Privacy Policy
Effective Date: June 2026
Introduction:
Welcome to Cognate Capital ("we," "our," or "us"). Cognate Capital is a proposed SEBI Category-1 Alternative Investment Fund, managed by Xspark Sherpas LLP. We are committed to protecting the privacy and security of the personal and proprietary information of our website visitors, prospective founders, and Limited Partners (LPs).
This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you visit our website or interact with our firm.
Information We Collect:
We may collect the following categories of information depending on your interaction with us:
Personal Identification Information: Name, email address, phone number, and professional titles submitted via contact forms or direct email.
Proprietary Business Information (Founders): Pitch decks, business plans, financial projections, cap tables, and intellectual property details submitted for investment consideration.
Financial & Compliance Information (LPs): Information required for Know Your Customer (KYC), Anti-Money Laundering (AML) compliance, and Expression of Interest (EOI) forms, which may include tax identification numbers, net worth declarations, and banking details.
Technical & Usage Data: IP addresses, browser types, operating systems, and website interaction metrics collected automatically via cookies to optimize website performance.
How We Use Your Information:
We do not sell, rent, or monetize your personal or business data. We use the information solely for the following institutional purposes:
Investment Evaluation: To review pitch decks, conduct commercial and technical due diligence, and evaluate potential investments.
Fund Operations: To process Expressions of Interest (EOIs), onboard Limited Partners, and manage capital call distributions.
Communication: To respond to inquiries, send updates regarding our SEBI registration status, and share relevant portfolio announcements.
Regulatory Compliance: To comply with the Securities and Exchange Board of India (SEBI) guidelines, legal obligations, and mandatory audits.
Information Sharing & Disclosure:
To execute our mandate, we may share your information under strict confidentiality with:
The Cognate Capital Network: Our internal team, General Partner, Advisory Board, and designated Venture Partners strictly for the purpose of technical and commercial diligence.
Service Providers: Trusted third-party legal counsel, fund administrators, and trustees (e.g., Axis or Vistra) required to operate the AIF.
Regulatory Authorities: SEBI, the Reserve Bank of India (RBI), or other statutory bodies if legally compelled or required for fund compliance.
Data Security & Retention:
We deploy industry-standard administrative, technical, and physical safeguards to protect your sensitive information from unauthorized access or disclosure.
Founders: If we pass on an investment, we may retain your pitch deck in our internal database for future reference, pattern recognition, and "anti-portfolio" tracking, unless explicitly requested otherwise.
LPs: Financial and KYC data is retained as mandated by Indian financial and tax regulations, even post-investment.
Cookies and Tracking Technologies:
Our website may use cookies and similar tracking technologies to enhance user experience and analyze site traffic. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use certain portions of our site.
Your Rights:
Subject to applicable Indian laws, including the Digital Personal Data Protection (DPDP) Act, 2023, you have the right to:
Request access to the personal data we hold about you.
Request correction of inaccurate or incomplete data.
Request the deletion of your personal data (subject to our overriding legal or regulatory obligations to retain such data for SEBI/AIF compliance).
Third-Party Links:
Our website may contain links to external sites (such as portfolio companies or press mentions) that are not operated by us. We have no control over, and assume no responsibility for, the content or privacy practices of any third-party sites or services.
Changes to This Privacy Policy:
We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our operational practices or regulatory requirements. Any modifications will be effective immediately upon posting the updated policy on this page.
Contact Information & Grievance Officer:
If you have any questions about this Privacy Policy, our data practices, or wish to exercise your rights, please contact us at team@cognatecap.com.
Effective Date: June 2026
Introduction:
Welcome to Cognate Capital ("we," "our," or "us"). Cognate Capital is a proposed SEBI Category-1 Alternative Investment Fund, managed by Xspark Sherpas LLP. We are committed to protecting the privacy and security of the personal and proprietary information of our website visitors, prospective founders, and Limited Partners (LPs).
This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you visit our website or interact with our firm.
Information We Collect:
We may collect the following categories of information depending on your interaction with us:
Personal Identification Information: Name, email address, phone number, and professional titles submitted via contact forms or direct email.
Proprietary Business Information (Founders): Pitch decks, business plans, financial projections, cap tables, and intellectual property details submitted for investment consideration.
Financial & Compliance Information (LPs): Information required for Know Your Customer (KYC), Anti-Money Laundering (AML) compliance, and Expression of Interest (EOI) forms, which may include tax identification numbers, net worth declarations, and banking details.
Technical & Usage Data: IP addresses, browser types, operating systems, and website interaction metrics collected automatically via cookies to optimize website performance.
How We Use Your Information:
We do not sell, rent, or monetize your personal or business data. We use the information solely for the following institutional purposes:
Investment Evaluation: To review pitch decks, conduct commercial and technical due diligence, and evaluate potential investments.
Fund Operations: To process Expressions of Interest (EOIs), onboard Limited Partners, and manage capital call distributions.
Communication: To respond to inquiries, send updates regarding our SEBI registration status, and share relevant portfolio announcements.
Regulatory Compliance: To comply with the Securities and Exchange Board of India (SEBI) guidelines, legal obligations, and mandatory audits.
Information Sharing & Disclosure:
To execute our mandate, we may share your information under strict confidentiality with:
The Cognate Capital Network: Our internal team, General Partner, Advisory Board, and designated Venture Partners strictly for the purpose of technical and commercial diligence.
Service Providers: Trusted third-party legal counsel, fund administrators, and trustees (e.g., Axis or Vistra) required to operate the AIF.
Regulatory Authorities: SEBI, the Reserve Bank of India (RBI), or other statutory bodies if legally compelled or required for fund compliance.
Data Security & Retention:
We deploy industry-standard administrative, technical, and physical safeguards to protect your sensitive information from unauthorized access or disclosure.
Founders: If we pass on an investment, we may retain your pitch deck in our internal database for future reference, pattern recognition, and "anti-portfolio" tracking, unless explicitly requested otherwise.
LPs: Financial and KYC data is retained as mandated by Indian financial and tax regulations, even post-investment.
Cookies and Tracking Technologies:
Our website may use cookies and similar tracking technologies to enhance user experience and analyze site traffic. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use certain portions of our site.
Your Rights:
Subject to applicable Indian laws, including the Digital Personal Data Protection (DPDP) Act, 2023, you have the right to:
Request access to the personal data we hold about you.
Request correction of inaccurate or incomplete data.
Request the deletion of your personal data (subject to our overriding legal or regulatory obligations to retain such data for SEBI/AIF compliance).
Third-Party Links:
Our website may contain links to external sites (such as portfolio companies or press mentions) that are not operated by us. We have no control over, and assume no responsibility for, the content or privacy practices of any third-party sites or services.
Changes to This Privacy Policy:
We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our operational practices or regulatory requirements. Any modifications will be effective immediately upon posting the updated policy on this page.
Contact Information & Grievance Officer:
If you have any questions about this Privacy Policy, our data practices, or wish to exercise your rights, please contact us at team@cognatecap.com.