A. Introduction
This Privacy Policy (“Policy”) outlines the practices and policies of Spice Bulls 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 (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:
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:
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 modify, revoke or withdraw Your consent for the collection and use of Your Personal Information at any time as per the procedure prescribed in section K below. However, please note that we will not be able to delete your KYC related information, financial and transaction information as per the applicable guidelines.
C. What we do with the Personal Information We Gather?
We may use Your Personal Information to:
D.1 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.2. 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.
You are responsible for the correctness of the Personal Information which You choose to submit to Us.
If You list Your name and email address in a blog/forum posting, then that information is public which will not be under the control of the Company. You are requested to take care when using any such 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 and as permitted or prescribed under Applicable Laws. Subsequently, the Personal Information will be erased by Us.
G.1 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.
G.2 Disclosures
Following are the third parties to whom Your Personal Information is shared with.
Specific consent for sharing Your Information with third parties, group companies will be sought from You, where so required under Applicable Laws.
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. Any sharing of information with third party service providers, group companies shall be under agreements which has confidentiality clauses restricting such parties with regard to the use of such Personal Information and in compliance with the provisions of Applicable Laws.
H. 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.
I. 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.
J. 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.
K. Your Rights
You have the right to update, 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 at care@spicebulls.com. Upon receiving Your request, We will proceed to update, limit the use of Your Personal Information in Our records as required under Applicable Laws.
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.
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 care@spicebulls.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 care@spicebulls.com:
L. Support and Escalations
For any service related support or for any consent related support as detailed above, please contact or email our customer care at care@spicebulls.com.
Address: 326,Ansal Chambers-II, Bhikaji Cama Place R.K. Puram,
South West Delhi, New Delhi, Delhi, India, 110066.
For escalations with related to privacy concerns, please reach out to our grievance officer, at the contact details as below. Our grievance officer will attempt to expeditiously redress your grievances:
Name - Sanatan Malik
Designation - Grievance Officer
Email - legal@spicebulls.com
326,Ansal Chambers-II, Bhikaji Cama Place R.K. Puram,
South West Delhi, New Delhi, Delhi, India, 110066.
M. 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.
Spicebulls Investments Limited (“Spicebulls” or “We” or “Us” or “Our” or “Company” which also includes its affiliates) is registered as a non-banking financial company duly authorized by the Reserve Bank of India (“RBI”) to provide financial services (“Services”). Spicebulls has its registered office at 326, Ansal Chambers-II, Bhikaji Cama Place R.K. Puram, South West Delhi, New Delhi, India, 110066. Using this site by implication, means that user “You/Customer” have gone through and agreed and abide by following terms & conditions (“Terms”).
This document is an electronic record in terms of Information Technology Act, 2000, amendments thereof from time to time and the rules thereunder as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.
1. GENERAL
2. Conditions of Use
3. Terms and Conditions for Loan Application
You hereby acknowledge and confirm that:
4. Privacy Policy & Data Protection
5. Proprietary Rights and Licence
6. Availability
7. Limitation of Liability
8. Disclaimer of Warranties
9. Indemnification
You agree to indemnify and hold the Company, its officers, directors, shareholders, employees, sub-contractors, agents, parent companies, sister companies, subsidiaries and other affiliates, indemnified and harmless from any claim or demand, including reasonable attorneys' fees, made by any third party due to or arising out of Your use of the Platform or the Services, any unauthorised use of the Platform or Services by You, Your violation of these Terms, or Your violation of any rights including rights in any form of intellectual property of any third party and/or any violation of applicable law by You.
10. Amendments to The Terms
11. Entire Agreement
The Terms including the Privacy Policy constitutes the entire agreement between You and the Company and governs Your access and use of the Platform and Services, superseding any prior agreements between You and the Company with respect to the Platform and Services. If any provision of these Terms is, or is found to be, unenforceable under Applicable Laws, that will not affect the enforceability of the other provisions of these Terms.
12. Governing Law and Dispute Resolution