Welcome to the website of ElementOne Group. The content of the Website is the property of ElementOne Growth Alternatives Trust and its associates and group Companies, having its office at 601 – 6th Floor, Sun City Business Tower, Golf Course Road, Sector 54, Gurugram- 122002. ElementOne Growth Alternatives Trust’ is registered with SEBI as a Category II Alternative Investment Fund with effect from July 25, 2025.
For the purpose of this Privacy Policy, wherever the context so requires the term “You” or “User” shall mean any natural or legal person defined under various acts including Online and offline clients and the term “We”, “Us”, “Our”, ElementOne shall mean ElementOne Credit Opportunities Fund/ ElementOne Growth Alternatives Trust, its group Companies, its employees, associates and affiliates.
ElementOne is strongly committed to every individual’s right to privacy and to keeping personal and financial information secure. As part of the effort to earn your trust and confidence in our commitment, we are fully disclosing our privacy practices. We therefore encourage you to read our privacy policy to familiarize and understand the types of personally identifiable information we collect and how we use this information. We undertake not to use the information for any purpose except the stated purpose.
We acknowledge and accept that the personal details that you impart to us, is to be kept in strict confidentiality and to use the information only in the manner which would be beneficial to our clients. We consider our relationship with you as invaluable and strive to respect and safeguard your right to privacy. We shall protect the personal details received from you with the same degree of care, but no less than a reasonable degree of care, to prevent the unauthorized use, dissemination, or publication of these information as we protect our own confidential information of a like nature. We shall use the personal information to improve our service to you and to keep you updated about our new product or information that may be of interest to you. The information collected from you would be used in the right spirit and context in which it is intended to be used. Your information would be used by us to process your trading request and to carry out the settlements of your obligations.
We respect the privacy of everyone who visits this website and are committed to maintaining the privacy and security of the personal information of all visitors to this Website. We view protection of your privacy as a very important principle. We understand clearly that you and your Personal Information is one of our most important assets. We store and process Your Information including any sensitive financial information collected (as defined under the Information Technology Act, 2000), if any, on computers that may be protected by physical as well as reasonable technological security measures and procedures in accordance with Information Technology Act 2000 and Rules there under. If You object to Your Information being transferred or used in this way, please do not provide the details of your information on the Website.
We shall not sell your personal information to any third party. However under certain conditions we would share this information.We share information as part of normal business operations, such as providing you with any services to which you subscribe, and any activity related to these services such as collecting fees for those services, and informing you about these services; as part of normal legal/regulatory purposes required by the Securities and Exchange Board of India and other regulatory and government entities, and we may occasionally invite selected third parties to participate in offers we feel would be attractive to customers.
It may become necessary for us to disclose your personal information to our agents and contractors, or to their subcontractors. However, these parties would be required to use the information obtained from us for such use exclusively.
Your account information is protected by placing it in the secure portion of our Web site, which is why you need to enter your unique login username and password each time you want to access your account information.
We may disclose personally identifiable information if required to do so by law or in the good-faith belief that such action is necessary to:
- Conform to the edicts of the law or comply with legal process served on the site or its owners;
- Protect and defend the rights or property of the site-owners or the site, and
- Act under exigent circumstances to protect the personal safety of users of the site, its owners, or the public.
You should be careful in handling the ID and Password and you should ensure that you do not reveal it to anybody, nor do you keep it in writing. We and our affiliates will share/sell/transfer / license / convey some or all of your personal information with another business entity to carry out any business activity or re-organization, amalgamation, restructuring of business or for any other reason whatsoever. Once you provide your information to us, you provide such information to us and our affiliate and we and our affiliate may use such information to provide you various services with respect to your transaction conducted with us
Our policy on the collection and use of personal information and other information is outlined below.
COMMUNICATIONS
When You use the Website or send emails or other data, information or communication to us, you agree and understand that You are communicating with Us through electronic records and You consent to receive communications via electronic records from Us periodically and as and when required. We may communicate with you by email or by such other mode of communication, electronic or otherwise.
