By entering this website (spacapital.com), the visitor consents to the terms of this policy. By submitting his/her Information to SPA, the visitor will be treated as having given his/her permission for processing the same in a manner provided in this policy.
At SPA Capital Services Ltd and its Group Companies and Affiliates (SPA), we respect the privacy of individual/visitor and are committed to take reasonable precautions to protect information consisting of personal information and `Sensitive Personal Data or Information’ (SPDI) (“Information”) of visitors of this SPA website, comply with all legal, regulatory and/or contractual obligations related to privacy. SPA has adopted the “Privacy by Default” principles in its approach to data privacy i.e. privacy of data and information is upheld first by default.
This policy covers the processing, storage and access to Information as required under lawful and/or contractual activities with SPA or otherwise required in the normal course of business. It describes SPA’s policies and procedures on the collection, usage and disclosure of Information provided/received by natural persons and meets the requirements established under:
- The Information Technology Act, 2000 – Section 43A;
- The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.
Scope of this Policy
This policy applies to all visitors of this SPA’s website (spacapital.com).
Information covered by this Policy
This policy applies to Information collected and processed by SPA consisting of following: Personal information is information related to a visitor, or a combination of pieces of information that could reasonably allow him to be identified. Personal information may consist of full name, personal contact numbers, residential address, email address, gender or date of birth.
Sensitive personal data or information (“SPDI”) is such personal information that is collected, received, stored, transmitted or processed by SPA, consisting of:
- KYC Status;
- Financial information such as bank account or credit card or debit card or other payment instrument details;
- Sexual orientation;
- Medical records and history;
- Any detail relating to the above personal information categories as provided to SPA for providing service; and
- Any of the information received under above personal information categories by SPA for processing, stored or processed under lawful contract or otherwise.
Please note that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal information.
Purpose of this Policy
SPA shall collect and use Information for legitimate business purposes in order:
- that a visitor may download product information, order products or Services and take advantage of certain other features of SPA’s website;
- to provide information or interactive services through this website, to the visitor’s e-mail address or, where the visitor wishes it to be sent by post, to the visitor’s postal address;
- to seek the visitor’s feedback or to contact the visitor in relation to the services offered on SPA’s website;
- to process orders or applications submitted by the visitor;
- to administer or otherwise carry out SPA’s obligations in relation to any agreement that the visitor may have with SPA;
- to anticipate and resolve problems with any goods or services supplied to the visitor;
- to create products or services that may meet the visitor’s needs;
- to process and respond to requests, improve SPA’s operations, and communicate with visitor/s about SPA’s products, services and businesses; and
- to allow the visitor to subscribe to SPA’s news alerts.
Collection of Information
Only minimum Information required to meet the purposes mentioned in this policy shall be collected from the visitor/s. Neither SPA nor its representatives shall be responsible for the authenticity of such Information provided by the visitor/s. As normal business practice, SPA may collect Information in order to enable the secure online authentication, interaction and transaction with natural persons. This may include the installation of cookies and the collection of other session data.
Access and Correction of Information
Any modifications / corrections required to the Information can be carried out on the website. In the event the visitor is unable to do so due to lack of functionality in SPA’s website, she/he may contact SPA on the email id given in clause 8.
Retention, Processing and storage of Information
SPA shall retain Information for only as long as necessary to meet legal or regulatory requirements or for legitimate business purposes as mentioned in this policy.
SPA has implemented required security practices and have a comprehensive documented information security program and policy in place, which contains managerial, technical, operational and physical security control measures that commensurate with the information assets being protected with SPA’s nature of business. It is being reviewed periodically to keep pace with business, technology and regulatory changes.
SPA cannot, however, ensure or warrant the security of any information transmitted and visitors may do so at their own risk. This is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. To protect visitor’s privacy and security, SPA takes reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. Visitors are responsible for maintaining the secrecy of their unique password and account information, and for controlling access to their email communications from SPA, at all times.
Disclosure of Information
SPA shall not use or disclose Information for purposes other than as mentioned in this policy, except with the consent of the visitor providing such Information or as required by law. However, SPA may be legally required to disclose the Information in the following cases:
- Where the disclosure is necessary for compliance of a legal obligation;
- Where mandated under the law by government agencies to disclose such Information.
Where necessary, SPA may disclose Information to business partners or third parties during the normal course of business for the purposes mentioned in this policy. In such cases, SPA will only share Information related data, assured that:
- The Information is processed legitimately and appropriately by the business partner or third party in line with the established consent or in line with legal requirements.
- The business partner or third party has adopted a reasonable and equivalent level of security practices and procedures to ensure security of the Information shared.
Contact for Feedback or Concern
For feedback or concern, if any, kindly contact:
Email Id: firstname.lastname@example.org