Privacy Policy

A. Introduction

This Privacy Policy (“Policy”) outlines the practices and policies of Spice Money Limited (referred to as the “Company,” “We,” “Our,” or “Us,” which also encompasses its associate companies) concerning the collection, use, processing, storage, retrieval, disclosure, and transfer of Your (the words, “Yours/ yours”, “Him/ him”, “His/ his”, “You/ you”, “User”, and “Customer” refers to the end user of various services provided by Us) information, including personal or sensitive personal data or information ("Information"). This Information may be received through Your access and utilization of various facilities, services provided by Us (“Services”) through Your access, interaction, or use of Our portal, network, website, or mobile application (“Platform”). It is important to note that the scope of this Policy is confined to the aforementioned Information collected or received by Us through Your use of the Platform or Services.

By accessing or using the Platform or availing the Services, You hereby explicitly and specifically agree to the terms outlined in this Policy. The collection, use, processing, storage, retrieval, disclosure, or transfer of Your Information shall be conducted in accordance with this Policy and in compliance with applicable laws including but not limited to the Digital Personal Data Protection Act, 2023 (“DPDP”), Information Technology Act, 2000 (“IT”), and the rules established thereunder, as may be amended periodically. Additionally, Our practices align with the regulations, directions, circulars, guidelines, or other mandates issued by the Reserve Bank of India ("RBI"), any other regulators in India and any other relevant acts, laws, regulations enacted by the Parliament of India/Government of India (collectively referred to as "Applicable Laws"), that are applicable to the Services available on the Platform. 

All terms and conditions, as well as policies governing the use of the Platform (as outlined in the Terms and Conditions or any other policies/terms of the Company), are hereby incorporated into this Policy by reference. We urge You to carefully read this Policy to ensure a clear understanding of how any Information You provide to Us will be handled. Your use of the Platform implies that You have read and accepted this Policy. By accessing or using the Platform or the Services, You explicitly and specifically consent to Our collection, processing, storage, transfer, use, disclosure, and handling of Your Information in accordance with this Policy. If You disagree with the practices outlined in this Policy, kindly refrain from providing Us with Your Information or using, accessing, or interacting with the Platform and/ or availing the Services.

You hereby represent to Company that:

1. The Information You provide to Us 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 Us.

2. Your providing the Information as well as Our 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.

3. You must ensure that the Information You provide to Us remains accurate and up-to-date at all times. 

4. 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, require such third parties to adopt reasonable security standards to safeguard Your Information.

5. The Platform and the Services thereon are not available to persons under the age of 18 or to anyone previously suspended or removed from the Platform by Us. By using the Platform, You represent that You are at least 18 years of age and have not been previously suspended or removed by Us, or disqualified for any other reason, from availing Our Services or using Our Platform. In addition, You represent and warrant that You have the right, authority and capacity to enter into this Agreement and to abide by all the terms of this Policy as part of this Agreement. Finally, You shall not impersonate any person or entity, or falsely state or otherwise misrepresent Your identity, age or affiliation with any person or entity. 

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 Policy.

B. What we Collect?

We may collect and/or gain access to and/or record following Information, as disclosed by You to Us:

• KYC related information

  • Personal details (e.g. name, 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.

  • 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.

  • User demographic information.

• Financial Info and Transactions

  • Financial details (e.g. credit history) needed as part of request for some of Our Services.

  • 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.

  • Phone number, transactional and promotional SMS/app notifications.

• Fraud Detection & Prevention

  • Information obtained from Your mobile device by way of using Our Platform like other IDs, communication information including device location, device information (including storage, photos and videos, file and docs, IMEI, network carrier information), SIM Serial Number, SMS, model.

  • Access to WiFi details through SSID information from Your device, to notify Users about the security of WiFi network.

  • Your location, approximate/ precise based on the best available/multiple sources including but not limited to GPS/mobile network/Wifi/IP etc.

• Other Actions

  • Opinions provided by You to Us by way of feedback or responses to surveys.

  • User behaviour analysis including preferences and interests.

Note: Users can always refuse to supply Personal Information, however, it may prevent them from access to certain Services related activities.

You have the right to revoke or withdraw Your consent for the collection and use of Your Personal Information at any time as per the procedure prescribed in section J below. However, please note that we will not be able to delete your KYC related information, Financial Info and Transactions, and Fraud Detection & Prevention as per the applicable guidelines.

• Guideline applicable for KYC Related Guideline - Click Here

• Guideline applicable for Financial Info and Transactions - Click Here

• Guideline applicable for Fraud Detection & Prevention - Click Here

C. 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.

D. Collection and Use of Non-Personal Information

We may collect Your non-personal information whenever You use and interact with the Platform. 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 You to connect to our Platform, 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 You and to understand which part of the Services and/or the Platform are of Your 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.

D.1. Sharing of information with Authorities

We may disclose Your Personal Information to the courts, law enforcement agencies, or any other government/regulatory/statutory authority, as required by them in connection with any ongoing proceedings before them.

E. Security

We are committed to ensuring that Your 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 Your Personal Information, username, password, transaction information, and data stored in our Platform/ eco-system.

