Welcome to Spark Money App: the Platform of Dvara Money Private Limited (“Dvara Money/ We”), a company incorporated in India under the Companies Act, 2013 with its registered office situated at 10th Floor, IIT Madras Research Park, Kanagam Village, Taramani, Chennai.

Dvara Money owns, develops, manages and operates its Website and associated Mobile Applications which offers its Users (“You” or “Yours” or “End User”) access and use of the Platform which includes the opportunity to avail the Services offered on/ through the Platform.

This DM Privacy Policy is a part of the DM T&C dvara-money-terms-conditions.pdf (dvaramoney.com) applicable to Services provided by/ facilitated by Dvara Money, either directly or indirectly through DM’s authorised Service Provides, Facilitators and or third-party service providers to You.

All terms defined in the DM T&C have the same meaning used here in this DM Privacy Policy. This DM Privacy Policy statement shall apply to all Users who visit, access and or use Dvara Money’s Platform and/ or avail Services either directly or via the DM Platform. The Users unconditionally agree that browsing the Platform and/or availing the Services signifies their complete assent and acceptance to this DM Privacy Policy. We respect the privacy of Our Users and is committed to protecting it in all respects. Any dispute with Dvara Money over privacy matters are subject to this DM Privacy Policy read in conjunction with the DM T&C and the Consent Form.

1. This Privacy Policy is published in compliance/reference of:

i. Section 43A of the Information Technology Act, 2000; and
ii. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”) “Personal Information” and “Sensitive personal data or information” shall be as defined under the SPI Rules.
The information about the Users as collected by Dvara Money is:
a. information supplied by Users and
b. information automatically tracked while navigation and or use of the DM Platform

2. Spark Account:

a. In order to use the Platform and avail the Services, Users will have to register on the Platform and create an individual account with a unique user identity using their mobile number and one time password (“OTP”) that is generated upon onboarding and, subsequently thereafter each time he/ she logs in (“Spark Account”). Pursuant to this, for availing the Services, You explicitly agree to provide for the access, sharing, transmission and or storage of Your information (as mentioned below) with Us, the Facilitators and or the Service Partners and or any third-party service providers, to the extent required for the provision and or facilitation of Services as availed by You either directly from Us or from the Service Partners, Facilitators and or any third-party service providers through Us.
b. You further agree that You are providing specific consent by reading, understanding and accepting the DM T&C, DM Privacy Policy herein and the Consent Form.

Untitled Document


Type of Data

Purpose for collection

Period of retention by DM

Savings Account

  1. Full name
  2. Mobile number
  3. Father’s name
  4. Mother’s name
  5. Date of Birth
  6. Email address
  7. Gender
  8. Permanent and Communication address
  9. Marital status
  10. Full name as on Your PAN Card
  11. Image of PAN card
  12. Self-photograph
  13. Employment status
  14. Occupation
  15. Employment Type / Status
  16. Income
  17. Photograph as contained in Your
  18. Aadhar card


The following particulars relating to Your nominee for the Savings Account opened by You vide the Platform:

  1. Full name
  2. Relationship to You
  3. Date of Birth
  4. Email address
  5. Address
  6. City
  7. State
  8. Pin Code
  9. Guardian


This is required for the creation of the Savings Account (including the KYC process) in partnership with Partner Bank.

All information/ details except Aadhar and PAN are retained until the Savings Account is maintained with the Partner Bank through the Platform.

Further, basic details (which may include person identifiable sensitive information) of the Users are retained for a further period of two (2) years post deletion of the Savings Account as per internal policy of DM.

Aadhar and PAN shall be deleted immediately upon successful KYC verification of the User/ sharing the same with Partner Bank, whichever is later.

Prepaid Instrument (“PPI”)

  1. Full name
  2. Mobile number
  3. Father’s name
  4. Mother’s name
  5. Date of Birth
  6. Email address
  7. Gender
  8. Permanent and Communication address
  9. Marital status
  10. Employment status
  11. Occupation
  12. Employment Type / Status
  13. Income
  14. Aadhar Card

This is required for facilitating issuance of PPI card.

