Privacy Policy

This Privacy Policy (defined below) was last updated: 06 August 2019 and is effective from 06 August 2019.

“Spolu” is a trademark of Spolu Perfect Service Inc., hereinafter referred to as “Spolu” or “We” or “our”.

It is hereby stated that Spolu values Your (wherever referred to in this Privacy Policy, would apply to the Users of the Spolu Website and App and the Service Partner as registered with the Spolu) privacy.

In this “Privacy Policy”, We detail the information that We collect about You when You visit our website, www.Spolu.in (the “Website“) or our mobile application namely “Spolu” (the “App”) and use the Services available on the Website or App, and how We use and disclose that information.

In terms of the Information Technology (Intermediaries Guidelines) Rules, 2011 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, any grievance or complaint may be intimated to Grievance Officer, who may be reached at care@Spolu.in. The complaint shall be redressed within a period of 07 (seven) working days from the date of receiving the complaint on the aforementioned e-mail id.

Any term not specifically defined herein would derive the meaning from the “Terms and Conditions” of the Spolu’s Website and / or App and “Terms of Vendor Registration”.

If You have any questions or comments about the Privacy Policy, please contact us info@Spolu.in. Your use of the Website/App and/or Services and any personal information You provide on the Website/App remains subject to the terms of the Policy and Spolu’s Terms of Use.

COLLECTION OF PERSONAL INFORMATION

Personal information” is defined to include information that whether on its own or in combination with other information may be used to readily identify or contact You such as: name, address, email address, phone number etc.

We collect Personal Information from Users who are using our Website and / or App. These information are partially or completely accessible to all other Users using Spolu’s Website or App, either directly or by submitting a request for a Service in any respective area. Service Partners and User sare required to create an account to be able to access certain portions of our Website / App, such as to submit questions, participate in polls or surveys, to request a quote, to submit a bid in response to a quote, and request information. Service Partners / Users, if and when they create and use an account with Spolu, will be required to disclose and provide to Spolu information including personal contact details, bank details, personal identification details (such as PAN card, Aadhar card, phonebook, call logs etc.) and participate in polls or surveys or feedbacks etc. Such information gathered shall be utilized to ensure greater customer satisfaction and help a customer satiate their needs. The type of personal information that We collect from You varies based on Your particular interaction with our Website or App.

Users: During the Account registration process and during Your usage of Spolu’s Website or App, We will collect information such as Your name, postal code, telephone email address and other Personal Information. You also may provide us with Your, mailing address, and demographic information (e.g., gender, age, political preference, education, race or ethnic origin, and other information relevant to Users surveys and/or offers). We may also collect Personal Information that You post in Your Offer, Profile, Wants, or Feedback, and any comments or discussions You post in any blog, chat room, or other correspondence site on the Website or App, or any comments You provide during dispute resolution with other Users of the Website or App.

Service Partners: If You are a Service Partners and would like to post any Personal Information about Yourself, We will require You to register an Account on the Website and / or App. During the Account registration process, We will collect Your business name, telephone number, address, zip code, travel preferences, a description of Your services, a headline for Your profile, first and last name, and email address. Other information may also be required to be provided to Spolu whilst You avail and use Spolu’s Website or App. In addition, You may, but are not required to, provide other content or Personal Information or any other information regardingYour business, including photographs and videos, which You may feel should not be given. Wealso may collect payment information, such as credit card information, from You.

Background Verification: The Service Partner acknowledges that as part of the on-boarding process, Spolu or an entity /agency appointed or nominated by Spolu (“Verifier”), may undertake background verification checks of the Service Partners in order to authenticate inter alia the genuineness and competency of the Service Partners. In light of the above, the Service Partners expressly consents to and acknowledges the following:

  • The Service Partners does not and will not have any objection to Spolu sharing the Service Partner’s Personal Information and documents, including but not limited to name, gender, date of birth, addresses, mobile number, email, education record, employment record, Aadhar number, other government issued IDs such as Voter ID, PAN card, driving license etc. (collectively “Proprietary Information”) with the Verifier for the purpose of background checks and verification.
  • The Service Partners authorise the Verifier to securely store the Service Partner’s Proprietary Information on their platform and understands that the Verifier shall endeavor to ensure confidentiality of the same.
  • The Service Partners acknowledges that the digital record of the Proprietary Information on the Verifier’s platform shall be accessible to Spolu and their authorizedUsers/ other Service Partners/affiliates/contractors, shall be entitled to access and update such digital record on the Verifier’s platform, including data, documents, certificates, verification reports, references, testimonials, etc. and shall be entitled to use the related services provided via the Verifier’s platform.
  • The Service Partners acknowledges that if the Service Partners is desirous of editing its digital record from the Verifier’s platform, it shall be entitled to do so by sending an email to such email address of the Verifier which shall be immediately provided by the company to the Service Partners, and in such a manner as the Verifier requires the same.
  • Spolu reserves its right to take appropriate actions (in its sole discretion) pursuant to the outcome of the background check and verification.
  • Spolu reserves the right to record the conversations between Service Partners and Usersfacilitated by Spolu through the messaging/chat mechanism on the Website and / or App,or the calls made through the virtual numbers provided to safeguard the privacy of Usersand Service Partners. All the chat/messaging logs or call recordings can be used to but not limited to monitor and prohibit abuse, safeguard the rights of Users and Service Partners, resolve disputes.

If Wedeem it necessary, in our sole and absolute discretion, We may also ask for and collect supplemental information from third parties, such as information about Your credit from a credit bureau (to the extent permitted by law), or information to verify any identification details You provide during registration.

You may log into our Website and / or App using Your mobile number. An OTP (one time password) will be generated and sent to the stated mobile number. We will then be asking Your other particulars, including but not limited to, name, goods and service tax registration no., e-mail id, and address with respect to completion of your profile and subsequently creation of account.

We store the information that We receive from You and the documents uploaded by You with other information that We receive about You for, including but limiting to, the purposes of this Privacy Policy read together along with “Terms and Conditions” of the Website and / or App and “Terms of Vendor Registration”.

Facebook controls the information it collects from You. For information about how Facebook may use and disclose Your information, including any information You make public, please consult Facebook’s privacy policy. Wehave no control over how any third party site uses or discloses the personal information it collects about You.

We and our third party Service Partners, which include ad networks, use cookies, web beacons, and other tracking technologies to collect information about Your use of our Website/App, such as Your browser type, Your ISP or operating system, Your domain name, Your access time, the URL of the previous website You visited, Your page views, Your IP address, and the type of device that You use. Wealso track how frequentlyYou visit our Website and use our Services. We use this information (including the information collected by our third party service providers) for Website analytics (including to determine which portions of our Website are used most frequently, what our Users like/do not like), to assist us in determining relevant advertising (both on and off our Website), to evaluate the success of our advertising campaigns, and as otherwise described in this policy.

We may obtain Your device ID, which is sent to Spolu’s servers and use it in fraud prevention efforts.

Cookies: We and our third party Service Partners collect information from You by using cookies. A cookie is a small file stored on Users’s computer hard drive containing information about the Users. The cookie helps us analyze web traffic or informs You about Your use of a particular website. Cookies allow web applications to respond to You as an individual, tailoring its operations to Your needs, likes and dislikes by gathering and remembering information about Your preferences. When You visit the Website or App, We may send one or more cookies (i.e., a small text file containing a string of alphanumeric characters) to Your computer that identifies Your browser.

Some of these cookies may be connected to any third-party companies or websites. The terms of use of such cookies are governed by this Privacy Policy and such policies of the relevant third party company or website. For example, Google measures the performance of advertisements by placing cookies on Your computer when You click on ads. If You visit the Website when You have such cookies on Your computer, We and Google will be able to tell that You saw the ad delivered by Google. The terms of use of these cookies are governed by this Policy and Google’s Privacy Policy.

Disabling Cookies: You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but You can usually modify Your browser setting to decline cookies if You prefer. If You disable cookies You may be prevented from taking full advantage of the Website because it may not function properly if the ability to accept cookies is disabled.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on Your computer’s hard drive, clear GIFs are embedded invisibly on web pages.

This Website and App contains a software development kit (“SDK”) from a third party, namelyAsian Checkout Pvt. Ltd., having registered office 130, Sector 37, Faridabad 121 003, Haryana, India. The SDK is integrated with this App for the purposes of profiling the device on media consumption and other device data and utilising the same to analyze media behavior and/or target relevant content and ads to the devicepursuant to the terms and conditions of Asian Checkout Pvt. Ltd..