To secure the Personal Information, provided by You, We implement reasonable security practices and procedures as mandated under the IT Laws. We have comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the Personal Information being collected and the nature of Our business.

When You use Our Platform, the Personal Information shared by You is visible to any service provider or service facilitator involved. You are responsible for the Personal Information You choose to submit in these instances. For example, if You list Your name and email address in a blog/forum posting, that information is public. You 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. If We become aware that Your Information has been disclosed in a manner not in accordance with this Policy, We will use best 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.

F. Retention of Personal Information

We will retain Your Personal Information for as long as the purpose for its usage exists or until You withdraw Your consent, whichever occurs earlier. Subsequently, the Personal Information will be erased by Us, except for any necessary record retention mandated by Applicable Laws.

F.2 Sharing Personal Information

We may use third-party service providers to help Us operate Our business and provide Services or administer activities on Our behalf, such as sending out newsletters or surveys. We may share Your 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 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.

F.3 Disclosures

Following are the third parties to whom Your Personal Information is shared with: 

1. Payment processing partners, service providers etc.: We may share Your Information submitted by You to financial institutions and service providers such as payment processors, card issuers, lead aggregators, collection service providers, NBFC partners and banking partners to facilitate transactions.

2. 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.

3. 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.

4. Government and regulatory organisations: We may share Your Information with the Government, law enforcement agencies, authorities, and regulatory bodies to comply with the legal obligations.

5. Marketing, business development, and sales partners: We may share Your Information with marketing, business development and sales partners for the purpose of improving and for carrying out marketing or business development activities through Our Platform.

6. 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.

7. 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.

G. Third Party Websites

You may find advertising or other content on the Platform 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 platform/ services and are not responsible for the practices employed by those websites and platform/ services linked to or from our Platform. In addition, these sites and platform, including their content and links, may be constantly changing. These sites and platform may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites and platform which have a link to the Services, is subject to that website and such platform’ terms and policies.

We may collaborate with various third parties in connection with the Platform or the provision of Services. It is important to note that once You provide Information to any third party or navigate to third-party links while using the Platform, Our Policy will no longer be applicable, and We disclaim responsibility for the privacy practices of these third parties.

H. Changes to this policy

We reserve the right to change, update, modify, insert, or delete any provision of this Policy, from time to time, at Our sole discretion. 

We encourage You to regularly check this page for any changes to this Policy. You acknowledge and agree that it is Your responsibility to periodically review this Policy and stay aware of any modifications.

I. Your Acceptance of These Terms

By utilizing the Services or accessing the Platform, You hereby agree and acknowledge to be bound by this Policy. You provide Your specific and explicit consent that We will collect, use, process, and share Your Personal Information and non-personal information in a manner consistent with the terms outlined in this Privacy Policy. If You do not agree with these terms, please refrain from using the Services. Your continued use of the Platform or Our Services following any change or amendment to this Policy shall indicate Your acknowledgment of such changes and Your agreement to be bound by the terms and conditions of such changes.

You agree that Your consent is given freely, specifically, with informed understanding, unconditionally, and unambiguously. This consent signifies Your agreement to the processing of Your Personal Information by Us for the specified purpose mentioned in this Policy.

J. Your Rights

You have the right to revoke or withdraw Your consent for the collection and use of Your Personal Information at any time. If You wish to do so, You can submit a request to Us on the following link: click here. Upon receiving Your request, We will proceed to erase Your Personal Information from Our records. 

However, please note that there are certain situations where We may be legally obligated to process or retain your Personal Information, as required by the Applicable Laws. These records and data shall be made available for scrutiny to regulators or any other investigation agencies as required under Applicable Laws. Please refer to this link click here for details on the Information We can delete, and are required to retain under the Applicable Laws.

Note: Please note that such action may impact Our ability to process or facilitate the use of Your Personal Information, potentially resulting in the discontinuation of the Services for which this Personal Information was being utilized, at Our sole discretion. 

By submitting a request at customercare@spicemoney.com, You may review, correct, complete or rectify the inaccurate Personal Information that is stored with Us.

You have the right to access the following details about Your Personal Information by submitting a request to customercare@spicemoney.com:

1. a summary of Your Personal Information being processed by Us and the processing activities undertaken with respect to such Personal Information;

2. the identities of all the third parties with whom Your Personal Information has been shared by Us, along with a description of the Personal Information so shared; and

3. any other information related to Your Personal Information and its processing, as may be prescribed under the Applicable Laws.

K. Contact Us

Please contact or email Our grievance officer, at one of the addresses below. Our grievance officer will attempt to expeditiously redress your grievances: 

Name – Ruchi Girdhar

Designation– Senior Vice President- Care

Email – ruchi.girdhar@spicemoney.com and cc to legal@spicemoney.com

L. Governing Law and Dispute Resolution

Except as otherwise described, all content accessed through the use of the Platform is made available solely to facilitate You. We control and operate the Platform and Services and make no representation that the contents and Services are appropriate or available for use in other locations. If You use the Platform from a location other than where the Platform and Services are controlled and operated, You are responsible for compliance with applicable local laws.

This 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.