policy acts as a notice for collection of Personal Data in accordance with the DPDPA, setting out: (i) the Personal Data sought to be collected; (ii) the purpose for which such Personal Data is sought; and (iii) the manner in which you may exercise your rights as a Data Principal; and
(ii) you are voluntarily providing your free and informed consent for processing your Personal Data in the manner set out under this Policy. You have the right to withdraw your consent at any time by writing to the Grievance Redressal Officer.
TERMS OF USE
This Privacy Policy shall form a part of the Terms of Use.
COMPLAINTS
If you have any questions, comments, complaints or suggestions in relation to this Privacy Policy, or any other concerns about the way in which we use, disclose or process information about you, please contact our Grievance Redressal Officer, at legal@northpointcapm.com.We shall endeavor to address all requests/complaints within 90 (ninety) days from the date of such a request/complaint being made.
This Privacy Policy has been last updated on 9 April 2026.