Asian Checkout Pvt. does not collect any personally identifiable information or audio/video / image/contact files from Your mobile device or electronic gadget or appliance. Asian Checkout Pvt. also automatically receives and tracks certain data about Your mobile device (such as Your device-type, installed software and language preference) Your taps and interests; and may create a unique device or Users ID for You. In some cases Asian Checkout Pvt. Ltd. can automatically detect or infer Your location using GPS, Your IP address, watermarks, but often Your operating system will require You to grant permission to access Your GPS; please refer to Your device’s system settings regarding location services.

HOW WE USE THE INFORMATION COLLECTED

We collect Your Personal Information and aggregate the sameabout the use of our Website and / or App and Services to better understand Your needs and to provide You with a better Website experience. Specifically, We may use Your personal information for any of the following reasons:

  • To provide our Services to You, including registering You for our Services, verifying Your identity and authority to use our Services, and to otherwise enable You to use our Website/App and our Services;
  • For customer support and to respond to Your inquiries;
  • For internal record-keeping purposes;
  • To process billing and payment, including sharing with third party payment gateways in connection with Website and/or Spolu’s products and Services;
  • To improve and maintain our Website/App and our Services.
  • To periodically send promotional emails to the email address You provide regarding new products from Spolu, special offers from Spolu or other information about Spolu that Wethink You may find interesting;
  • To contact You via email, telephone, facsimile or mail, or, where requested, by text message, to deliver certain services or information You have requested;
  • For Spolu’s market research purposes, including, but not limited to, the customizationof the Website / App according to Users’ interests;
  • We may use Your demographic information (i.e., age, postal code, residential and commercial addresses, and other various data) to more effectively facilitate the promotion of goods and services to appropriate target audiences and for other research and analytical purposes;
  • To resolve disputes, to protect ourselves and other Users of our Website/App and Services, and to enforce our Terms of Use;
  • We also may compare personal information collected through the Website / App and Services to verify its accuracy with personal information collected from third parties; and
  • We may combine aggregate data with the Personal Information thatWe collect about You.
  • From time to time, Spolu may use personal information for new and unanticipated uses not previously disclosed in our Privacy Policy.

ELECTRONIC NEWSLETTERS, INVITATIONS, POLLS AND SURVEYS

At our sole discretion, Spolu may offer any of the following free services on the Website/App, which You may select to use or receive at Your option. Certain of the following services may require You to provide additional personal information as detailed below:

Electronic Newsletters: We may offer a free electronic newsletter to Website / App Users. We will gather the email addresses of Users who sign up for Spolu for the newsletter mailing list. Users may remove themselves from this mailing list by opting out of receiving newsletters during the registration process, by following the link provided in each newsletter that points Users to a subscription management page where the Users can unsubscribe from receiving newsletters or by changing their preferences in their Profile Settings page.

“Send To A Friend”: Our Website and / or AppUsers can voluntarily choose to electronically forward a link, page, or document to someone else by clicking “send to a friend.” To do so, the Users must provide his or her email address, as well as the email address of the recipient. The Users email address is used only in the case of transmission errors and, of course, to let the recipient know who sent the email. The information is not used for any other purpose.

Polling: We may offer interactive polls to Users so they can easily share their opinions with other Users and see what our audience thinks about important issues, Services, and/or the Website/App. Opinions or other responses to polls are aggregated and are not identifiable to any particular Users. We may use a system to “tag” Users after they have voted, so they can vote only once on a particular question. This tag is not correlated with information about individual Users.

Surveys: We may conduct Users surveys from time to time to better target our content to our Website/AppUsers. We will not share individual responses from these surveys with any third party. We will share aggregate data with third party service providers, Service Partners, and other third parties. We may also will post aggregate data containing survey responses on our Website / app; that data may be viewed and downloaded by other Users of our Website/App.

