(Registered with the Securities and Exchange Board of India)
Effective Date:10-03-2026
Last Updated:10-03-2026
1. INTRODUCTION
Fractoprop Fund Managers LLP, a limited liability partnership, incorporated under Limited Liability Partnership Act, 2008, having its registered office at RD House, Plot No. T1, Cama Industrial Estate, Walbhat Road, Goregaon (East), Mumbai – 400063 acts as the fund manager for Ridhama Real Estate Trust registered with the Securities and Exchange Board of India (“SEBI”) as a [Category II AIF], bearing Registration No. IN/AIF2/25-26/1989 , having its registered office at Plot No. T1, Cama Industrial Estate, Walbhat Road, Goregaon (East), Mumbai – 400063 (hereinafter referred to as the “LLP”, “we”, “us”, or “our”), is committed to protecting the privacy and personal data of its investors, clients, directors, employees, counterparties, and website users.
This Privacy Policy sets out the manner in which we collect, process, store, use, disclose, and protect personal data in compliance with applicable Indian laws and SEBI regulatory requirements.
2. APPLICABILITY
This Policy applies to:
- Investors / Contributors
- Limited Partners / Unit Holders
- Clients under Portfolio Management Services
- Investment Advisory Clients
- Directors / Designated Partners
- Key Managerial Personnel
- Authorized Signatories
- Ultimate Beneficial Owners (UBOs)
- Website visitors
3. CATEGORIES OF PERSONAL DATA COLLECTED
We may collect and process the following categories of information:
A. Identity & KYC Information
- Name
- PAN
- Aadhaar (where permissible)
- Passport
- Corporate Identification Number (for corporates)
- FATCA / CRS declarations
- UBO declarations
B. Contact Details
- Address
- Phone number
C. Financial Information
- Bank account details
- Income and net-worth details
- Source of funds
- Demat account details
- Investment allocation details
- Transaction records
D. Regulatory & Compliance Information
- AML documentation
- PEP declarations
- Sanctions screening results
- Risk profiling information
E. Technical Information (Website Use)
- IP address
- Browser type
- Cookies
- Device identifiers
4. PURPOSE OF PROCESSING
We process personal data for:
- Client onboarding and KYC compliance
- Compliance with SEBI regulations
- Anti-Money Laundering (AML) compliance
- FATCA / CRS reporting
- Risk profiling and suitability assessment
- Portfolio management and advisory services
- Fund administration
- Regulatory reporting to SEBI and other authorities
- Investor communications
- Audit and compliance reviews
- Fraud prevention and investigation
5. LEGAL BASIS FOR PROCESSING
Personal data is processed based on:
- Consent of the Data Principal
- Performance of contractual obligations
- Compliance with SEBI regulations and applicable law
- Legitimate regulatory and business interests
6. DISCLOSURE OF PERSONAL DATA
Personal data may be disclosed, where necessary, to the following entities:
- SEBI and other regulatory authorities
- Stock exchanges
- Depositories and clearing corporations
- Custodians and fund administrators
- Banks and payment gateways
- Auditors and legal advisors
- KYC Registration Agencies (KRAs)
- Credit rating agencies (where applicable)
- Government authorities
Such disclosures are made strictly on a need-to-know basis and in accordance with regulatory requirements.
7. DATA RETENTION
We retain personal data:
- For the duration of the client relationship
- As required under SEBI regulations
- As required under anti-money laundering laws
- For audit, legal, and regulatory purposes
Records are maintained for minimum statutory periods prescribed under SEBI regulations and other applicable laws.
8. DATA SECURITY MEASURES
We implement appropriate technical and organizational safeguards including:
- Encryption of sensitive data
- Secure servers
- Role-based access control
- Multi-factor authentication
- Data access logging
- Periodic IT and cyber security audits
- Confidentiality undertakings from employees
9. DATA PRINCIPAL RIGHTS
Subject to applicable law, individuals have the right to:
- Access their personal data
- Seek correction of inaccurate data
- Withdraw consent (subject to regulatory constraints)
- Request erasure (where legally permissible)
- Nominate another individual to exercise rights
- Lodge grievance with the Grievance Officer
Requests may be made at:
Email: contact@fractoprop.com
10. COOKIES POLICY
Our website may use cookies and tracking technologies to enhance user experience and monitor usage analytics. Users may disable cookies through browser settings.
11. GRIEVANCE REDRESSAL
In compliance with applicable law, the Company has appointed:
Grievance Officer: Mr. Dhaval Thakkar
Designation: Designated Partner
Email: contact@fractoprop.com
Address: RD House, Plot No. T1, Cama Industrial Estate, Walbhat Road, Goregaon (East), Mumbai – 400063.
Grievances shall be addressed within the timelines prescribed under applicable law and SEBI regulations.
12. AMENDMENTS
The Company reserves the right to amend this Privacy Policy. Updated versions shall be published on our website.
13. DISCLAIMER
This Privacy Policy shall be read in conjunction with SEBI regulations applicable to the Company, including:
- SEBI (Alternative Investment Funds) Regulations, 2012 (if AIF)
- SEBI (Portfolio Managers) Regulations, 2020 (if PMS)
- SEBI (Investment Advisers) Regulations, 2013 (if IA)