In the event the User avails an PPI in conjunction with the Savings Account, retention of Data shall be as per the Savings Account policy as mentioned above.
In the event the Users avail the PPI as a standalone, the collected information shall be stored until the User holds the PPI. Pursuant to the deactivation of the PPI, DM shall retain basic information of the User for a period of two (2) years, post Service availment as per DM internal policy.
It is pertinent to note that Aadhar shall be deleted immediately upon sharing the same with Fino.

ITR Services

  1. Name
  2. Contact number
  3. City
  4. State
  5. Company details
  6. Pan number
  7. Pan photocopy
  8. Bank details- A/C number and IFSC code
  9. Communication Address
  10. IT login password
  11. Form 16 for salaried Users

This is required for the filing of ITR returns of the User.

Shall be retained until ITR Service is provided to the User (which shall include each consequent ITR Service being availed).

Further, basic details of the User (which may include person identifiable sensitive information) shall be retained for a further period of two (2) years, post Service availment as per the internal policy of DM.


This shall be an add-on service offered to the User upon availment of Savings Account. Hence, the existing information with DM (as mentioned in Savings Account above) shall be used for the same.

This is required for the facilitation of digital gold accumulation in partnership with a Digital Gold Partner.

Information used for facilitation of digital gold shall be retained until the User maintains the Savings Account or maintains digital gold balance, or as per statutory requirements whichever is later.


  1. Name
  2. Address
  3. Aadhar Number
  4. Communication Address
  5. Email
  6. Name
  7. Date of birth
  8. Gender
  9. Language
  10. Mobile Number
  11. Nominee Name
  12. Nominee DOB
  13. Nominee Relation
  14. PAN number

This is required for the facilitation of Insurance from the Insurance Partner.

Shall be retained until the User holds the insurance of the Insurance Partner or as per statutory / audit requirements.

It is clarified that other than the Facilitators mentioned in the above table, few information/ data of the User shall be shared/ accessed by other Facilitators / Service Providers / Partners or any third-party service providers as the case may so require, as well for the provision of/ facilitation of Services to the Users.

Retention of User information and or any data maybe extended in addition to the specifications stated above, in line with meeting necessary statutory, legal and or audit requirements depending on the Services being availed by the User.

b. In addition to the above, the User acknowledges that the below data/ information shall be captured and stored by DM or permissions (as mentioned below) shall be sought upon access/ usage of DM Platform in availing the Services:

Untitled Document


Type of Data provided by You

Additional Details

Retention Period

Data/ Information

The following details in relation to Your device shall be collected at the time of Your use and Access of the DM Platform and/or Services:

  1. IP address
  2. Mobile name and model
  3. Android version 
  4. Android id
  5. Manufacturer 
  6. Location

Automatic collection of Data upon Your access/use of the DM Platform.

Shall be retained until the Services are availed through the DM Platform.




To take picture of documents, proof and KYC documents



File Storage

To upload picture of documents, proof and KYC documents from User's phone

Location Permission

To enhance User support by displaying nearby Spark Dost centres, Dvara Money will only retrieve location details when the Platform is actively in use. In this connection, Dvara Money ensures that location information is not fetched in the background.

c. Notwithstanding anything contained herein, Dvara Money’s retention of User information and or any data maybe extended in addition to the specifications stated above, in line with meeting necessary statutory, legal and or audit requirements depending on the Services being availed by the User.

d. It is pertinent to note that few of the above requested information are personally identifiable and can be classified as ‘Sensitive Personal Information’ under Regulation 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”). However, these ‘Sensitive Personal Data’ are not stored by Dvara Money (except PAN for the provision of ITR Services) and are shared with Our Service Partners including RBI regulated Partner Bank for the creation of Savings Account and/ provision of other Services.