SECURITY

We employ procedural and technological security measures, which are reasonably designed to help protect Your personal information from unauthorized access or disclosure. Spolu may use encryption, passwords, and physical security measures to help protect Your Personal Information against unauthorized access and disclosure. No security measures, however, are 100% complete. Therefore, We do not promise and cannot guarantee, and thus You should not expect, that Your personal information or private communications will not be collected and used by others. You should take steps to protect against unauthorized access to Your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping Your log-in and password private. Spolu is not responsible for the unauthorized use of Your Persona Information or any other informationor for any lost, stolen, compromised passwords, or for any activity on Your Account via unauthorized password activity.

DISCLOSURE

We may share the information that We collect about You, including Your personal information, as follows:

  • We may disclose Your information including Personal Information if: (i) Spolu reasonably believes that disclosure is necessary in order to comply with a legal process (such as a court order, search warrant, etc.) or other legal requirement of any governmental authority, (ii) disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iii) reasonably necessary to enforce this Privacy Policy, our Terms of Use etc. (iv) disclosure is intended to help investigate or prevent unauthorized transactions or other illegal activities, or (v) necessary or appropriate to protect our rights or property, or the rights or property of any person or entity.
  • We may contract with various third parties for the provision and maintenance of the Website and App, Services and our business operations, and Spolu may need to share Your Personal Information and data generated by cookies and aggregate information (herein referred collectively as, “information“) with these vendors, service agencies and Service Partners. For example, We may provide Your information to a credit card processing company to process Your payment. The vendors and service agencies will not receive any right to use Your Personal Information beyond what is necessary to perform its obligations to provide the Services to You. If You complete a survey, Wealso may share Your information with the survey provider; if Weoffer a survey in conjunction with another entity, Wealso will disclose the results to that entity.
  • Your request for Services may be shared with third party websites / app with whom Wehave a contractual relationship in order to provide Your request with maximum exposure. The post on the third party website/app will include the details of Your request, including Your location, and other contact details. Interested bidders, however, will be able to click on Your request on such third party site, and will be directed to our Website and / or App, where they will have access to Your contact details (partial or complete), as would any other service provider or Service Partner on our Website and / or App interested in bidding on Your request.
  • If You are a Service Partner, the information that You post (other than Your payment information) is available to other Users of our Website and / or App and our third party service provider. Comments that Users post to our Website and / or App also will be available to other visitors to our Website/App, accordingly. In addition, We will post the results (in aggregate form) of surveys to our Website and / or App. If You are a consumer, name, and location, as well as the details of Your request, are available to all visitors to our Website/App. ServicePartners also will be permitted to see the Usersfull name, telephone number, email address and the location.
  • We will disclose Your Personal Information, including, without limitation, Your name, city, state, telephone number, email address, Users ID history, quoting and listing history, and fraud complaints, to law enforcement or other government officials if Weare required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of a governmental authority.
  • In the event that Spolu undergoes a change in control, including, without limitation, a merger or sale of all or substantially all of Spolu’s assets to which this Website and / or App relates or other corporate reorganization in which Spolu participates, and is thus merged with or acquired by a third party entity (a “Successor“), Spolu hereby reserves the right to transfer the information Wehave collected from the Users of the Website/App and/or Services to such Successor.
  • In addition, in the event of Spolu’s bankruptcy, reorganization, receivership, or assignment for the benefit of creditors, or the application or laws or equitable principles affecting creditors’ rights generally, Spolu may not be able to control how Your information is transferred, used, or treated and reserves the right to transfer the information Wehave collected from the Users of the Website and / or App and/or Services to non-affiliated third parties in such event.
  • We may share Your personal information with other Registered Users to whom You explicitly ask us to send Your information or if You explicitly consent to such disclosure upon receipt of a specific Service. For instance, when You contact for a specific Service with another Registered Users, Spolu will send that Registered User a notice that includes the personal information that You have chosen to allow Spolu to reveal to Users with whom You contract.

LINKS TO EXTERNAL WEBSITES

The Website and / or App may contain links to other websites/app or resources over which Spolu does not have any control. Such links do not constitute an endorsement by Spolu of those external websites/ mobile applications. You acknowledge that Spolu is providing these links to You only as a convenience, and further agree that Spolu is not responsible for the content of such external websites/app. Weare not responsible for the protection and privacy of any information which You provide while visiting such external websites and such sites are not governed by this Policy. Your use of any external website is subject to the terms of use and privacy policy located on the linked to external website.

