Data Policy

Last updated: July 13, 2026

1. Scope

This Data Policy supplements our Privacy Policy and provides detailed information about how A3 Capital collects, processes, and manages personal data on this website. This policy is issued in compliance with the Digital Personal Data Protection Act, 2023 (India) and the UK/EU General Data Protection Regulation (GDPR).

2. Data Controller

A3 Capital (Mitcon AI & Deeptech Fund) is the Data Controller responsible for your personal data. For data protection enquiries: sriram@a3capital.in

3. Categories of Personal Data

CategoryData ItemsSource
IdentityFull name, email, LinkedIn URLProvided by user
Investor ProfileCountry, investor type, how heard, referrerProvided by user
KYC DocumentsID proof, address proof, accreditation, source of fundsUploaded by user
Startup InformationStartup name, description, pitch deck PDFProvided by user
TechnicalIP address, browser, timestamps, access logsAutomated collection
Compliance RecordsR1–R5 register entries, NDA records, document access logsGenerated by system

4. Processing Activities

ActivityPurposeLegal Basis
Registration processingEvaluate investor eligibilityConsent
Jurisdiction routingAssign correct regulatory pathwayLegitimate interest
KYC verificationRegulatory compliance (SEBI, AML)Legal obligation
Document access loggingAudit trail for fund materialsLegal obligation
Pitch deck evaluationAssess startup for potential investmentConsent
Compliance register maintenanceSEBI AIF regulatory recordsLegal obligation

5. Consent Management

Consent is obtained at the point of data collection through explicit checkboxes. You must affirmatively check the consent box before your data is submitted. Consent can be withdrawn at any time by contacting sriram@a3capital.in. Withdrawal of consent does not affect the lawfulness of processing before withdrawal.

6. Data Protection Officer

For data protection matters, contact: sriram@a3capital.in

7. Breach Notification

In the event of a personal data breach, A3 Capital will notify the relevant data protection authority and affected individuals within 72 hours of becoming aware of the breach, in accordance with DPDP Act and GDPR requirements.

8. Automated Decision-Making

This website uses automated processing for jurisdiction routing (assigning investors to the correct regulatory pathway based on country of residence). This does not constitute automated decision-making with legal or significant effects. All investment eligibility decisions involve human review.

9. International Data Transfers

Data may be transferred to and processed in countries outside your jurisdiction of residence, including India, the United States, and EU/EEA countries. Appropriate safeguards (including Standard Contractual Clauses where required) are in place to ensure adequate protection of your data during international transfers.

10. Grievance Redressal

If you have a complaint about how we handle your personal data:

  1. Contact us at sriram@a3capital.in — we will respond within 30 days
  2. If unresolved, you may escalate to the Data Protection Board of India (DPDP Act)
  3. For UK/EU users, you may complain to the Information Commissioner's Office (ICO) / your national DPA