1. No Disclosure of personally-identifiable information to third parties
SPA shall not intentionally disclose to third parties without your permission (and will take commercially reasonable steps to prevent the accidental disclosure of) any personally-identifiable information you may provide while visiting this website, subject to the following exceptions: (i) SPA may disclose your personally-identifiable information to third parties as required or permitted by applicable laws, rules or regulations; (ii) SPA may disclose your contact information in response to inquiries by bona-fide rights owners in connection with allegations of infringement of copyright or other proprietary rights arising from information you have submitted on this website or otherwise provided to SPA; and (iii) if SPA (and/or one or more of its affiliates) merges with or sells all or substantially all of its assets to a third party, information collected about you on this website may be disclosed to such third party.
SPA has implemented generally accepted standards of technology and operation security in order to protect personally-identifiable information from loss, misuse, alteration or destruction. Only authorized SPA personnel are provided access to personally-identifiable information, and such employees/persons are required to treat this information as confidential. Notwithstanding these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personally- identifiable information.
4. Minors/unsound mind
This website is not intentionally designed for or directed at persons less than 18 years of age or younger or unsound mind, and SPA will not intentionally collect or maintain information about anyone under the age of 18 year.
5. Privacy notice
SPA takes the protection of your privacy very seriously. We will only use your personal information to deliver the services you have requested from us, and to meet our legal and regulatory responsibilities.
a) How we obtain information from you?
We obtain information about you when you engage us to deliver our services and/or when you use our website, for example, when you contact us about our services.
b) What type of information do we obtain/collect from you?
The personal information we collect from you will vary depending on which services you engage us to deliver. The personal information we collect might include but not limited to, your full name address, telephone number, email address, your Director Identification Number, bank account details, your IP address, cookie information etc, which pages you may have visited on our website and when you accessed them.
c) How is your information used?
In general terms, and depending on which services you engage us to deliver, as part of providing our agreed services we may use your information to:
- contact you by post, email or telephone or message or other permitted mode
- verify your identity where this is required
- understand your needs and how they may be met
- maintain our records in accordance with applicable legal and regulatory obligations
- process financial transactionsv
- prevent and detect crime, fraud or corruption
- to send periodic emails on latest updates for the different areas
- for processing of invoices or payments
We are required by legislation, other regulatory requirements and our insurers etc to retain your data where we have ceased to act for you. The period of retention required varies with the applicable legislation. To ensure compliance with all such requirements it is the policy of the SPA to retain all data for a period of [eight] years from the end of the period concerned.
d) Who has access to your information?
- We will not sell or rent your information to third parties.
- We will not share your information with third parties for marketing purposes without taking explicit consent from you.
- Any staff with access to your information has a duty of confidentiality under the ethical standards that SPA is required to follow.
- However, we may share information under legal and regulatory compliance purposes with authorities.
e) Third Party Service Providers working on our behalf
We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary and legitimate to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes.
Please be assured that we will not release your information to third parties unless you have requested that we do so, or we are required to do so by law or regulation for example, by a court order or for the purposes of prevention and detection of crime, fraud or corruption etc.
f) How you can access and update your information
Keeping your information up to date and accurate is important to us. We commit to regularly review and correct where necessary, the information that we hold about you. If any of your information changes, please email or write to us, or call us using the ‘Contact information’ noted below. You have the right to ask for a copy of the information the Company holds about you.
g) Security precautions in place to protect the loss, misuse or alteration of your information.
Whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given, or where you have chosen, a password which enables you to access information, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Your data will usually be processed in our offices in India. However, to allow us to operate efficient digital processes, we may sometimes need to store information in servers located/to be located outside India at any point of time. We take the security of your data seriously and so all our systems have appropriate security in place that complies with all applicable legislative and regulatory requirements.
h) Your choices
We may occasionally contact you by permitted mode such as [post / email / telephone/message] with details of any changes in legal and regulatory requirements or other developments that may be relevant to your affairs and, where applicable, how we may assist you further. If you do not wish to receive such information from us, please let us know by contacting us as indicated under ‘Contact information’ below.
i) Your rights
- Access to your information: You have the right to request a copy of the personal information about you that we hold.
- Correcting your information: We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards
- Deletion of your information: You have the right to ask us to delete personal
information about you where:
- you consider that we no longer require the information for the purposes for which it was obtained
- you have validly objected to our use of your personal information - see Objecting to how we may use your information’ below
- our use of your personal information is contrary to law or our other legal obligations
- We are using your information with your consent and you have withdrawn your consent - see ‘withdrawing consent to use your information’ below.
However, the data shall be retained as per the legal and regulatory requirement for meeting the statutory, legal and regulatory requirement.
j) Restricting how we may use your information:
In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where there is no longer a basis for using your personal information but you do not want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
k) Objecting to how we may use your information:
Where we use your personal information to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.
l) Withdrawing consent to use your information:
Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given. Please contact us in any of the ways set out in ‘Contact information’ below if you wish to exercise any of these rights.
m) Changes to our privacy notice
We keep this privacy notice under regular review. This privacy notice was last updated on October 2021.
For any queries or complaints about how we handle your personal information contact us at– firstname.lastname@example.org
6. Cookies policy
A cookie is a small piece of data or message that is sent from an organisation's web server to your web browser and is then stored on your hard drive. Cookies can't read data off your hard drive or cookie files created by other sites, and do not damage your system.