Privacy Policy

Last updated: May 2026

1. Introduction

BigK Capital VCC (“BigK Capital,” “we,” “us”) is committed to protecting your personal data. This Privacy Policy describes how we collect, use, share, and protect personal data in connection with your use of www.bigkcapital.com (the “Website”) and any communication you have with us. We process personal data in accordance with the Mauritius Data Protection Act 2017 (“DPA”) and other applicable data-protection laws. For the purposes of the DPA, BigK Capital VCC is the controller of your personal data.

2. Personal data we collect

We collect personal data that you provide to us voluntarily. This includes information you submit through forms on the Website (such as your full name, email address, country of residence, investor type, telephone number, and the contents of any message), information you provide in correspondence with us, and information collected automatically when you visit the Website (such as IP address, browser type, device identifiers, and pages viewed).

If you proceed beyond an initial enquiry to subscribe to a sub-fund of BigK Capital VCC, we will collect additional personal data as required by the Financial Intelligence and Anti-Money Laundering Act 2002 (“FIAML”) and applicable know-your-customer (“KYC”) regulations — including, where relevant, source-of-wealth information, beneficial ownership information, tax residency information, and politically exposed person declarations. The full scope of such data is described in the Subscription Agreement and related documents.

3. Lawful basis for processing

We process your personal data on one or more of the following lawful bases under the DPA: your consent; the performance of a contract to which you are a party, or steps taken at your request prior to entering into a contract; compliance with a legal obligation to which we are subject (including under FIAML, FATCA, and the Common Reporting Standard); and the legitimate interests pursued by us or by a third party, where those interests are not overridden by your rights and interests.

4. How we use personal data

We use personal data to: (i) respond to your enquiries and provide you with the information you request; (ii) administer and improve the Website; (iii) assess your suitability as an investor and discharge our KYC, AML, and counter-terrorism-financing obligations; (iv) send you fund-related communications, including reports, notices, and updates, where lawful; (v) comply with legal, regulatory, and reporting obligations; and (vi) protect our legitimate business interests, including the prevention of fraud and the enforcement of our legal rights.

5. Sharing of personal data

We may share your personal data with: (i) our service providers and professional advisors, including the Fund’s administrator (KFS (Mauritius) Ltd), custodian (Kotak Mahindra Bank Limited), auditor, legal counsel, and compliance advisors; (ii) regulatory authorities, including the FSC, where required by law; (iii) tax authorities under exchange-of-information regimes including FATCA and the Common Reporting Standard; and (iv) other third parties where you have given consent.

We do not sell your personal data, and we do not share it with third parties for their direct-marketing purposes.

6. International transfers

Some recipients of your personal data may be located outside Mauritius, including in jurisdictions whose data-protection laws may differ from those of Mauritius. Where we transfer personal data outside Mauritius, we comply with the cross-border-transfer requirements of the DPA, which require that the recipient jurisdiction provide an adequate level of data protection or that appropriate safeguards (such as binding contractual undertakings) be in place.

7. Data retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, and to satisfy any legal, regulatory, accounting, or reporting requirements. Investor records collected under FIAML are retained for a minimum of seven years following the termination of the relationship.

8. Security

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. No internet-based service can guarantee absolute security; we therefore cannot warrant that personal data will always be secure against every conceivable risk.

9. Your rights as a data subject

Subject to the DPA, you have the right to: access the personal data we hold about you; request correction of inaccurate personal data; request erasure of personal data, in certain circumstances; restrict or object to certain types of processing; receive a copy of your personal data in a structured, commonly-used, machine-readable format (data portability); and withdraw consent at any time, where processing is based on consent.

To exercise any of these rights, please contact us using the details below. You also have the right to lodge a complaint with the Data Protection Office of Mauritius (https://dataprotection.govmu.org).

10. Cookies

The Website uses cookies and similar technologies to operate the site, remember your preferences, and gather anonymous statistical information. You may set your browser to refuse cookies; doing so may limit functionality. Where required, you will be given the option to accept or decline non-essential cookies through a consent banner.

11. Children

The Website is not directed at children under the age of 18, and we do not knowingly collect personal data from children.

12. Updates to this policy

We may update this Privacy Policy from time to time. The most current version will always be posted on the Website with the “Last updated” date noted above.

13. Contact

Questions regarding this Privacy Policy, or requests to exercise your rights as a data subject, should be directed to: fund@bigkcapital.com.

Postal address: BigK Capital VCC, Block 8, 1827 Building, Vivea Business Park, Moka, Mauritius.