Privacy Policy
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⦁ This Privacy Policy (“Policy”) governs the manner in which Spice Money Limited (the “Company” or “Spice” or “We” or “Our” or “Us” which also includes its affiliates) collects, gains access to, uses, maintains, store, transfer/ share and discloses information including personal or sensitive personal data or information ("Information") of the users (each, a “User” or “You/ you” or “Your/ your” or “Customer”) of various services (as elaborated in the Terms and Conditions of the Company) (“Services”) provided by the Company, either through the portal/ network, website of the Company or through mobile applications (collectively referred to as “Platform”). Please note that the scope of this Policy is limited to the aforesaid Information collected or received by the Company through your use of the Services. By accessing or using the Platform or by availing Our Services, you agree to the terms of this Privacy Policy. The collection, use, processing, storage, retrieving, disclosure, or transfer of your Information will be in accordance with this Privacy Policy and as required or permitted under the applicable laws, including but not limited to the Information Technology Act, 2000 and the rules framed thereunder, as may be amended from time to time ("IT Laws") and the regulations, directions, circulars, guidelines or other mandates issued by the Reserve Bank of India ("RBI") or the National Payments Corporation of India and any other applicable acts/ laws passed by the Parliament of India/ Government of India and as applicable to the Services (collectively, "Applicable Laws").
All the terms and conditions/ policies in respect of the Services provided by the Company (as set out in the Terms and Conditions or any other policies of the Company) are incorporated in this Policy by reference. Please read this Privacy Policy carefully to make sure you understand how any Information you provide to Us will be handled. If you use any of Our Services, you will be regarded as having read and accepted this Privacy Policy. By accessing or using the Platform, you expressly consent to Our collection, processing, storage, transfer, use, disclosure and handling of your Information in accordance with this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, please do not provide Us with Your Information, or use, access or interact with the Platform and/or avail Our Services.
You hereby represent to Company that:
- The Information you provide to Company from time to time, is and shall be authentic, correct, current and updated and you have all the rights, permissions and consents as may be required to provide such Information to Company.
- Your providing the Information as well as Company's consequent storage, collection, usage, transfer, access or processing of the same (pursuant to your consent provided herein) shall not be in violation of any agreement, laws, charter documents, judgments, orders and decrees.
- If you disclose to Us any Information relating to other people, you represent that you have the full authority to do so and to permit Us to use such Information in accordance with this Privacy Policy.
- You must ensure that the Information you provide Us remains accurate and up-to-date at all times.
- Your Information will primarily be stored in electronic form however certain data can also be stored in physical form. We may enter into agreements with third parties to store or process your Information or data. These third parties may have their own security standards to safeguard your Information or data and We will, on reasonable basis, require such third parties to adopt reasonable security standards to safeguard your Information.
- Note: “Personal Information” means the 'personal data' and 'sensitive personal data or information' as defined under the Applicable Laws and as provided by you under the purview of this Privacy Policy.
- What we collect?
We may collect and/or gain access to and/or record following information, as you have disclosed to us:
- Personal details (e.g. name, sexual orientation, Email ID, contact details including, residential address, date of birth, documents such as identity card/ User IDs / passport details /Aadhaar details / PAN / Voter ID / driving license, and/or education details) provided by You to Us to avail various Services from Us.
- Your details including Purchase history/ transaction history, balances, payment details, for maintaining records (as per the Applicable Laws) of Your virtual account/ trade balance account.
- Financial details (e.g. credit history) needed as part of request for some of Our Services.
- Images/ Photos of documents/ live photo/ Video required for availing any of Our Services.
- Employment details (e.g. occupation, positions held, employment history, business details, GST details (including extracting of GST from PAN or from GST Number) salary and/or benefits) as part of Our record retention for various Services or required under Applicable Laws.
- Opinions provided by You to Us by way of feedback or responses to surveys.
- Your location, approximate/ precise based on the best available/multiple sources including but not limited to GPS/Mobile network/Wifi/IP etc
- Information obtained from Your mobile device by way of using Our Platform like device location, device information, other IDs, communication information including phone number, SIM Serial Number, SMS, device information (including storage, Photos and Videos, File and docs, model, IMEI, Network Carrier information), transactional and promotional SMS/app notifications.