UPDATING, DELETING AND CORRECTING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of Your personal information in the following ways:

  • You can review and correct Your personal information by logging into the Website/App and navigating to Your preferences page in “Edit Profile.”
  • You must promptly update Your personal information if it changes or is inaccurate. Typically, We will not manually alter Your personal information because it is very difficult to verify Your identity remotely. Nonetheless, upon Your request We will suspend Your Account and keep “invisible” Your personal information from view as soon as reasonably possible based on Your Account activity and in accordance with applicable law.
  • We do retain information from suspended accounts in order to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations of any Registered Users, enforce our Terms of Use, and take any other actions otherwise permitted by law that Wedeem necessary in our sole and absolute discretion.
  • You should understand, however, that once You publicly post a Service request, Offer, Want, Feedback, or any other information onto the Website/App, You may not be able to change or remove it. Once Wehave deleted or removed Your Account, You agree that Spolu shall not be responsible for any personal information that was not included within Your deleted and/or removed Account that remains on the Website and / or App.

WHAT CHOICES DO I HAVE REGARDING USE OF MY PERSONAL INFORMATION?

We may send periodic promotional or informational emails to You. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 15 (fifteen) business days for us to process opt-out requests. If You opt-out of receiving emails about recommendations or other information Wethink may interest You, We may still send You emails about Your Account or any Services You have requested or received from us.

THIRD-PARTY AD NETWORKS

We participate in third party ad networks that may display advertisements on other websites based on Your visits to our Website and / or App as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which You might be interested. Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to You. These third party cookies and other technologies are governed by each third party’s specific privacy policy, and not by Spolu’s Policy. We may provide these third-party advertisers with information about Your usage of our Site/App and our services, as well as aggregate or non-personally identifiable information about visitors to our Site and Users of our service.

YOUR FULL NAME AND USE OF SPOLU INFORMATION

As a Registered User or Registered Service Partner of the Website and / or App You will select a Full Name during the registration process. All of Your activities on the Website and / or App will be traceable to Your Full Name. Certain other people, including other Registered Users with whom You have transacted business via the Website and / or App, can see a large part of Your activity on the Website and / or App. If You book a Service with a Registered User, cancel a scheduled Service with a Registered User, receive an offer on Your posted Service from a Registered User, or have posted a Service, Spolu may send a notice to You or the appropriate Registered Users that includes Your Full Name. Thus, if You associate Your real name with Your Full Name, the people to whom You have revealed Your name may be able to personally identify Your Website and / or App activities.

The Website and / or App facilitate Your sharing of personal information with others in order to negotiate, provide, and use the Services. If You agree to contract for a service with another Registered Users, You may need to reveal Your name, email, phone number, or personal address to that individual so that the service may be performed. Please respect the privacy of others. You agree to use the information of other Users solely for the following purposes: (a) Spolu-transaction-related purposes; and (b) using Services offered through the Website and / or App.

Your password is the key to Your Account. When creating Your password You should use unique numbers, letters, special characters, and combinations thereof. In addition, DO NOT disclosesYour password to anyone. If You do share Your password or Your Personal Information or any other informationwith others, You are solely responsible for all actions taken via Your Account. If You lose control of Your password, You may lose substantial control over Your Personal Information and be subject to legally binding actions taken on Your behalf. Thus, IF YOUR PASSWORD HAS BEEN COMPROMISED FOR ANY REASON, YOU MUST IMMEDIATELY NOTIFY SPOLU TO CHANGE YOUR PASSWORD.

USERS GENERATED CONTENT

We invite You to post content on our Website and / or App, including Your comments, Feedback, pictures, and any other information that You would like to be available on our Website and / or App. If You post content to our Website and / or App, all of the information that You post will be available to all visitors to our Website and / or App. If You post Your own content on our Website and / or App or Services, Your posting may become public and Spolu cannot prevent such information from being used in a manner that may violate this Policy, the law, or Your personal privacy.

PRIVACY POLICY UPDATES

This Privacy Policy is current as of the effective date set forth above. Spolu may, in its sole and absolute discretion, change this policy from time to time by updating this document. Spolu will post its updated policy on the Website and / or App on this page. Spolu encourages you to review this policy regularly for any changes. Your continued use of this Website and / or App and/or continued provision of Personal Information to us will be subject to the terms of the then-current Privacy Policy.

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