Privacy Policy

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 subsidiaries) concerning the collection, use, processing, storage, retrieval, disclosure, and transfer of your information, including personal or sensitive personal data or information ("Information"). The words, “Your, “You”, “User” refers to the user, or partner for various services provided by Us, as applicable. This Information may be received through Your access, delivery or utilization of various facilities, services provided by Us (“Services”) through Your access, interaction, or use of Our portal, network, website, or mobile application (together referred to as “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 for receipt of or partnering in the delivery of the 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 Platform and Services are for use and delivery only in India. The same is not meant for use outside India. 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.

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 or acceptance of Our Services implies that You have read and accepted this Policy. By accessing or using or partnering in 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 or partnering in 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 shall not be in violation of any agreement, laws, charter documents, judgments, orders and decrees.
3. You shall 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. Your understand these third parties may have their own security standards to safeguard Your Information or data and We will, require such third parties to comply with Applicable Laws 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 or partnering in the delivery of the Services, 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.
6. 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 or unlawfully access any personal data.

What we collect?

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

• Towards KYC and for delivery and receipt of Services

• 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 directly or through our agents, to Us to provide to Us or to avail from Us various Services.
• Images/ Photos of documents/ live photo/ Video provided by You or received from You directly, or through our agents, for availing or delivering any of Our Services.
• User demographic information, Financial details (e.g. credit history), 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) for assessment of, or for provision of various services provided or received by You, or partnered by You, or as required by Us under Applicable Laws.
• Phone number, transactional and promotional SMS/app notifications.
• Your details including purchase history/ transaction history, balances, payment details, Your virtual account/ trade balance account details, for maintaining of records (as per the Applicable Laws).

• 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, all to the extent necessary to ensure safety receive or deliver the Services.
• 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.
• We may also conduct User behaviour analysis including preferences and interests to ensure proper delivery of the Services, as per the consents that You provide to Us.

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.
• Troubleshooting.
• 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 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 share with You, updates on changes to the Services and their terms and conditions including Platform’s terms and conditions.
• To undertake research and analytics for offering or improving Our Services and their security and service quality;
• To verify Your identity for Us to provide Services and to help us understand the usage trends.
• 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 Send You Our newsletter and 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.

Collection and use of non-personal information

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. We may collect Your non-Personal Information whenever You use and interact with the Platform to ensure proper delivery and receipt of Services.

This Information is aggregated and used to help to understand which part of the Services and/or the Platform are of Your most interest to You and to provide more useful information to You.

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 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.

Security

We are committed to ensuring that Your Personal Information is secure. We adopt appropriate data collection, storage, and processing practices and security measures in accordance with Applicable Laws 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.

We have comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures 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 may be available the service provider or service facilitator as involved. To secure the Personal Information, provided by You, We require our partners to comply with Applicable Laws.

Please note that You are responsible for the Personal Information You choose to submit to Us. If You list Your name and email address in any blog/forum posting enabled as part of the Platform or Services, 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 and due to the inherent nature of technology, We cannot warrant complete security of all Information that You share with Us. 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.

Retention of Personal Information

We will retain Your Personal Information for as long as such retention is required under Applicable Laws, or until You withdraw Your consent, whichever occurs later. Where You have requested us for the deletion of Your Personal Information, the same will be erased by Us as detailed in section K below, except for record retention as mandated by Applicable Laws and as required for legal, regulatory purposes.

Sharing Personal Information

We may use third-party service providers to help Us operate Our business and to provide Services. We take steps to ensure that such third-party service providers used by Us will only use Your information to the extent necessary to allow them to perform the Services, or the activities they provide to Us. We share Your Personal Information with these third parties, for those limited purposes.

Please note that 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 as per the terms of this policy, You are governed by the third party partners Terms and Conditions and in such circumstances the privacy policy of such other website will apply where You interact with them. Where You have submitted information to third party services providers, or have availed the services of such third party services providers, We will not be liable for their any acts or omissions.

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 and Services.
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 for 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 and with auditors for audit related purposes.
5. Marketing, business development, and sales partners:We may share Your Information with marketing, business development and sales partners, where We have Your consent, 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 where they are involved in providing the Services and/or particular features, or for internal corporate/business restructuring purposes.
7. In any other circumstances where We have Your consent for any other purpose disclosed by Us to You.

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. Where You proceed to third party Site, please note that 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.

Browsing and interaction on any other website, including websites and platforms which have a link to the Services, is subject to that website and such platform’ terms and policies. These sites and platform, including their content and links, may be constantly changing and these sites and platform may have their own privacy policies and customer service policies and You will be governed by the same.

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.

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.

Your Rights

You have the right to revoke or withdraw Your consent for the collection and use of Your Personal Information at any time. By submitting a request at customercare@spicemoney.com, You may review, correct, complete or rectify the inaccurate Personal Information that is stored with Us.

Upon receiving Your request for deletion of Your Perosnal Information, We will proceed to stop the further processing of Your Personal Information. 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.

Notwithstanding the above, as elaborated in section B above, please note that there are certain situations where We will be legally obligated to retain Your Personal Information, under the Applicable Laws.

Contact Us

You may contact us pertaining to this policy including the matters as detailed below, by submitting a request to customercare@spicemoney.com:

1. In case of any query pertaining to Your personal information submitted to Us.
2. to update or modify Your personal information
3. to revoke or withdraw Your consent for the collection and use of Your Personal Information
4. a summary of Your Personal Information being processed by Us and the processing activities undertaken with respect to such Personal Information;
5. any other information related to Your Personal Information and its processing, as may be prescribed under the Applicable Laws.

We will expeditiously endeavour to resolve the query/grievance within a period of 30 (thirty) days from the date of receipt of the query/grievance.

In case Your queries or concerns pertaining Your personal information is not resolved within such period, please contact or email Our grievance officer, at 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

Governing Law and Dispute Resolution

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 sole and exclusive jurisdiction of the courts at Delhi, India.