- Access to WiFi details through SSID information from Your device, to notify Users about the security of WiFi network.
- User behaviour analysis, demographic information (such as preferences and interests etc).
- Note: Users can always refuse to supply Personal Information, however, it may prevent them from engaging in certain Services related activities.
- What we do with the Personal Information we gather?
We may use your Personal Information to:
- To process transactions.
- To Administer and personalize the Services.
- To undertake research and analytics for offering or improving Our Services and their security and service quality; Troubleshooting and helping Us to understand usage trends.
- To check and process Your requirements submitted to Us for Services and / or instructions or requests received from You in respect of these Services.
- To share with You, updates on changes to the Services and their terms and conditions including Platform’s terms and conditions.
- To take up or investigate any complaints / claims / disputes.
- To respond to Your queries or feedback submitted by You; Send important notices, such as communications about purchases/downloads and changes to Our Policy.
- To verify Your identity for Us to provide Services to You.
- To carry credit checks, screenings or due diligence checks as lawfully required by Us.
- To monitor and review Services from time to time.
- To undertake financial / regulatory / management reporting, and create and maintain various risk management models.
- To conduct audits and for record keeping purposes.
- To enable us to show You advertisements which are relevant to You and Your interests, selective offers and promotions, search results, location-based services.
- To comply with the requirements of Applicable Laws / regulations and / or court orders / regulatory directives received by Us.
- To Send You Our newsletter.
- Collection and use of non-personal information
- We may collect non-personal information about Users whenever they use and interact with the Services. Non-personal information may include the information other than the Personal Information (as indicated above) and may also include browser name, the type of computer, and technical information about means used by the User to connect to our Services, such as the information about the operating system and the internet service providers utilized and other similar information.
- This information is aggregated and used to help us provide more useful information to the User and to understand which part of the Services, its products, and services are of most interest.
- If we do combine non-personal information with Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
- Sharing of information with Authorities
- We may share Personal Information as well as non-personal information of the User with the courts, police authorities, or any other government/regulatory/statutory authority, in case these are required by them in relation to any proceedings pending before them.
- Security
- We are committed to ensuring that the User’s Personal Information is secure. We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of the User's Personal Information, username, password, transaction information, and data stored in our Services/ eco-system.
- When a User uses Services and products offered by us through the Services, the Personal Information shared by the User is visible to the other users and can be read, collected, or used by them. The User is responsible for the Personal Information User chooses to submit in these instances. For example, if the User lists his/her name and email address in a blog/forum posting, that information is public. Users are requested to take care when using these features.
- While We try Our best to ensure your Information is safe and secure, because of the inherent vulnerabilities of the internet, We cannot warrant complete security of all Information that you share with Us. You should understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of your Information. If we become aware that your Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted by Applicable Laws.
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Retention of Personal Information
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We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by Applicable Laws.
- Sharing Personal Information
- We may use third-party service providers to help us operate our business and Services or administer activities on our behalf, such as sending out newsletters or surveys. We may share the User’s Personal Information with these third parties for those limited purposes. We only share the Personal Information on a partial and “need-to-know” basis.
- In general, the third-party service providers used by Us will only collect, use and disclose your information to the extent necessary to allow them to perform the services or activities they provide Us. In such cases, We share the Information securely and use commercially reasonable efforts to ensure that all recipients comply with confidentiality obligations and sign covenants in this regard. However, certain third-party service providers (such as banks, financial institutions, payment aggregators or credit information companies), have their own privacy policies in respect to the information We are required to provide to them. For these third-party service providers, We recommend that you read their privacy policies to understand the manner in which your Information will be handled by them. Once you leave the Platform or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or the Platform's Terms and Conditions and in such circumstances the privacy policy of such other website will apply. We will not be liable for any acts or omissions of the third-party service provider.
- Disclosures
Where any Service requested by You involves a third party, such information as is reasonably necessary by the Company to carry out your service request may be shared with such third party.
