Overview
This privacy policy ("Privacy Policy") is incorporated by reference into the Terms and Conditions (the "Terms and Conditions" or "Terms").
Website and mobile application – Spindhan (collectively referred to as the "Platform") is owned and operated by Spindhan ("Spindhan", "We" or "Us") to provide you with our services.
This Privacy Policy applies to all the Users whose Personal Information has been processed by Us in the course of our task-based reward platform, including task completion services, spin-to-win activities, and reward redemption.
We respect your privacy and hence, handle your personal data with the utmost care and confidentiality.
By visiting the Platform, You ("You" or "Your") accept and agree to be bound by the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms and Conditions of the Platform ("Terms") and shall be read harmoniously and in conjunction with the Terms.
Important Disclaimer
BY USING AND ACCESSING THE PLATFORM AND BY AVAILING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE, SHARING, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.
Collection of Information
To provide you with the Services, we collect, use and process your personal information (as defined below), including your sensitive information (as defined below). The types of personal information we may collect (directly from you or from third-party sources) and our privacy practices depend on the nature of the relationship you have with the Company and the requirements of applicable law.
Information that You Provide to Us
Account Registration Information:
- Full name
- Mobile number
- Email address
- Date of birth
- Gender
- Password and security credentials
KYC Information:
- Government-issued photo identification
- Address proof documents
- Bank account details
- UPI ID information
- Biometric data (if required)
- Digital signatures
Financial Information:
- Bank account numbers and IFSC codes
- UPI payment details
- Transaction history and patterns
- Tax identification numbers (PAN)
- Withdrawal and deposit records
Device and App Permissions
We request the following permissions:
- Camera: For document verification and KYC processes
- Gallery/Photos: To upload KYC documents
- Contacts: For referral programs (with explicit consent)
- SMS: To read OTP messages for verification
- Location: For compliance with local regulations and fraud prevention
- Device Storage: To cache app data and improve performance
- Phone: For account verification and customer support
Automatically Collected Information
Usage and Activity Data:
- Task completion patterns and performance
- Spin wheel interaction history
- App navigation and feature usage
- Session duration and frequency
- Reward claiming behaviour
Technical Information:
- Device type, model, and operating system
- IP address and network information
- Browser type and version
- App version and update history
- Crash reports and error logs
How We Use Your Information
Core Platform Services
- Account Management: Creating, maintaining, and securing user accounts
- Task Administration: Providing skill-based tasks and tracking completion
- Reward Processing: Managing spin wheel mechanics and prize distribution
- Payment Processing: Facilitating withdrawals and financial transactions
- Customer Support: Responding to queries and resolving issues
Compliance and Security
- KYC Verification: Identity verification as per regulatory requirements
- Anti-Fraud Protection: Detecting suspicious activities and preventing abuse
- AML Compliance: Monitoring transactions for money laundering prevention
- Tax Compliance: Generating tax documents and TDS certificates
- Regulatory Reporting: Compliance with Indian financial regulations
Platform Improvement
- Analytics: Understanding user behaviour to improve services
- Personalisation: Customising task recommendations and rewards
- Performance Optimisation: Enhancing app functionality and user experience
- Marketing Communications: Sending relevant updates and promotional offers
Information Sharing and Disclosure
Service Providers and Partners
We may share your information with:
Payment Processors:
- Banks and payment gateways for transaction processing
- UPI service providers for digital payments
- Financial institutions for KYC verification
Technology Partners:
- Cloud storage providers for secure data hosting
- Analytics platforms for app performance monitoring
- Customer support tools for query resolution
Compliance Partners:
- KYC verification agencies
- Credit bureaus (if applicable)
- Tax authorities, as required by law
Legal and Regulatory Disclosure
We may disclose your information:
- To comply with legal obligations under Indian laws
- In response to government requests or court orders
- For regulatory compliance with authorities
- To protect our rights and prevent fraud or illegal activities
- In emergency situations, to protect user safety
Data Security Measures
Technical Safeguards
- Encryption: All sensitive data is encrypted in transit and at rest
- Secure APIs: Protected communication channels for all transactions
- Access Controls: Role-based access to user information
- Regular Security Audits: Periodic assessment of security measures
- Fraud Detection Systems: Real-time monitoring for suspicious activities
User Responsibilities
- Keep login credentials confidential
- Do not share OTP or verification codes
- Report suspicious account activity immediately
- Use secure networks for app access
- Update app regularly for the latest security features
Data Retention and Storage
Retention Periods
- Active Account Data: Retained while account remains active
- Transaction Records: Maintained for 7 years as per financial regulations
- KYC Documents: Stored as required by regulatory guidelines
- Communication Records: Kept for 3 years for support purposes
- Analytics Data: Anonymised data may be retained indefinitely
Data Storage
- Location: Secure cloud infrastructure within India
- Backup Systems: Regular backups with encryption
- Access Logging: All data access activities are logged and monitored
Your Privacy Rights
Access and Control
- Data Access: Request copies of your personal information
- Data Correction: Update or correct inaccurate information
- Data Portability: Obtain data in a structured, machine-readable format
- Account Deletion: Request account closure and data removal
Communication Preferences
- Opt-out: Unsubscribe from marketing communications
- Notification Settings: Control app notifications and alerts
- Email Preferences: Manage email communication types
Children's Privacy
Age Restriction: Spindhan is not intended for users under 18 years of age.
If we discover that we have collected information from a minor without proper parental consent, we will delete such information immediately. Parents who believe their child has provided information should contact us immediately.
Updates to Privacy Policy
Policy Changes
We may update this Privacy Policy to reflect:
- Changes in legal requirements
- New platform features or services
- Enhanced privacy protections
- User feedback and requirements
Notification of Changes
- Major Changes: 30-day advance notice via email and app notifications
- Minor Updates: Notice through app interface and website
- Continued Use: Constitutes acceptance of updated policy
Grievance Redressal
Response Timeline
- Acknowledgement: Within 24 hours
- Resolution: Within 15 days of complaint receipt
- Escalation: Further appeal options available if not satisfied
