PRIVACY POLICY
Disclaimer: In case of any discrepancy or
difference, the English version will take precedence over the translation
We value the trust you place in us and recognize the
importance of secure transactions and information privacy. This Privacy Policy
describes how SPASHAL TECHNOLOGY PRIVATE LIMITED and its affiliates
(collectively “Spashal, we, our, us”) collect, use, share or otherwise process
your personal data through Spashal website www.Spashal.in, its mobile application, and
m-site (hereinafter referred to as the “Platform”).
While you can browse sections of the Platform without the
need of sharing any information with us, however, please note we do not offer
any product or service under this Platform outside India and your personal data
will primarily be stored and processed in India. By visiting this Platform,
providing your information or availing out product/service, you expressly agree
to be bound by the terms and conditions of this Privacy Policy, the Terms of Use and the
applicable service/product terms and conditions, and agree to be governed by
the laws of India including but not limited to the laws applicable to data
protection and privacy. If you do not agree please do not use or access our
Platform.
Collection of Your Information
When you use our Platform, we collect and store your
information which is provided by you from time to time. Once you give us your
personal data, you are not anonymous to us. Where possible, we indicate which
fields are required and which fields are optional. You always have the option
to not provide data by choosing not to use a particular service, product or
feature on the Platform.
We may track your buying behavior, preferences, and other
information that you choose to provide on our Platform. We use this information
to do internal research on our users' demographics, interests, and behavior to
better understand, protect and serve our users. This information is compiled
and analyzed on an aggregated basis. This information may include the URL that
you just came from (whether this URL is on our Platform or not), which URL you
next go to (whether this URL is on our Platform or not), your computer browser
information, and your IP address.
We may collect personal data (such as email address,
delivery address, name, phone number, credit card/debit card and other payment
instrument details or medical or health related information) from you when you
set up an account or transact with us or participate in any event or contest.
While you can browse some sections of our Platform without being a registered
member, certain activities (such as placing an order or consuming our online
content or services) do require registration. We use your contact information
to send you offers based on your previous orders and your interests.
If you choose to post messages on our message boards, chat
rooms or other message areas or leave feedback on the Platform or the social
media handles maintained by us or if you use voice commands or virtual try and
buy or similar features to shop on the Platform, we will collect that
information you provide to us. We retain this information as necessary to
resolve disputes, provide customer support, troubleshoot problems or for
internal research and analysis as permitted by law.
If you send us personal correspondence, such as emails or
letters, or if other users or third parties send us correspondence about your
activities or postings on the Platform, we may collect such information into a
file specific to you.
If you enroll into our loyalty and membership program, such
SuperCoin, VIP or similar programs offered by Spashal, we will collect and
store your personal data such as name, contact number, email address,
communication address, date of birth, gender, zip code, lifestyle information,
demographic and work details which is provided by you to Spashal or a
third-party business partner that operates online/offline establishments or
platforms where you can earn loyalty points for purchase of goods and services,
and redeem loyalty points. We will also collect your information related to
your transactions on Spashal platform and such third-party business partner
platforms. When such a third-party business partner collects your personal data
directly from you, you will be governed by their privacy policies.
Additionally, we collect your UPI ID if you choose to pay via our Spashal UPI
platform. Spashal shall not be responsible for the third-party business
partner’s privacy practices or the content of their privacy policies, and we
request you to read their privacy policies prior to disclosing any information.
Spashal has onboarded certain third-party business partners
on the Platform who specialize in the categories like travel ticket
reservations, booking online movie tickets, paying online bills and more
(Ultra-Partners). If you use the services of Ultra-Partners, you will be
redirected to Ultra-Partners websites/applications and your entry to
Ultra-Partners websites/applications will be based on your Spashal login
credentials after seeking your permissions to share the data further. Spashal
shall not be responsible for the Ultra-Partner’s privacy practices or the
content of their privacy policies, and we request you to read their privacy
policies prior to disclosing any information.
Use of Demographic / Profile Data / Your Information
We use your personal data to take and fulfill orders,
deliver products and services, process payments, and communicate with you about
orders, products and services, and promotional offers. To the extent we use
your personal data to market to you, we will provide you the ability to opt-out
of such uses. We use your personal data to assist sellers and business partners
in handling and fulfilling orders; enhancing customer experience; resolve
disputes; troubleshoot problems; help promote a safe service; collect money;
measure consumer interest in our products and services; inform you about online
and offline offers, products, services, and updates; customize and enhance your
experience; report to regulatory authorities wherever required, detect and
protect us against error, fraud and other criminal activity; enforce our terms
and conditions; and as otherwise described to you at the time of collection of
information.