Following are the third parties to whom Your Personal Information is shared with:
- Group companies of the Company: We may share your Information to our subsidiaries, affiliates, and group companies in order to efficiently provide certain products and/or services and/or particular features, for internal corporate/business restructuring purposes and audit related purposes etc. in compliance with Applicable Laws;
- Payment processing partners, lending partner and third-party vendors: We may share your Information submitted by You to financial institutions and service providers such as payment processors, card issuers, collection service provider, NBFC partners and banking partners to facilitate transactions;
- IT Service Providers: We may share Your Information to IT Service Providers who are engaged in the provision of information technology services for fulfilling various aspects of the Platform and for research and analytics;
- Identity and other information verification providers: We may share Your Information to identity and other Information verification to complete identification and Information verification processes in accordance with Applicable Laws;
- Government and regulatory organisations: We may share your Information with the Government, law enforcement agencies, authorities, and regulatory bodies when the Company must comply with its legal obligations.
- Marketing, business development, and sales partners: We may share Your Information with marketing, business development and sales partners for the purpose of improving and carrying out marketing or business development activities to provide better services to You through our Platform; or
- In any other circumstances where We have Your consent for any other purpose disclosed by Us to You, when You provide the Information.
We are committed to always keeping all such Information safe and provide the highest possible degree of care available under the technology presently in use.
- Third party websites
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Users may find advertising or other content on the Services that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these sites and services and are not responsible for the practices employed by those websites and services linked to or from our Services. In addition, these sites and services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites and services which have a link to the Services, is subject to that website and services’ terms and policies.
- We may work with different third parties in connection with the Platform or for providing the Services. Please be aware that any Information provided to any third-party or when you click through or are routed to third-party links while using the Platform, Our Privacy Policy no longer will apply and that We are not responsible for the privacy practices of these third parties.
- Changes to this privacy policy
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We reserve the right to change, update, modify, insert, or delete any provision of this Privacy Policy, from time to time, in Our sole discretion, without any prior notice to you.
- We encourage User to frequently check this page for any changes to stay informed about how we are helping to protect the Personal Information we collect. User acknowledges and agrees that it is his/her responsibility to review this Policy periodically and become aware of modifications.
- User acceptance of these terms
- By using the Services, you hereby agree and acknowledge to be bound by this Privacy Policy and you hereby consent that we will collect, use, process and share your Personal Information and non-personal information in the manner set out herein above. If you do not agree with these terms, please do not use the Services. Your continued use of the Services after any change/ amendment to this Privacy Policy shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
Your Rights
- You can any time revoke/ withdraw Your consent that You have given to Us for the collection and use of the Personal Information and non-personal information by submitting a request at customercare@spicemoney.com. However, this right is limited in some situations, such as where we are legally or otherwise bound to process or retain your Personal Information and non-personal information.
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Note: Please note that this may also affect our ability to process or enable your Personal Information and non-personal information and may therefore lead to the discontinuation of the Services for which this Personal Information and non-personal information was being used for, at our sole discretion. Please note that you do not have an unqualified right under applicable laws for deletion of your Personal Information and non-personal information.
- Upon Your request, You may review, correct or rectify the inaccurate Personal Information that is stored with Us.
Contact Us
- If you would like to ask about, make a request relating to, or complain about how We process your information, please contact or email Our grievance officer, at one of the addresses below. Our grievance officer will attempt to expeditiously redress your grievances.
- ⦁ For any request, complain, feedback or grievances, please contact:
Name – Amit Sharma
Designation– Executive Vice President- Operations & Care
Email – amit.sharma@spicemoney.com
- GOVERNING LAW AND DISPUTE RESOLUTION
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Except as otherwise described, all content availed by the use of the Platform are made available only to facilitate the Users. Spice controls and operates the Platform and Services and makes no representation that the contents and Services are appropriate or available for use in other locations. If you use the Services from a location other than the location where the Platform and Services are controlled and operated, you are responsible for compliance with applicable local laws.
- This Privacy Policy shall be governed by and shall be construed in accordance with the laws of India. All disputes relating to this Policy shall be subject to the exclusive jurisdiction of the courts at Delhi, India.