Further, some of this information is maintained in our marketing database. We may contact you either by post, or by telephone or e-mail primarily as a follow-up to your request/enquiry or to answer your questions. We may also contact you from time to time in respect of other products and services that may be of interest to you. If you do not wish to receive information about these products or services, you may simply contact us by phone, e-mail or and inform us.
HOW WE USE AND SHARE YOUR PERSONAL INFORMATION
We use Personal Information for various functions, such as:
Client Onboarding and Relationship Management: We may process your information in connection with onboarding and maintaining our relationship with you. This may include, without limitation –
- Respond to your questions about our Services.
- Send you communications related to your use of our Services.
- Offer you products or Services we believe may interest you.
- Personalise your experience on the Platform, showing you relevant content and tailoring displays to your preferences.
- Understand and use your IP address to diagnose and resolve server problems, administer the Platform, identify you, and gather broad demographic data.
PROMOTIONAL/NON-PROMOTIONAL COMMUNICATION
We may use your contact information to communicate with you by sending emails, text messages, or other notifications about our products and Services. While you can opt out of receiving promotional communications at any time, we may still send you non-promotional messages related to your account, the Services, or your use of the Platform. Additionally, we may use your device’s IP address to deliver the content and data you request directly to your device.
TO ENSURE SECURITY, COMPLIANCE AND RISK MANAGEMENT
- Verify your identity, maintain Platform security and detect errors, fraud, or other prohibited activities.
- Contact you via phone, SMS, WhatsApp, or email for technical issues, feedback, and security reasons.
- Enforce our Terms and Conditions, and protect our contractual or other legal rights or to bring or defend legal proceedings.
- To comply with applicable legal and regulatory obligations under Indian law, including SEBI regulations, know your client (KYC) norms, anti-money laundering (AML) compliances, and tax laws. This includes risk profiling, monitoring and recording transactions and communications, making necessary disclosures to tax authorities, financial regulators, judicial or government bodies, and assisting in the investigation or prevention of fraud and other unlawful activities.
- To facilitate audits conducted by our internal/external auditors or by any third party auditors appointed in accordance with regulatory requirements.
- To address complaints, requests, or reports from you or others.
We may share your Personal Information in the following circumstances:
- Within the ElementOne Group to enable internal operations and improve our Services.
- With trusted strategic partners and third-party service providers who assist in:
- Payment processing
- Marketing and Advertising
- Performance Monitoring
- Technology and Platform development
- Technology Service Provider (TSP) and Account Aggregators (AA)
These third parties are contractually obligated to follow strict confidentiality and data protection standards.
- You specifically agree and consent to ElementOne sharing your information (including Personal Information) with various third parties, including but not limited to, banks, payment gateways, SEBI-registered entities, Stock Exchanges, CERSAI, and KRAs. This is done solely for the purpose of reviewing your profile and processing your transaction requests for ElementOne’s Services or other products.
- Upon receipt of your explicit consent, ElementOne and third-party platforms where our Services are offered or marketed, may exchange your information to enable your access to and use of such Services directly through those platforms. This data sharing is governed by mutual contractual arrangements, under which the third parties are obligated to maintain the confidentiality of your Personal Information (to the extent shared) and to process it solely for the purposes for which it was disclosed.
- To protect the rights, property, or safety of ElementOne, our users, or others, this may include:
- Sharing information with external organisations for fraud detection and prevention
- Disclosures required for legal or regulatory obligations, including cooperation with law enforcements or regulatory bodies
LOG FILE INFORMATION COLLECTED AND STORED AUTOMATICALLY
If you visit/ log into our website just to browse, read pages or download information, we gather and store certain information about your visit automatically. This information cannot and does not identify you personally. When you register with or view our site, our servers automatically record certain information that your web browser sends whenever you visit our website. The kind of information that is gathered automatically include the type of browser you are using (e.g. Internet Explorer, Firefox, etc.), the type of Operating System you are using (e.g. Windows or Mac OS) and the domain name of your Internet Service Provider, the date and time of your visit and the pageson our website. We sometimes use this information to improve our website(s) design, content and primarily to give you a better browsing experience. This notice / policy is not intended to and do not create any contractual or other legal rights in favour of any user or viewer of https://elementone.fund/or on behalf of any other party. However, users and viewers are informed that by using the website https://elementone.fund/, they are deemed to have consented to the collection and use of information by ElementOne as stated above.