With your consent, we may have access to your SMS, instant
messages, contacts in your directory, location, camera, photo gallery and
device information. We may also request you to provide your PAN, credit
information report (from credit agencies), GST Number, Government issued ID
cards/number and Know-Your-Customer (KYC) details to: (i) check your
eligibility for certain products and services like insurance, credit and
payment products; (ii) issue GST invoice for the products and services
purchased for your business requirements; (iii) enhance your experience on the
Platform and provide you access to the products and services being offered by
us, sellers, affiliates or lending partners. You understand that your access to
these products/services may be affected in the event consent is not provided to
us.
In our efforts to continually improve our product and
service offerings, we and our affiliates collect and analyze demographic and
profile data about our users' activity on our Platform. We identify and use
your IP address to help diagnose problems with our server, and to administer
our Platform. Your IP address is also used to help identify you and to gather
broad demographic information.
We will occasionally ask you to participate in optional
surveys conducted either by us or through a third-party market research agency.
These surveys may ask you for personal data, contact information, date of
birth, demographic information (like zip code, age, or income level),
attributes such as your interests, household or lifestyle information, your
purchasing behavior or history, preferences, and other such information that
you may choose to provide. The surveys may involve collection of voice data or video
recordings, the participation of which would purely be voluntary in nature. We
use this data to tailor your experience at our Platform, providing you with
content that we think you might be interested in and to display content
according to your preferences.
Cookies
We use data collection devices such as "cookies"
on certain pages of the Platform to help analyze our web page flow, measure
promotional effectiveness, and promote trust and safety. "Cookies"
are small files placed on your hard drive that assist us in providing our
services. Cookies do not contain any of your personal data. We offer certain
features that are only available through the use of a "cookie". We
also use cookies to allow you to enter your password less frequently during a
session. Cookies can also help us provide information that is targeted to your
interests. Most cookies are "session cookies," meaning that they are
automatically deleted from your hard drive at the end of a session. You are
always free to decline/delete our cookies if your browser permits, although in
that case you may not be able to use certain features on the Platform and you
may be required to re-enter your password more frequently during a session.
Additionally, you may encounter "cookies" or other similar devices on
certain pages of the Platform that are placed by third parties. We do not
control the use of cookies by third parties. We use cookies from third-party
partners such as Google Analytics for marketing and analytical purposes. Google
Analytics helps us understand how our customers use the site. You can read more
about how Google uses your personal data here: https://www.google.com/intl/en/policies/privacy/.
You can opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
You can also control the use of cookies at the individual browser level, but if
you choose to disable cookies, it may limit your use of certain features or
functions on the services.
Sharing of personal data
We may share personal data internally within Spashal group
companies including SPASHAL TECHNOLOGY PRIVATE LIMITED, and other Spashal
affiliates, related companies and third parties, including Credit Bureaus and
business partners (such as UPI platform), for purposes of providing products
and services offered by them, such as, personal loans offered by SPASHAL
TECHNOLOGY PRIVATE LIMITED through its lending partners, insurance, the
deferred payment options, Spashal Wallet offered by SPASHAL TECHNOLOGY PRIVATE
LIMITED through its lending partners. These entities and affiliates may share
such information with their affiliates, business partners and other third
parties for the purpose of conducting the required checks, namely for the
purpose of credit underwriting, providing you their products and services and
may market to you as a result of such sharing unless you explicitly opt-out.
For products that are required to be prescribed by qualified
professionals under law, we permit processing of such orders on the Platform
only upon confirmation that a valid prescription has been uploaded by you. In
cases where the prescriptions uploaded by you are invalid, illegible, or
expired or if prescription is not uploaded by you, we may, through third-party
vendors connect You with medical practitioners, teleconsultants or third-party
professionals where required to rectify the prescription or in case of
invalid/illegible/expired prescription or issue a prescription in case
prescription is not uploaded by you, based on the information that You provide
to them. You agree and acknowledge that you will be redirected to the
teleconsultation services only in limited cases where prescription validation
or prescription issuance is required.
We may disclose your personal data to third parties, such as
sellers, business partners. This disclosure may be required for us to provide
you access to our products and services; for fulfillment of your orders; for
enhancing your experience; for providing feedback on products; to collect
payments from you; to comply with our legal obligations; to conduct market
research or surveys; to enforce our Terms of Use; to facilitate our marketing
and advertising activities; to analyze data; for customer service assistance;
to prevent, detect, mitigate, and investigate fraudulent or illegal activities
related to our product and services. We may disclose personal data if required
to do so by law or in the good faith belief that such disclosure is reasonably
necessary to respond to subpoenas, court orders, or other legal process. We may
disclose personal data to law enforcement agencies, third party rights owners,
or others in the good faith belief that such disclosure is reasonably necessary
to enforce our Terms of Use or Privacy Policy; respond to claims that an
advertisement, posting or other content violates the rights of a third party;
or protect the rights, property or personal safety of our users or the general
public.
We and our affiliates will share / sell some or all of your
personal data with another business entity should we (or our assets) plan to
merge with, or be acquired by that business entity, or reorganization,
amalgamation, restructuring of business. Should such a transaction occur that
another business entity (or the new combined entity) will be required to follow
this Privacy Policy with respect to your personal data.
