This document is an electronic record in terms of (i) Information Technology Act, 2000; (ii) the rules framed there under as applicable; and (iii) the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.
“Personal Information” is defined under the SPI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such a natural person.
The SPI Rules further define “sensitive personal data or information” of a person to mean personal information about that person relating to:
- financial information such as bank accounts, credit and debit card details or other payment instrument details;
- physical, physiological and mental health condition;
- sexual orientation;
- medical records and history;
- biometric information;
- information received by body corporate under lawful contract or otherwise;
- visitor details as provided at the time of registration or thereafter; and
- call data records.
- WHAT INFORMATION SPSL COLLECTS FROM YOU
SPSL may collect two (2) types of information about you: Personal and Non-Personal.
- Personal Information
Personal Information refers to information that lets SPSL know the specifics of who you are and which may be used to identify, contact or locate you (e.g. name, age, gender, mailing address, telephone number and e-mail address). SPSL may collect Personal Information when you use the Platform including, without limitation, setting up account information, filling out surveys, corresponding with SPSL, or otherwise volunteering information about yourself.
- Non-personal Information
Non-Personal Information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or online visitations). SPSL may collect Non-Personal Information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.
- HOW SPSL COLLECTS YOUR INFORMATION
The Personal Information practices set forth apply to all SPSL’s customers worldwide.
- Information Provided By The User
Failure to provide all required information required by SPSL may prevent access to any or all SPSL Platform, and failure to maintain accurate information may result in suspension or termination of access to any or all SPSL Platform.
- Information Collected Through Technology
While you are able to visit the Platform and remain anonymous, SPSL or its third party service providers may still collect Non-Personal Information about your use of the SPSL Platform (e.g. your Internet browser, operating system, IP address, connection speed, and the domain name of your Internet service provider). Such information may be gathered by the following methods:
- Cookies: Cookies, including local shared objects, are small pieces of information that are stored by your browser on your computer’s hard drive which work by assigning to your system a unique number that has no meaning outside of the SPSL Platform. Cookies do not generally contain any Personal Information. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. Not accepting cookies may make certain features of the SPSL Platform unavailable to you.
- IP Address: You may visit many areas of the SPSL Platform anonymously without the need to become a registered User. Even in such cases, SPSL may collect IP addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin Services with an Internet services provider. Each time you access the Platform and each time you request one of SPSL’s pages, the server logs your IP address.
- Web Beacons. Web beacons are small pieces of data that are embedded in web pages and e-mails. SPSL may use these technical methods in HTML e-mails that SPSL sends to Users to determine whether they have opened those e-mails and/or clicked on links in those e-mails. The information from use of these technical methods may be collected in a form that is Personal Information.
- HOW SPSL USES YOUR INFORMATION
- SPSL uses the information that you provide or that we collect to operate, maintain, enhance, and provide all of the features and services found on the Platform as well as to track user-generated content and Users to the extent necessary to comply as a service provider.
- System Administration
SPSL may use Non-Personal Information for the purposes of system administration, assisting in diagnosing problems with SPSL servers, monitoring SPSL’s system performance and traffic on the Platform and to gather broad demographic information about SPSL customers.
- Notices to Registered Users
If you have registered for an Account, SPSL may use your Personal Information to send e-mails or text messages regarding your registration, including confirmation to verify the accuracy of any information you have provided, and instructions on how to avail the services. SPSL may also send you e-mails to verify your identity or to notify you if SPSL believes your use of SPSL Platform violates any applicable agreement for the use of the SPSL Platform.
- Contact Information
If you contact SPSL by telephone, e-mail or letter, SPSL may keep a record of your contact information and correspondence. If you report a problem with the SPSL Platform, SPSL may collect this information in a file specific to you. You may contact SPSL at [*] to request the removal of this information from Fusion Web Work’s database.
- HOW TO ACCESS AND CHANGE YOUR PERSONAL INFORMATION
- Upon request, SPSL shall allow Users to update or correct Personal Information previously submitted, but only to the extent such activities will not compromise privacy or security interests. Additionally, upon request, SPSL shall delete Personal Information from the database where such information is stored; however, it may be impossible to entirely delete a User’s entry without some residual information being retained due to the manner in which data backups are maintained. Requests to delete Personal Information shall be submitted to [email protected]
To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.
- DISCLOSURE OF INFORMATION TO THIRD PARTIES
5.1. SPSL does not sell, trade or rent Personal Information collected through the SPSL Platform to any third party. Notwithstanding the foregoing, SPSL shall: (1) fully cooperate with law enforcement agencies; and (2) may be required to disclose Personal Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation.
- SAFEGUARDING YOUR PERSONAL INFORMATION
- Security Measures
SPSL takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of Personal Information. These include, but are not limited to, internal reviews of: (a) SPSL’s data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where SPSL stores Personal Information. All SPSL employees, contractors and agents who access Personal Information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of Personal Information.
- Third Party Links
The SPSL Platform may contain links to third parties who may collect Personal Information and Non-Personal Information directly from you. Additionally, SPSL may use third parties to provide components of the SPSL Platform. In either case, such third parties may have separate privacy policies and data collection practices, independent of SPSL. SPSL: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such websites; and (c) does not make any warranties or representations about the contents, products or services offered on such websites or the security of any information you provide to them.
- CHILDREN UNDER 18 YEARS OF AGE
- Use of the SPSL Platform is not intended for minors under the age of 18 (“Minors”). Minors are not authorized by SPSL to use the SPSL Platform, even if Minors set up an Account or accept the terms of any agreement for SPSL Platform. Parents or guardians may authorize Minors between the ages of 12 and 17 to use the SPSL Platform, provided they assume all responsibility and legal liability for the conduct of such Minor including, without limitation, monitoring the Minor’s access and use of the SPSL Platform. SPSL does not intentionally collect nor maintain any personally identifiable information from Minors. If you discover your Minor child has submitted his/her information to SPSL, you may request to have such information deleted from SPSL’s database by sending an e-mail request to [email protected] together with the e-mail address that was submitted by the Minor. Upon receiving the request, SPSL shall delete such information within 7 business days.