Privacy

Last updated: 25 August 2026

Who we are

This website, merituscapital.in, is operated by Meritus Advisors LLP (“Meritus”, “we”, “us”), the investment manager of the Meritus India Fund, a Category III Alternative Investment Fund registered with the Securities and Exchange Board of India (IN/AIF3/24-25/1654).

For the purposes of India’s Digital Personal Data Protection Act, 2023, Meritus Advisors LLP is the Data Fiduciary for the personal data described here, and you are the Data Principal.

Our registered office is at TBQ Suite 514, One World Center, Lower Parel, Mumbai 400013, India.

What this policy covers

This policy covers the personal data we collect through this website and through the email communications we send to people who have asked to receive them.

It does not cover the information collected when someone becomes an investor in the Meritus India Fund. That process runs through the Fund’s subscription documents, its administrator and its KYC and anti-money-laundering checks, and it is governed by those documents rather than by this page.

In short

We collect very little, and only what you give us. We use it to reply to you, to send you the updates you asked for, and to understand which parts of the site are read. We do not sell personal data, and we do not add anyone to a mailing list who has not asked to be on one. You can ask us at any time what we hold about you, and ask us to correct it or delete it.

What we collect

Information you give us. When you use a contact form, request a document, or sign up for our updates, we collect the details you enter. Depending on the form, that is your name, email address, telephone number, a description of the kind of reader you are, and anything you choose to write in a free-text field. We also record the fact that you gave consent, the wording you agreed to, and when you agreed to it.

Information about your visit. Like almost every website, ours records technical information automatically: pages viewed, approximate location derived from your network address, referring page, browser and device type, and the date and time. This is collected through analytics and through the ordinary server logs of our hosting provider.

Investor login. If you have an account for the investor area, we hold the credentials and account details needed to operate it.

Information from other sources. We may add publicly available business information – an employer, a professional role, a firm’s website – to a record we already hold, so that we can understand who we are speaking to. We do not build profiles from data purchased for that purpose.

We do not deliberately collect sensitive categories of data through this website, and we ask you not to send them to us through it.

Why we use it, and on what basis

• Reply to an enquiry, or arrange a conversation – because you asked us to. Our basis is the consent you gave on the form.
• Send you updates – our research, our commentary, and news of what we are doing, because you asked to receive it. Our basis is your consent, which you can withdraw at any time.
• Provide a document you requested, such as a quarterly Eye on India – to deliver the thing you came for. Our basis is your consent.
• Keep a record of your consent – so we can show what you agreed to, and when. Our basis is a legal obligation, and ordinary business record-keeping.
• Screen submissions for invalid or automated entries – to keep the site usable and our records clean. Our basis is a legitimate business interest.
• Operate the investor area – to give investors access to their own information. Our basis is the performance of our arrangements with you.
• Understand how the site is used, in aggregate – to make it better. Our basis is a legitimate business interest.
• Meet our regulatory, tax and anti-money-laundering obligations – because we are required to. Our basis is a legal obligation.

We use your details only for the purpose you gave them for. If we ever want to use them for something materially different, we will ask you first.

Consent, and how to withdraw it

Where we rely on your consent, it is given by a deliberate act – ticking a box, or submitting a form that says plainly what you are agreeing to. Nothing is pre-ticked, and consent is never bundled with something else.

You can withdraw consent at any time, and it is as easy to withdraw as it was to give. Use the unsubscribe link in any email we send, or write to us at the address at the end of this policy. Withdrawing consent stops future use; it does not undo what was lawfully done beforehand, and it does not remove the record that consent was once given, which we keep precisely so that the position is auditable.

Who we share it with

We share personal data only where there is a reason to, and only with:

• Service providers who run parts of this site and our communications on our behalf – website hosting and content delivery, document hosting, email delivery and list management, customer relationship management, form and traffic analytics, spam and abuse prevention, and membership or login services. They act on our instructions and are not permitted to use your data for their own purposes.
• Professional advisers – auditors, lawyers, compliance and tax advisers, where they need it to advise us.
• Regulators, courts and authorities, where we are required or permitted by law to provide it. This includes SEBI and authorities acting under India’s anti-money-laundering framework.
• A successor, if our business or a part of it is ever reorganised or transferred, on terms that preserve the protections in this policy.

