Privacy Policy.

1. Who we are and what this covers

The website at www.lumikai.com (the "Website") is operated by LUMIKAI INTERACTIVE II LLP for itself, its affiliates and other related entities operating under the Lumikai name, including entities that sponsor, operate, manage or advise onshore and offshore investment funds and investment vehicles, as well as such funds and investment vehicles themselves ("Lumikai", "we", "us", "our"). Lumikai is a venture capital firm that sponsors, manages, advises and operates onshore and offshore investment funds and investment vehicles focused on interactive media, digital platforms, and games. 

We value your privacy and are committed to protecting the personal data we collect from you or that you share with us through the Website, in accordance with applicable data protection laws. This Privacy Policy (this “Policy”) explains how we collect, use, store, disclose and protect such personal data, and the rights available to you in relation to it. 

By using the Website, you agree to the terms of this Policy. If you do not agree, please do not use the Website. This Policy forms part of, and should be read together with, our Terms of Use.

This Policy covers personal data collected through the Website. It does not cover personal data Lumikai collects through other means, including but not limited to direct introductions, correspondence, events, relationship-building outside the Website, communications with investors or prospective investors, and other contacts maintained independently of the Website.

"Personal data" means any information or data about an individual who is identified or identifiable, directly or indirectly, by or in relation to such information or data, whether alone or in combination with other information, and includes, for example, your name, email address, phone number, IP address, location data, device or cookie identifiers and other online identifiers.

2. Information we collect, and why

You can browse most of the Website without telling us who you are. We collect personal data mainly when you choose to provide it, for example, through a form.

1. When you browse the Website. We automatically collect technical data such as your IP address, device and browser type, operating system, referring page, approximate location (from IP), and how you interact with pages. This data is collected automatically as part of the normal operation of the Website, and we do not use it to identify you individually. We use this to operate, secure, troubleshoot, and improve the Website and to understand usage on an aggregated basis.
2. When you submit a pitch or contact us about funding. We collect the details you provide, such as your name, company, contact details, and any materials or information you send, to review the opportunity, respond to you, manage our deal-flow and relationship with you, and if relevant, for our internal research, market and sector analysis, and investment evaluation, including in aggregated form. As set out in our Terms of Use, unless we have signed a non-disclosure agreement with you, any materials you submit will be treated as non-confidential. Lumikai reviews a large number of opportunities, and ideas or business models comparable to yours may already be known to us or under evaluation. Your submission does not limit our ability to consider, pursue or invest in any other business, whether or not it competes with yours, and any decision on whether to proceed with an opportunity remains entirely at our discretion.
3. When you contact us or send a media or general enquiry. We collect your name, contact details, professional affiliation, the substance of your enquiry, and our records of the correspondence, to respond and manage the relationship.
4. When you engage with us on social media. We may process information that is publicly available on those platforms, such as your username, profile details, and public comments about us.
5. When you download our research or reports. We collect your name and email address to give you access to the materials, understand who is reading our research, and manage the relationship.

Information about others. If you provide personal data about another person, such as a co-founder or colleague, you confirm that you are authorised to share it with us for the purposes described in this Policy.

Sensitive information. We do not seek to collect sensitive personal data, such as health, financial account or government identification details, through the Website, and we ask that you do not send it to us.

Accuracy of information. Please ensure that the information you share with us is accurate, complete and current. We rely on it as provided and do not independently verify it.

3. Cookies

The Website uses cookies and similar technologies to remember your preferences, keep the Website working, and help us understand usage. As is customary for websites, we use this information to measure traffic, such as the number of visitors and page views, and to identify browsing trends and patterns, generally on an aggregated basis. Some of these cookies may be set by third-party service providers, such as analytics providers, who process the information on our behalf. By continuing to use the Website, you agree to our use of cookies as described in this Policy. You can control or disable cookies through your browser settings, though some parts of the Website may not work properly if you do.

4. How we share information

We do not sell your personal data. We may share it:

1. With service providers who perform functions on our behalf (e.g. hosting, analytics, email delivery), under contractual confidentiality and data-protection obligations, and only for those functions;
2. Where required by law, court order, or a lawful request or direction from any statutory, regulatory, governmental, judicial, quasi-judicial or tax authority or any person acting on its behalf, or to establish, exercise, or defend legal claims, prevent fraud, or protect the safety of any person;
3. In connection with any actual or proposed merger, acquisition, restructuring, financing, change or transfer of management or advisory rights, or sale of all or part of our business or assets, in which case we will take reasonable steps to require the recipient to protect your data consistent with this Policy.

We may also share information that has been aggregated or anonymised so that it no longer identifies any individual, including for our research, reports and other publications.

5. Third-party websites and services

The Website may contain links to, or embedded content from, third-party websites, platforms and services, including social media platforms, video and podcast hosting services, and the websites of our portfolio companies. This Policy does not apply to those third parties. Once you leave the Website or interact with third-party content, any personal data you provide or that is collected is governed by that third party’s own privacy policy and terms. We do not control, and are not responsible for, the content, privacy practices or security of any third-party website or service, and the inclusion of a link does not imply our endorsement. We encourage you to review the privacy policy of any third-party website or service you visit.

6. Cross-border transfers

We may store or process your personal data on servers or with service providers or Lumikai entities located outside India or outside your country of residence. Where we do, we transfer it only as permitted under applicable law.

7. How long we keep it

We retain personal data for as long as we consider necessary for the purposes described in this Policy, or as required or permitted under applicable law or for our legal, regulatory, or legitimate business needs. When it is no longer required, we will take reasonable steps to delete or anonymise it.

8. Your rights

Subject to applicable law, you may:

1. Request access to a summary of the personal data we hold about you and how we process it;
2. Ask us to correct or complete inaccurate or incomplete data;
3. Request erasure of your data (we may need to retain some data for legal or regulatory reasons);
4. Withdraw consent at any time where we rely on your consent (this will not affect processing already carried out, and some services may then be unavailable to you);
5. Nominate another person to exercise your rights in the event of your death or incapacity, where the applicable laws provide for this;
6. Raise a grievance regarding our processing of your personal data.

To exercise any of these rights, contact us using the details in Section 12.

We will respond to requests and grievances within a reasonable period, not exceeding 90 days, or such other period as applicable law may require. To protect your data, we may need to verify your identity before acting on a request. We may decline or limit a request where permitted by applicable law, including where it is manifestly unfounded, excessive or repetitive, or where complying would affect the rights of others or our legal or regulatory obligations.

9. Security

‍We implement reasonable technical and organisational measures designed to protect personal data from unauthorised access, loss, misuse, or alteration. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Any transmission of personal data to us is at your own risk.

In the event of a personal data breach, we will notify affected individuals and the relevant authorities where required and within the timelines prescribed by applicable law.

10. Children

The Website is not intended for use by children, and we do not knowingly permit access by, or collect information from, individuals under 18 years of age.  

11. Changes to this Policy

We may update this Policy from time to time by posting the revised Policy on the Website, with the effective date updated accordingly. Please review this Policy periodically. Continued use of the Website after an update means you accept the revised Policy.

12. Contact us

For questions, requests, or complaints about your personal data or this Policy, contact our Grievance Officer, Tiasha Guha Neogy, Compliance Officer, Lumikai Interactive II LLP, at hello@lumikai.com. 

13. Governing law‍

This Policy shall be governed by the laws of India. Consistent with our Terms of Use, any dispute arising in connection with it shall be subject to the exclusive jurisdiction of the courts at Gurugram, Haryana.