Privacy Policy


This Privacy Policy is incorporated by reference into the Lightrock Terms of Use (the “Terms”), accessible here. The terms “we,” and “us” include Lightrock Investment Advisors Private Limited (formerly known as LGT Impact Investment Advisors India Private Limited), Lightrock Corporate Services Private Limited, their group companies and affiliates (“Lightrock”) and Aspada Capital Advisors LLP. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information. All other terms not defined under “Definitions” below or otherwise herein will have the meanings set forth in the Terms.

 1. Scope

This Privacy Policy applies to Personal Information that is collected and Processed by Lightrock in the course of our business, including but not limited to the Site (together with any and all future online and offline services provided by Lightrock.

2. Transparency/Notice–Types of Personal Information We Collect and How We Use It

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Lightrock and the requirements of applicable law.

You may provide Personal Information directly to Lightrock through interacting with the services, requesting services, or requesting information. As you navigate the services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below. We endeavour to collect only that information which is relevant for the purposes of Processing.

2.1. Types of Personal Information We Collect

Lightrock collects Personal Information regarding its visitors, guests, subscribers, and recipients of Lightrock communications and services (collectively “Individuals”). When you use the services or engage in certain activities, such as submitting Personal Information requesting services or information, or contacting us directly, we may ask you to provide and collect Personal Information from you such as email address when you choose to engage with our services, request information about our services or otherwise interact or communicate with us.

Posting on the Site. Lightrock may offer public accessible to its Site and blogs. You should be aware that, when you disclose information about yourself in or on Lightrock’s pages or blogs (as the case may be), the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.

 Automatic Data Collection. We may collect certain information automatically through our services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID or other device identifiers that are automatically assigned to your computer or device when you access the internet, browser type and language, geo-location information, hardware type, operating system, internet service provider, pages that you visit before and after using the services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the services, and other actions taken through use of the services such as preferences.

2.2. How Lightrock Uses Your Information

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

To Provide Services or Information Requested. Lightrock may use information about you to fulfil requests for services or information, including responding to questions, comments, and other requests; or provide access to certain areas, functionalities, and features of Lightrock’s services.

Administrative Purposes. Lightrock may use Personal Information about you for its administrative purposes, including to:

- measure interest in Lightrock’s services;

- develop new services;

- ensure internal quality control;

- verify your identity;

- communicate about activities on Lightrock’s services and systems;

- send communications for informational and operational purposes; and

- enforce our Terms.

 Marketing Lightrock Services. Lightrock may use Personal Information to provide you with materials about opportunities and services that may be of interest, including new content or services. Such uses include:

- to tailor content and offerings;

- to notify you about offerings, services, and events that may be of interest to you, including those of our business partners or affiliates;

- for other purposes disclosed at the time that Individuals provide PersonalInformation.

Research and Development. Lightrock may use Personal Information to create non-identifiable information, which is used for a variety of functions, including research, internal analysis, analytics, and any other legally permissible purposes, including in order to help us to optimally deliver our existing services or develop new services. We may share anonymous Individual and aggregate data withThird Parties for research and analysis purposes.

Other Uses. Lightrock may use Personal Information for which we have a legitimate interest, such as individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

 2.3. Cookies,Pixel Tags/Web Beacons, Analytics Information

We, as well as Third Parties that provide content or other functionality on our Site, may use cookies, pixel tags, social media widgets, analytics tools, local storage, and other technologies (“Technologies”) to automatically collect information through the services. Most browsers allow you to block and delete cookies and other Technologies. However, if you do that, the Site may not work properly.

 Our usesof such Technologies fall into the following general categories:

OperationallyNecessary for the operation of and access to the Site, services, applications,and tools, or to identify irregular site behaviour, prevent fraudulent activityand improve security;


PerformanceRelated to assess the performance of our websites and understand how ourvisitors use our websites; and


FunctionalityRelated to offer enhanced functionality when accessing or using our Site.