We do not sell personal data, we do not rent it, and we do not share it with third parties for their own marketing.

Where your data is processed

We are based in India, but several of the services above are operated by providers outside India, principally in the United States and the European Union, and their infrastructure may be distributed across more than one country. Your personal data may therefore be stored or processed outside India.

Where we use such a provider, we satisfy ourselves that appropriate contractual protections are in place, and we transfer data only to countries not restricted for that purpose under applicable Indian law.

How long we keep it

We keep personal data only as long as it serves the purpose it was collected for, and then delete it, unless we are required to retain it for longer.

In practice:

• Enquiries and update subscriptions – for as long as the relationship is live, and for a reasonable period afterwards. We review these records periodically and remove contacts we no longer have a reason to hold.
• Consent records – for as long as we hold the underlying data, and for a period afterwards, so that we can evidence what was agreed.
• Investor and prospective-investor records subject to anti-money-laundering rules – for the period required under the Prevention of Money Laundering Act and SEBI’s regulations, which is at least five years after the end of the relationship or the transaction.
• Technical logs and analytics – for a short period, in line with the retention settings of the services we use.

If you ask us to delete your data, we will do so unless we are legally required to keep it, in which case we will tell you.

Cookies and similar technologies

This site uses cookies and comparable technologies to make the site work, to keep you signed in to the investor area, and to measure how the site is used. Some are set by us; others are set by the providers described above, including our analytics and abuse-prevention tools.

You can control cookies through your browser settings, including blocking or deleting them. Some parts of the site, particularly the investor login, will not work properly without them.

The site uses Google reCAPTCHA to distinguish people from automated submissions. Google receives information about your interaction with the site for that purpose, and its use is subject to Google’s own privacy terms.

Your rights

Under the Digital Personal Data Protection Act, 2023, you have the right to:

• Ask what we hold – a summary of your personal data and how it is being processed, and the identities of others we have shared it with
• Correct or complete it, and update it where it is inaccurate or out of date
• Have it erased, where it is no longer needed for the purpose it was collected for and we are not required to keep it
• Withdraw consent, as described above
• Nominate another person to exercise these rights on your behalf if you die or become unable to exercise them yourself
• Raise a grievance with us, and have it addressed

To exercise any of these, write to us using the contact details below. We will respond promptly and within the time limits set by applicable law. We may need to confirm your identity before acting, which protects you as much as us.

If you are not satisfied with how we have handled a grievance, you may complain to the Data Protection Board of India.

A word on obligations. The Act also places duties on you: give us accurate details, do not impersonate someone else, and do not raise frivolous complaints. We mention this because the Act requires that we do.

If you are in the EEA or the UK

Where the EU or UK General Data Protection Regulation applies to our processing, you additionally have the right to object to processing carried out on the basis of our legitimate interests, to request restriction of processing, to receive a copy of data you provided in a portable form, and to complain to your local supervisory authority. Requests should be made to the same address below.

Children

This website and the material on it are intended for adults, and in most cases for professional and institutional investors. It is not directed at children, and we do not knowingly collect personal data from anyone under 18. Please do not use the forms on this site if you are under 18. If you believe a child has given us personal data, tell us and we will delete it.

Security

We take reasonable technical and organisational measures to protect personal data, including encrypted connections to this site, access controls on the systems that hold contact records, and selecting service providers who maintain recognised security practices. No system is perfectly secure, and we do not claim otherwise. If a breach occurs that affects your data, we will notify you and the Data Protection Board of India as the law requires.

Changes to this policy

We will update this page when our practices change. The date at the top shows when it was last revised. Where a change materially affects how we use data you have already given us, we will tell you directly rather than rely on you noticing.

Contact us

Questions, requests and grievances relating to personal data should go to our Investor Grievance Officer, Jayesh Tandel:

Meritus Advisors LLP
TBQ Suite 514, One World Center
Lower Parel
Mumbai 400013, India

Email: compliance@merituscapital.in
Telephone: +91 22 6982 6926

This policy is available in English. If you would like it in another language listed in the Eighth Schedule to the Constitution of India, write to us and we will arrange it.