Links to Other Sites
Our Platform may provide links to other websites or
applications that may collect personal data about you and you will be governed
by their privacy policies. Spashal shall not be responsible for the privacy
practices or the content of their privacy policies, and we request you to read
their privacy policies prior to disclosing any information.
Security Precautions
We maintain reasonable physical, electronic and procedural
safeguards to protect your information. Whenever you access your account
information, we offer the use of a secure server. Once your information is in
our possession, we adhere to our security guidelines to protect it against
unauthorized access. However, by using the Platform, the users accept the
inherent security implications of data transmission over the internet and the
World Wide Web which cannot always be guaranteed as completely secure, and therefore,
there would always remain certain inherent risks regarding use of the Platform.
Users are responsible for ensuring the protection of login and password records
for their account.
Choice/Opt-Out
We provide all users with the opportunity to opt-out of
receiving non-essential (promotional, marketing-related) communications after
setting up an account with us. If you do not wish to receive promotional
communications from us, then please login into the Notification Preference page
of Platform [https://www.Spashal.in/communication-preferences/email]
to unsubscribe/opt-out.
Advertisements on Platform
We use third-party advertising companies to serve ads when
you visit our Platform. These companies may use information (not including your
name, address, email address, or telephone number) about your visits to this
and other websites in order to provide personalized advertisements about goods
and services of interest to you. You have an option to opt out from tracking of
personalized advertising using the “Opt out of Ads Personalization” settings
using your device’s settings application. Spashal will have no access to your
GAID once you select this feature.
Children Information
Use of our Platform is available only to persons who can
form a legally binding contract under the Indian Contract Act, 1872. We do not
knowingly solicit or collect personal data from children under the age of 18
years. If you have shared any personal data of children under the age of 18
years, you represent that you have the authority to do so and permit us to use
the information in accordance with this Privacy Policy.
Data Retention
We retain your personal data in accordance with applicable
laws, for a period no longer than is required for the purpose for which it was
collected or as required under any applicable law. However, we may retain data
related to you if we believe it may be necessary to prevent fraud or future
abuse, to enable Spashal to exercise its legal rights and/or defend against
legal claims or if required by law or We may continue to retain your data in
anonymised form for analytical and research purposes.
Your Rights
We take every reasonable step to ensure that your personal
data that we process is accurate and, where necessary, kept up to date, and any
of your personal data that we process that you inform us is inaccurate (having
regard to the purposes for which they are processed) is erased or rectified.
You may access, correct, and update your personal data directly through the
functionalities provided on the Platform. You may delete certain non-mandatory
information by logging into our website and visiting Profile and Settings
sections. You can also write to us at the contact information provided below to
assist you with these requests.
You have an option to withdraw your consent that you have
already provided by writing to us at the contact information provided below.
Please mention “for withdrawal of consent” in the subject line of your
communication. We will verify such requests before acting upon your request.
Please note, however, that withdrawal of consent will not be retroactive and
will be in accordance with the terms of this Privacy Policy, related Terms of
Use and applicable laws. In the event you withdraw consent given to us under
this Privacy Policy, such withdrawal may hamper your access to the Platform or
restrict provision of our services to you for which we consider that
information to be necessary.
Your Consent
By visiting our Platform or by providing your personal data,
you consent to the collection, use, storage, disclosure and otherwise
processing of your personal data on the Platform in accordance with this
Privacy Policy. If you disclose to us any personal data relating to other
people, you represent that you have the authority to do so and to permit us to
use the data in accordance with this Privacy Policy.
You, while providing your personal data over the Platform or
any partner platforms or establishments, consent to us (including our other
corporate entities, affiliates, lending partners, technology partners,
marketing channels, business partners and other third parties like credit
bureaus ) to contact you through SMS, instant messaging apps, call and/or
e-mail for the purposes specified in this Privacy Policy.
Changes to this Privacy Policy
Please check our Privacy Policy periodically for changes .
We may update this Privacy Policy to reflect changes to our information
practices. We will alert you to significant changes by posting the date our
policy got last updated, placing a notice on our Platform, or by sending you an
email when we are required to do so by applicable law.
Grievance Officer
In accordance with Information Technology Act 2000 and rules
made there under, the name and contact details of the Grievance Officer are
provided below:
Mr. Abhishek
Designation: Senior Manager
SPASHAL TECHNOLOGY PRIVATE LIMITED
Unit 319 Sr No 227/A/1/17 ,
10 Biz Park , Viman nagar,
Pune, Maharashtra - 411014
Email: support@Spashal.in
Customer Support
If you have a query, concern, or complaint in relation to
collection or usage of your personal data under this Privacy Policy, please
contact us at support@Spashal.in
You can reach our customer support team to address any of
your queries or complaints related to product and services by clicking the
link, selecting your order and choosing 'Need Help' option: https://www.Spashal.in/helpcentre
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