2.4 Third-PartyWebsites, Social Media Platforms, and Software Development Kits

The Sitemay contain links to other websites and other websites may reference or link toour Site or other services. These other domains and websites are not controlledby us, and Lightrock does not endorse or make any representations aboutThird-Party websites or social media platforms. We encourage our users to readthe privacy policies of each website and/or application they interact with.Visiting these other websites or applications is at your own risk.


Lightrock’sservices may include publicly accessible blogs. The Site and our other servicesmay also contain links and interactive features with various social mediaplatforms (e.g., widgets). You should be aware that Personal Information whichyou voluntarily include and transmit online in a publicly accessible blog,social media platform or otherwise online, or that you share in an open forummay be viewed and used by others without any restrictions.


3. Onward Transfer Lightrock May Disclose YourInformation

3.1. InformationWe Share

We mayshare your information as described in this Privacy Policy with our Third-Partyservice providers for provision of services to us or our legitimate businesspurposes; to comply with legal obligations; to protect and defend our rightsand property) or with your permission.


We mayaccess, preserve, and disclose your Personal Information and content if webelieve doing so is required or appropriate to: (i) comply with law enforcementrequests and legal process, such as a court order; (ii) protect yours’, ours’or others’ rights, property, or safety; (iii) to enforce Lightrock policies or contracts;(iv) when we believe disclosure is necessary or appropriate to prevent physicalharm or financial loss or in connection with an investigation or prosecution ofsuspected or actual illegal activity; or (v) if we, in good faith, believe thatdisclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for securitypurposes, e.g., to detect unauthorized activity on the Site or in utilisationof the services.


Merger,Sale, or Other Asset Transfers. If we are involved in amerger, acquisition, financing due diligence, reorganization, bankruptcy,receivership, sale of company assets, or transition of service to anotherprovider, then your information may be transferred as part of such atransaction as permitted by law and/or contract. Lightrock will endeavour todirect the transferee to use Personal Information in a manner that isconsistent with the Privacy Policy in effect at the time such PersonalInformation was collected.


3.2. DataTransfers

All PersonalInformation collected via or by Lightrock may be stored on our servers, on theservers of our affiliates or the servers of our service providers injurisdictions that ensure the same level of data protection that is required tobe provided by Lightrock under applicable law, including but not limited toIndia, the United States, the European Union. By providing information toLightrock, you consent to the storage of your Personal Information in theselocations.


4. Opt-Out, Grievances, Unsubscribing

You have the right to opt out of certain uses and disclosures of yourPersonal Information by contacting In sucha case, you may no longer visit or access the Site. Where otherwise permittedby applicable law, you may send an e-mail to torequest erasure of Personal Information held about you by Lightrock. You mayalso raise any grievances or queries you have about our privacy practices orthis Privacy Policy by contacting Lightrock’s Compliance Officer by email at


If you receive an unwanted email from us, you can use the unsubscribelink found at the bottom of the email to opt-out of receiving future emails, orcontact Notethat you will continue to receive transaction-related emails regarding yourrelationship with us.


5. Data Retention

Lightrock retains the Personal Information we receive as described inthis Privacy Policy for as long as you use our services or as necessary tofulfil the purpose(s) for which it was collected, provide our services, resolvedisputes, establish legal defences, conduct audits, pursue legitimate businesspurposes, enforce our agreements, and comply with applicable laws.


6. Security of Your Information

We take steps to ensure thatyour information is treated securely and in accordance with this PrivacyPolicy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, andwe cannot ensure or warrant the security of any information you provide to us.We do not accept liability for unintentional disclosure. If we learn of asecurity system’s breach, we will notify you electronically by posting a noticeon the Site or sending an e-mail to you.


7. Changes and Additions

Lightrockreserves the right to make changes and additions to the information provided,including the Site Content, at any time without notice by posting modifiedterms on the Site and without liability or penalty to Lightrock. Yourcontinued use of the Site after such posting will be deemed acceptance of thechanges.

8. Definitions

The following capitalized terms shall have the meanings herein as set forth below.

Personal Information” is any information relating to an identified or identifiable natural person, and includes, names, photos, emails, device data, browsing history, etc.

Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Lightrock or Lightrock’s agents.