THIRD-PARTY WEBSITES AND THEIR DATA PRACTICES
When you access third-party websites through links provided on this Platform, those external sites may collect your personal information, such as your IP address, browser type, or operating system. ElementOne does not control and is not responsible for the privacy practices, data handling, or content of these third-party websites.
You may also encounter cookies or similar tracking technologies on these websites. Please note that ElementOne has no control over how such tools are used by third parties.
Each of these third-party services operates under its own privacy policy, which governs how your information is collected, stored, and used. This Privacy Policy does not apply to any data you share with or that is collected by such third parties. We strongly encourage you to review their privacy policies before interacting with their websites or services.
UPDATING OR REVIEWING YOUR SENSITIVE PERSONAL DATA OR INFORMATION
You may upon written request to us review the sensitive personal data or information provided. ElementOne shall ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible.
You should ensure that each time you leave your terminal you log yourself out. This prevents someone else from accessing your account if you leave your computer and your session has not “timed out”.
DISCLOSURE OF YOUR INFORMATION
We do not sell or rent your Personal Information to any third party. We are committed to exercising reasonable care to prevent any unauthorized disclosure of your Personal Information. We will, however, share your information with judicial, administrative, and regulatory bodies as necessary to comply with legal and regulatory obligations under applicable laws.
YOUR CONTROL OVER PERSONAL INFORMATION
You maintain control over your Personal Information held by us:
- Review Access: You may access and review your Personal Information at any time by logging into the Platform.
- Withdrawal of Consent: You have the right to withdraw your consent for the collection and use of your Personal Information under this Policy at any time.
- Deletion: Upon receiving your request for deletion for Personal Information, ElementOne will erase your Personal Information, unless retention is required under applicable laws and regulations. Please note that deletion of your Personal Information may impact your ability to access or use certain features of the Platform or Services.
REASONABLE SECURITY PRACTICES FOR PROTECTING INFORMATION
ElementOne uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. ElementOne cannot, however, ensure or warrant the security of any information you transmit to ElementOne and you do so at your own risk. Once we receive your transmission of information, ElementOne makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
To protect your privacy and security, ElementOne take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from ElementOne, at all times.
LINK TO OTHER WEBSITES
We are not accountable for the content of any of the linked sites. By providing access to other websites we are neither suggesting nor approving the content available in the linked websites.
DISCLAIMER ON USER INFORMATION
ElementOne shall not be held responsible for verifying the accuracy or authenticity of any information submitted by you. The responsibility for any misrepresentation, inaccuracy, fraud, negligence, or any related civil or criminal liability arising from the information you provide rests solely with you.
GOVERNING LAW AND JURISDICTION
This Policy is governed by the laws of India. Any disputes arising from it will be subject to the exclusive jurisdiction of the courts in Gurugram.
CHANGES TO OUR PRIVACY POLICY
Our policies and security practices are continuously reviewed and updated to adapt to evolving legal, technological, and business developments We reserve the right to make modifications and alterations to the details/information of the website. Users are advised to use the data for the purpose of information only and rely on their own judgement while making investment decisions. Changes to the privacy policy are effective when they are posted on page. Please visit our website to keep yourself abreast of any changes to this policy.
Do help us protect your privacy by maintaining the secrecy of the username and password you use for any of our services. Please note that this privacy policy does not create any contractual or other legal rights ion or behalf of any party, nor is it intended to do so.
Your continued engagement with the Platform subsequent to such changes signifies your acceptance of the updated Policy and your consent to the collection and use of your Personal Information as per its revised terms. All amendments become effective on the ‘Last Updated’ date specified within the Policy
