Dvara Money Private Limited Privacy Policy

Welcome to the Spark Dost App (“Spark Dost Platform”) owned and operated by Dvara Money (“Dvara Money”), which presently has its registered office at Chennai.

This Spark Dost Privacy Policy is a part of the Spark Dost T&C [●] applicable to Spark Dost for imparting Spark Dost Services to Dvara Money through the Spark Dost Platform.

All terms defined in the Spark Dost T&C have the same meaning used here in this Spark Dost Privacy Policy. This Spark Dost Privacy Policy shall apply to all Spark Dosts who are onboarded for the purpose of imparting Spark Dost Services to Dvara Money through the Spark Dost Platform. Spark Dosts unconditionally agree that browsing and/ or imparting Spark Dost Services through the Spark Dost Platform signifies their unconditional assent to this Spark Dost Privacy Policy. We respect the privacy of Spark Dosts and are committed to protect it in all respects. Any dispute with Dvara Money over privacy matters are subject to this Spark Dost Privacy Policy read in conjunction with the Spark Dost T&C and the Engagement Letter

This Privacy Policy is published in compliance of:

Section 43A of the Information Technology Act, 2000;
Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”) “Personal Information” and “Sensitive personal data or information” shall be as defined under the SPI Rules. The information about the Spark Dosts as collected by Dvara Money is:

information supplied by Spark Dosts and
information automatically tracked while navigation (Information).

In order to access the Spark Dost Platform, Your name and mobile number which is provided by the Spark Dost in pursuance of the Engagement Letter shall be utilized and the same is classified as ‘Sensitive Personal Information’ under Regulation 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPI Rules”). Accordingly, the usage of the Spark Dost Platform for the purpose of imparting the Spark Dost Services shall amount to written consent under Regulation 5 of the SPDI Rules.

In addition to the above, the below access from the device utilized by the Spark Dost for using the Spark Dost Platform shall be required and the same shall be classified as ‘Sensitive Personal Information’:

Type of access provided by You	Purpose	Time Period
Camera	To capture the image of the Customer documents	Until engagement with Dvara Money as a Spark Dost
Storage	To upload the image of the Customer documents from photo gallery directly	Until engagement with Dvara Money as a Spark Dost
Location	Requirement of the Partner Bank in connection with the biometric KYC process of the Customer	Until engagement with Dvara Money as a Spark Dost
Bluetooth	For connecting with the biometric machine or thermal printer	Until engagement with Dvara Money as a Spark Dost
Fingerprint	Requirement of the Partner Bank as part of biometric KYC process	Until engagement with Dvara Money as a Spark Dost
Bluetooth	For connecting with the biometric machine or thermal printer	Until engagement with Dvara Money as a Spark Dost
Notification	For notifying any updates	Until engagement with Dvara Money as a Spark Dost

You shall be able access Spark Dost Platform using the mobile number registered with Dvara Money and the OTP generated each time while accessing Spark Dost Platform (collectively, “Login Credentials”).

To improve the responsiveness and Spark Dost interface for our Spark Dosts, Dvara Money may use “cookies”, or similar electronic tools to collect information to assign each Spark Dost a unique, random number as a Spark Dost Identification (Spark Dost ID). Unless You voluntarily identify yourself, Dvara Money cannot know who You are, even if We assign a cookie to Your computer. The only Personal Information a cookie can contain is information You supply. A cookie cannot read data off Your hard drive. We receive and store certain types of information whenever You interact with Us via the Spark Dost Platform though Your computer/laptop/netbook or mobile/tablet/pad/handheld device etc.

For rendering the Spark Dost Services, You shall be redirected to the platform/ website of the Service Partners and/ or the Facilitators as the case maybe. Once You leave the Spark Dost Platform, You shall be governed by the privacy policy of such Service Partners and/ or the Facilitators may include links to other websites or mobile applications.

Deletion of Spark Dost’s data/ information:

Upon the expiry of the Engagement Letter, the data/ information of the Spark Dost shall be deleted from the database of Dvara Money subject to the terms herein and the Engagement Letter.
In the event the Spark Dost desires for the deletion of his/ her data/ information including Sensitive Personal Information available with Dvara Money at any time, the Spark Dost must terminate the Engagement Letter in pursuance of the terms therein. Upon the completion of the notice period as mentioned in the Engagement Letter, Dvara Money shall delete the information of the Spark Dost from its database subject to the terms herein and the Engagement Letter.
Provided however, if required by regulatory, audit, legal and or statutory requirements, We will have the right to keep a copy of Your data/information provided by You for such statutory, audit, legal and or regulatory purposes, as the case may so require.
For the avoidance of doubt, it is clarified that in case of a deletion request with respect to the data/ information, such request shall not have an automatic effect of withdrawal/ deletion of data/ information stored at the Facilitators and Service Partner’s end. In connection with this, the Spark Dost will have to take the steps as mentioned in such Facilitators and Service Partner’s terms and conditions.

We take utmost care our Spark Dost’s Personal Information and/or Sensitive Personal information and we share Spark Dost’s personal information with our employees and third- party facilities providers strictly on a “need to know” basis. Hence, We take all such steps to ensure that electronic records are valid under the Information Technology Act, 2000 as amended from time to time and notifications and rules framed thereunder.

Dvara Money may share the sensitive Personal Information to any third party without obtaining the prior consent of the Spark Dost in the following limited circumstances:

When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences.
Dvara Money proposes to share such information within its group companies and officers and employees of such group companies and/or third-party service provider for the purpose of processing Personal Information on its behalf.
Dvara Money may use third-party advertising companies and/or within group companies to serve ads when the Spark Dost’s uses the Spark Dost Platform. These companies may use Personal Information about the Spark Dost’s visit to the Spark Dost Platform and other websites in order to provide advertisements about goods and services of interest to the Spark Dost.
Dvara Money shall transfer information about the Spark Dost in case Dvara Money is acquired by or merged with another entity .
Dvara Money may share the Personal Information with the Service Partners, Facilitators and such other third-parties on a need-to-know basis.

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. All information gathered on Dvara Money is securely stored within Dvara Money controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. However, as effective as Our security measures are, no security system is impenetrable. We cannot guarantee the security of Our database, nor can We guarantee that information You supply will not be intercepted while being transmitted to Us over the Platform.

Grievance Redressal

Redressal Mechanism: Any complaints, abuse or concerns with regards to content and or comment or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email signed with the electronic signature to Grievance Officer, at [email protected] or write at the following address:

Chinmay Bhat, Dvara Money, Contact no: +91 99728 18380, No. 3/1, 2nd Floor, PID No 82-19-3/1, 100 Feet Road, Indiranagar, Bangalore - 560038

We request the Spark Dost to please provide the following information in his/her complaint:

Identification of the information provided by Spark Dost.
Clear statement as to whether the information is personal information or sensitive personal information.
Spark Dost address, telephone number or e-mail address.
A statement that You have a good-faith belief that the information has been processed incorrectly or disclosed without authorization, as the case may be.
A statement, under penalty of perjury, that the information in the notice is accurate, and that the information being complained about belongs to Spark Dost

I acknowledge that I have read and do hereby accept the terms and conditions contained detailed above.