Privacy Policy

1. Introduction

Spindigo respects the privacy of individuals who access or use the Platform. This Privacy Policy describes the manner in which information is collected, used, stored, processed and disclosed in connection with the use of the Platform.

The Platform is designed to enable registered users to digitally store, organise, manage, retrieve and maintain a catalogue of professional or business-related contacts and connections ("Connections") for their own internal reference and networking purposes.

This Privacy Policy applies to all individuals who access or use the Platform, including registered users and visitors ("You", "Your" or "User").

2. Definitions

For the purposes of this Privacy Policy, unless the context otherwise requires:

• "Personal Information" means any information that identifies or relates to an identifiable individual, including name, phone number, email address, photograph, business details or similar identifiers.
• "User Data" means information provided by a User at the time of registration or use of the Platform, including account credentials and profile-related information.
• "Connection Data" means contact information, business details or other information relating to third parties that a User voluntarily uploads, stores or manages on the Platform as part of their Connections.
• "Applicable Laws" shall include all laws, rules, regulations, guidelines and governmental directions in force in India, including the Information Technology Act, 2000 and rules framed thereunder.

3. Consent

By accessing or using the Platform, You expressly consent to the collection, storage, use and processing of Your information in accordance with this Privacy Policy.

You acknowledge that all information provided by You is provided voluntarily and at Your sole discretion. Spindigo shall not be responsible for the accuracy, completeness or authenticity of the information provided by You.

You may choose not to provide certain information or withdraw consent; however, such refusal or withdrawal may restrict Your ability to access or use certain features of the Platform.

4. Nature of Information Collected

4.1 User Account Information

Spindigo may collect Personal Information directly from You at the time of registration or use of the Platform, including Your name, phone number, email address, profile picture, profile details and business-related identifiers, for the purpose of creating and maintaining Your user account.

4.2 Connection Data Uploaded by Users

The Platform allows Users to upload, store and manage contact information of third parties as Connections. Such Connection Data may include names, phone numbers, email addresses, photographs, business names or related professional details. Spindigo does not independently collect, verify, access, monitor, use or control Connection Data uploaded by Users. Connection Data is stored solely to enable the User's personal contact management functionality on the Platform.

4.3 Technical and Usage Information

Spindigo may automatically collect certain technical and usage-related information, including IP address, device identifiers, browser type, operating system, access timestamps and usage patterns, for security, analytics and performance optimisation purposes.

5. Purpose of Collection and Use of Information

Spindigo collects and processes information solely for the following purposes:

• to enable registration, authentication and secure access to the Platform;
• to provide Users with functionality to store, manage, search, filter and retrieve their Connections;
• to maintain Platform security, integrity and performance;
• to communicate with Users regarding Platform-related updates or support;
• to retain system logs and traffic data for security monitoring, fraud detection, and breach response;
• to comply with Applicable Laws and enforce Spindigo's legal rights.

Spindigo does not use User Data or Connection Data for advertising, profiling, marketing, solicitation or commercial exploitation.

6. No Access to Connection Data

For the avoidance of doubt:

• Spindigo does not access, read, view, analyse or monitor Connection Data uploaded or stored by Users;
• Connection Data remains accessible only to the User who has uploaded such data;
• Spindigo does not share Connection Data with any third party.

Connection Data is stored using reasonable security safeguards, including encryption and access controls, to prevent unauthorised access.

7. User Responsibility for Third-Party Data

You acknowledge and agree that:

• You are solely responsible for ensuring that You have obtained all necessary consents, permissions and authorisations from third parties whose information is uploaded or stored as Connection Data;
• Spindigo does not determine the purpose of collection of Connection Data;
• Spindigo shall not be liable for any claims, disputes or liabilities arising out of the collection, storage or use of Connection Data by You.

8. Data Security

Spindigo implements reasonable security practices and procedures, consistent with Applicable Laws, to protect information from unauthorised access, loss or misuse.

Information may be stored on secure servers or cloud infrastructure operated by third-party service providers engaged by Spindigo, subject to contractual confidentiality and security obligations.

