1. INFORMATION WE COLLECT
- Information You Give to Us: Information that is necessary for the use of the Spunky Platform. We ask for and collect the following personal information about you when you use the Spunky Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
- Account Information: When you sign up for a Spunky Account, we require certain information such as your first name, last name, and email address. To use certain features of the Spunky Platform, we may ask you to provide additional information, which may include your address, and phone number
- Payment Information: To use certain features of the Spunky Platform (such as to purchase the products and/or services on Spunky Platform), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments via the payment gateway.
- Communications with Spunky: When you communicate with Spunky or use the Spunky Platform to communicate with us, we collect information about your communication and any information you choose to provide.
- Information you choose to give us: You may choose to provide us with additional personal information in order to obtain a better user experience when using Spunky Platform. This additional information will be processed based on your consent.
- Other Information: You may otherwise choose to provide us information when you fill in a form, conduct a search, respond to surveys, post to community forums, participate in promotions, or use other features of the Spunky Platform (if available and applicable).
- Information We Automatically Collect from Your Use of the Spunky Platform: When you use the Spunky Platform, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Spunky Platform.
- Geo-location Information: When you use certain features of the Spunky Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Spunky may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
- Usage Information: We collect information about your interactions with the Spunky Platform such as the pages or content you view, your searches for Spunky Platform and the services that are provided, and other actions on the Spunky Platform.
- Log Data and Device Information: We automatically collect log data and device information when you access and use the Spunky Platform, even if you have not created a Spunky Account or logged in. That information includes, among other things: details about how you’ve used the Spunky Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Spunky Platform.
- Information We Collect from Third Parties: Spunky may collect information, including personal information, that others provide about you when they use the Spunky Platform or reach the Spunky Platform through a third-party, or obtain information from other sources and combine that with information we collect through the Spunky Platform. We do not control, supervise or are responsible for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
- Other Sources: To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. We may receive information about you and your activities on and off the Spunky Platform through partnerships, or about your experiences and interactions from our partner ad networks.
- Information we receive from other accounts or sources: we can receive information about you from other sources, such as from your other accounts (like when you use your Apple ID to sign in on our website) or other websites, including data brokers, our Partners, social media providers like Facebook and Twitter, advertising networks and analytics partners, and payment and delivery service providers.
2. HOW WE USE INFORMATION WE COLLECT:
- We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Spunky Platform, create and maintain a trusted and safer environment and comply with our legal obligations and enable you to access and use the Spunky Platform.
- We may use the information to operate, protect, improve, and optimize the Spunky Platform and experience, such as by performing analytics and conducting research.
- Provide customer service. Send you service or support messages, updates, security alerts, and account notifications.
- If you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, (iv)to facilitate delivery of the product and/or services purchased by you; and (v) for any purpose you authorize at the time of collection.
- Create and Maintain a Trusted and Safer Environment.
- Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Verify or authenticate information or identifications provided by you.
- Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required.
- Comply with our legal obligations.
- Enforce our Terms of Service and other policies.
- We process this information given our legitimate interest in protecting the Sitch Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
- We may use the information shared by you to send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Spunky or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google).
- We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.
3. SHARING AND DISCLOSURE:
- With Your Consent: Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Spunky Account or when you participate in promotional activities conducted by Spunky partners or third parties.
- Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights: Spunky may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Spunky, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, or (v) to protect the rights, property or personal safety of Spunky, its employees, its affiliates, directors or members of the public at large.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Spunky Platform secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.
Where appropriate, we may notify you about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Spunky’s Property and the Spunky Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that guest about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
- Social Media Platforms: Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Spunky Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. The social media platforms with which we may share your personal data are not controlled or supervised by S Spunky. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.
Please note that you may, at any time ask Spunky to cease processing your data for these direct marketing purposes by sending an e-mail to firstname.lastname@example.org
4. OTHER IMPORTANT INFORMATION
- Analyzing your Communications: We may review, scan, or analyze your communications on the Spunky Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
5. THIRD PARTY PARTNERS & INTEGRATIONS
The Spunky Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Spunky doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Spunky, or both. These Third Party Partners will have their own policies for use, protection and disclosure of personal information. We encourage you to review the privacy policies of the other websites you visit.
6. YOUR RIGHTS
- You are responsible for keeping your personal information up-to-date: You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
- In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us: We generally retain your personal information forever in order to comply with our legal obligations. If you no longer want us to use your information to provide the Sitch Platform to you, you can request that we erase your personal information. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests;
- We may retain and use your personal information to the extent necessary to comply with our legal obligations;
- Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible.
- Withdrawing Consent and Restriction of Processing: Where you have provided your consent to the processing of your personal information by Spunky you may withdraw your consent by sending an e-mail to xxx. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
- We do not sell your personal information for processing by direct marketing agencies: We may however use your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Spunky will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
7. DATA PROTECTION AND SECURITY:
- Spunky uses systems as prescribed under the applicable Indian Laws in order to protect the personal information shared by you. All necessary means have been employed to ensure that your personal information remains protected.
- We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Spunky credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of the information shared by you with Spunky, please contact us.
9. CONTACT US