Privacy Policy

Effective Date: April 1st, 2026
Last Updated: March 17th, 2026

This Privacy Policy explains how Rohera Capital (“we,” “us,” or “our”) collects, uses, discloses, and protects personal information obtained through www.roheracapital.com (the “Site”), our mobile applications (if applicable), and in the course of providing our products and services. This Policy complies with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), the Privacy and Electronic Communications Regulations (PECR), the California Consumer Privacy Act (CCPA/CPRA), and the Australian Privacy Act 1988 (Cth).

1. Who We Are

• Business Name/Data Controller (UK/EU): Rohera Capital
• Business Address: 1601 N Sepulveda #352, Manhattan Beach, CA 90266
• Email: info@roheracapital.com

If you are located in the UK or EEA, we are the data controller responsible for your personal data. For U.S. residents, we act as the “Business” under applicable state privacy laws. For users in Australia, we comply with the Australian Privacy Act 1988 (Cth) and guidance from the Office of the Australian Information Commissioner (OAIC).

2. Personal Data We Collect
We may collect and process the following categories of personal data:

• Identification Data: name, title, date of birth.
• Contact Data: email address, telephone number, postal address.
• Transaction Data: payment information (note: we do not store full payment card details - these are processed securely by our payment processor), billing details, delivery details (where physical goods are provided), purchase history, and invoice information.
• Technical Data: IP address, device identifiers, browser type, operating system, and activity on our Site.
• Marketing and Communication Data: your preferences in receiving marketing communications from us and our third parties, your communication preferences, and your interests in our products and services.
• Usage Data: how you use our Site and services, including cookie data.

We do not intentionally collect or process special category data (also known as sensitive personal data, including racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sex life or sexual orientation) as defined under UK GDPR Article 9, unless we have obtained your explicit consent or another lawful basis applies under Article 9(2), or as required by law. If you voluntarily provide such information to us, we will process it only with your explicit consent and in accordance with applicable law. Under California law, we also do not intentionally collect or process "sensitive personal information" as defined by the CPRA (including precise geolocation, racial or ethnic origin, religious or philosophical beliefs, contents of mail/email/text messages, genetic data, biometric data, health data, or data concerning sex life or sexual orientation) without providing you with the right to limit its use.

3. How We Collect Personal Data
We collect personal data through:

• Direct interactions: when you fill out forms, make a purchase, contact us, or subscribe to updates.
• Automated technologies: through cookies, web beacons, pixel tags, analytics tools (such as Google Analytics), server logs, and similar tracking technologies. For more information, please see our Cookie Policy.
• Third parties: including payment processors, advertising networks, analytics providers, and social media platforms.
• We may alco collect publicly available information, such as social media profile details, online reviews, or professional contact information, where permitted by law.

4. How We Use Personal Data
We process personal data for the following purposes and lawful bases:

• To perform a contract with you (Article 6(1)(b) UK/EU GDPR) – e.g., providing goods or services you purchase.
• To comply with legal obligations (Article 6(1)(c)).
• For our legitimate interests (Article 6(1)(f)) – e.g., improving our Site, fraud prevention, and analytics.
•  Based on your consent (Article 6(1)(a)) – e.g., for marketing or placing non-essential cookies.
• For vital interests or public tasks where applicable (Articles 6(1)(d) and 6(1)(e)).

5. Sharing and Disclosure of Personal Data
We may share your information with:

• Service providers who assist with hosting, payment processing, analytics, marketing, or logistics.
• Professional advisers such as accountants, lawyers, or consultants under confidentiality obligations.
• Government, regulatory, or law enforcement agencies when required by law.
• Third-party advertising or analytics providers, with your consent where required.

All third-party service providers are bound by written confidentiality and data-processing agreements requiring them to process personal data only on our instructions and in accordance with this Policy.

We do not sell your personal information, but we may share limited data for targeted advertising, which may be considered a “sale” or “sharing” under U.S. state laws. You can opt out at any time using our “Do Not Sell or Share My Personal Information” link.

6. International Data Transfers
We operate globally and may transfer personal data outside the UK, EEA, or your home country. Where we do, we ensure adequate safeguards in accordance with Articles 44–49 of the UK/EU GDPR, including:

• Adequacy decisions under Article 45 (e.g., Data Privacy Framework for the U.S.).
• Standard Contractual Clauses (SCCs) and the UK Addendum.
• Binding Corporate Rules where applicable.

You can request details of these safeguards by contacting us at info@roheracapital.com.

7. Data Retention
We retain personal data only as long as necessary to fulfill the purposes outlined in this Policy, including to comply with legal, tax, or reporting requirements. Retention periods vary depending on the data type and purpose of processing. When no longer required, data is securely deleted or anonymized.

8. Your Rights
Depending on where you live, you may have the following rights:

• Under UK/EU GDPR:
• Right of access (Article 15)
• Right to rectification (Article 16)
• Right to erasure (Article 17)
• Right to restriction of processing (Article 18)
• Right to data portability (Article 20)
• Right to object to processing (Article 21)
• Right to withdraw consent at any time (Article 7(3))
• Right to lodge a complaint with your local supervisory authority, such as the Information Commissioner’s Office (ICO) in the UK: https://ico.org.uk or call 0303 123 1113
• Under U.S. State Laws (e.g., California, Virginia, Colorado, Connecticut):
• Right to know what personal information we collect and how it’s used.
• Right to access and delete your data.
• Right to correct inaccurate data.
• Right to opt out of the sale or sharing of personal information.
• Right to limit use of sensitive personal information.
• To exercise these rights, contact us at info@roheracapital.com. We will respond within the timeframe required by law (typically one month under GDPR or 45 days under U.S. state laws).
• Under Australian Law (Privacy Act 1988):
• Right to access your personal information.
• Right to request correction of inaccurate, incomplete, or outdated information.
• Complaints may be made to the OAIC at https://www.oaic.gov.au. 

9. Children’s Privacy
Our services are not intended for children under 16 (or under 13 in the United States). We do not knowingly collect or process personal data from minors without appropriate parental or guardian consent where required by law. If you believe we have collected data from a child without appropriate consent, contact us immediately at info@roheracapital.com and we will take steps to delete such information promptly.
10. Security of Your Personal Data

We implement technical and organizational security measures to protect your data against unauthorized access, alteration, disclosure, or destruction. These include encryption, firewalls, secure servers, and limited access protocols. However, no method of transmission over the internet is entirely secure, and we cannot guarantee absolute security.

11. Automated Decision-Making and Profiling
We do not use personal data for automated decision-making that produces legal or similarly significant effects. Where we use profiling for marketing analytics, we do so based on your consent and you can object or withdraw consent at any time.

12. Changes To This Policy
We may update this Privacy Policy from time to time to reflect legal, technical, or business changes. The “Last Updated” date at the top of this page will reflect the current version. Where legally required, we will notify you of significant changes or request renewed consent.

13. Contact Us
If you have questions or concerns about this Privacy Policy or how we handle your personal data, contact:
Rohera Capital
1601 N Sepulveda Blvd #352, Manhattan Beach, CA 90266
info@roheracapital.com