While reasonable safeguards are implemented, no system is entirely secure, and Spindigo does not guarantee absolute security of information.

In the event of a data breach, including any unauthorised access, disclosure, sharing, use, alteration, destruction of any data or information on the Platform, Spindigo shall:

• Notify affected Users of the nature, extent, timing and consequences of the breach promptly;
• Report the breach to the Data Protection Board of India, within seventy-two hours of becoming aware of such breach.

9. Disclosures

Spindigo does not sell, rent, trade or otherwise commercially exploit any Personal Information or User Data or Connection Data.

Spindigo may disclose limited information only in the following circumstances and strictly in accordance with Applicable Laws:

9.1 Legal and Regulatory Requirements

Spindigo may disclose information if required to do so by law, regulation, court order, governmental authority or legal process, or where such disclosure is necessary to enforce Spindigo's legal rights, investigate violations, or protect the rights, property or safety of Spindigo, Users or the public.

9.2 Service Providers

Spindigo may engage third-party service providers for hosting, cloud storage, analytics, security or technical support. Such service providers may have limited access to information strictly for the purpose of providing such services and are bound by confidentiality and data protection obligations consistent with this Privacy Policy.

9.3 Business Transfers

In the event of any merger, acquisition, restructuring, sale of assets or transfer of business, Spindigo may transfer information to the successor entity, subject to such entity continuing to comply with this Privacy Policy or a substantially similar privacy framework.

10. Data Retention

Spindigo retains Personal Information and User Data for no longer than is necessary for the specified purpose for which it was collected, including account maintenance, platform functionality, compliance under Applicable Laws.

Connection Data uploaded by Users shall be retained only for so long as the User maintains an active account on the Platform or until such data is deleted by the User.

Spindigo may retain certain information for longer periods where required under Applicable Laws, or to enforce legal rights, even after account deletion.

Upon termination or deletion of a User account, information may remain in backup systems for a limited duration, subject to secure deletion practices.

11. Cookies and Similar Technologies

The Platform may use cookies or similar technologies to enhance functionality, improve user experience, analyse usage trends and maintain security.

Cookies do not collect sensitive Personal Information or User Data or Connection Data. Users may control or disable cookies through their device or browser settings; however, doing so may impact certain Platform features.

Spindigo does not use cookies for behavioural advertising or cross-platform tracking.

12. User Rights

Subject to Applicable Laws, You may request access to, correction or deletion of Your User Data by contacting the grievance officer as mentioned below.

Spindigo may require verification of identity before processing such requests and may refuse or limit requests where permitted under Applicable Laws.

You also have the right to submit any grievance regarding the processing of Your User Data by Spindigo. If Your grievance is not resolved within the prescribed period in the Applicable Laws, you may approach the Data Protection Board of India.

You have the right to withdraw consent for any processing purpose at any time, by reaching out to the grievance officer as mentioned below.

Requests relating to Connection Data must be addressed by the User directly through the Platform's functionality.

13. Third-Party Links

The Platform may contain links to third-party websites, applications or services. Spindigo does not control and is not responsible for the privacy practices, content or security of such third-party platforms.

Access to third-party platforms shall be governed by their respective terms and privacy policies, and Spindigo shall not be liable for any loss or damage arising therefrom.

14. Changes to This Privacy Policy

Spindigo reserves the right to amend or update this Privacy Policy at any time at its sole discretion.

Where any amendment involves a change to the purposes for which Your Personal Information is processed, or any other material change to Your rights or Spindigo's obligations, Spindigo shall notify You of such change and shall obtain Your fresh consent before such change takes effect.

For non-material amendments (such as corrections of typographical errors, formatting updates or administrative changes), Spindigo shall provide notice of the update on the Platform, and continued use of the Platform after such notice shall constitute acceptance of such non-material changes.

Users are encouraged to periodically review this Privacy Policy.

15. Grievance Redressal Mechanism

In accordance with Applicable Laws, Spindigo has designated a grievance officer to address concerns or complaints relating to this Privacy Policy:

Spindigo shall endeavour to acknowledge and resolve grievances within the timelines prescribed under Applicable Laws.