3. Withdrawal of consent and Deletion Request:

Withdrawal of consent:

a. If the User wants to withdraw the consent given earlier for use, storage and sharing of the Limited Information (provided for all Services except PPI) and desires for the same to be deleted, the User shall send in a request for such withdrawal byclicking on the ‘delete my data’ option available in the ‘account details’ section of the Platform and feed in the OTP generated to his/ her registered mobile number. In case of Limited Information pertaining to PPI, You have to place a request for deletion with the Spark Dost agent. (“Deletion Request”) Upon 30 (thirty) days from the Deletion Request, Dvara Money shall delete the Limited Information pertaining to the User. Provided however, if required by regulatory, audit, legal and or statutory requirements, We will have the right to keep a copy of Your data/information provided by You for such statutory, audit, legal and
or regulatory purposes, as the case may so require.

b. In the event of such a Deletion Request, Dvara Money shall have the option to not provide the Services and/ or temporarily suspend its Services provided/ facilitated to You, at any given point in time.

c. For the avoidance of doubt, it is clarified that in case of withdrawal of consent and Deletion Request with respect to the data/ information collected for Services facilitated by Dvara Money, such withdrawal and Deletion Request shall not have an automatic effect of withdrawal/ deletion of data/information stored at the Facilitators and Service Partner’s end. In connection with this, the User will have to take the steps as mentioned in such Facilitators and Service Partner’s terms and conditions.

4. All required information is service dependent and Dvara Money may use the above said User information to, maintain, protect, and improve the Services (including advertising and or marketing services) and for developing new services. Such information will not be considered as sensitive if it is freely available and accessible in the public domain or is furnished under the Right to Information Act, 2005, any rules made there under or any other law for the time being in force. The primary
reason for gathering information is to improve Our products, deals, services, website content and navigation.

5. To improve the responsiveness and user interface for Our Users, Dvara Money may use “cookies”, or similar electronic tools to collect information to assign each User a unique, random number as a User Identification (User ID) to understand the User’s individual interests using the identified computer. Unless You voluntarily identify Yourself, Dvara Money cannot know who You are, even if We assign a cookie to Your computer. The only Personal Information a cookie can contain is information You supply. A cookie cannot read data off Your hard drive. Our advertisers may also assign their own cookies to Your browser (if You click on their ads), a process that We do not control. We receive and store certain types of information whenever You interact with Us via Website,
Mobile Application or service though your computer/laptop/netbook or mobile/tablet/pad/handheld device etc.

6. We may receive information about You from other sources, add it to database in relation to You and treat it in accordance with this DM Privacy Policy. If You provide information to the platform provider or other partner, whom We provide Services, Your account information and order information may be passed on to Us. We may obtain updated contact information from third parties in order to correct our records and fulfil the Services or to communicate with You.

7. The Platform may include links to other websites or mobile applications. Such websites or mobile applications are governed by their respective privacy policies, which are beyond our control. Once You leave Our servers (You can tell where You are by checking the URL in the location bar on Your browser), use of any information You provide is governed by the privacy policy of the operator of the mobile application, You are visiting. That policy may differ from Ours. If You can’t find the privacy policy of any of these sites via a link from the mobile application’s homepage, You should contact the mobile application or website owners directly for more information. When We present
information to Our advertisers — to help them understand Our audience and confirm the value of advertising on the Platform, it is usually in the form of aggregated statistics on traffic to various pages / content within the Platform. We use third party advertising/marketing companies to serve ads when You visit the Platform. These companies may use information (not including Your name, address, email address or telephone number or other personally identifiable information) about Your visits to this and other websites or mobile application, in order to provide advertisements about goods and services of interest to You. We do not provide any Personally Information to third party websites/
advertisers/ ad-servers without Your consent, except in the circumstance mentioned in below clause.

8. We take utmost care of our user’s Personal Information and/or Sensitive Personal information and We share User’s personal information with the Service Partners, Facilitators, Our employees and third-party facilities providers on strictly on a “need to know” basis hence we take all such steps to ensure that electronic records are valid under the Information Technology Act, 2000 as amended from time to time and notifications and rules framed thereunder.

9. Dvara Money may share the sensitive Personal Information to any third parties without obtaining the prior consent of the User in the following limited circumstances:

i. When it is requested or required by Law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences.

ii. Dvara Money proposes to share such information within its group companies, auditors, consultants officers and employees of such group companies and/or Service Partners, Facilitators and/ or thirdparty service provider for the purpose of processing Personal Information on its behalf.

iii. Dvara Money may use third-party advertising companies and/or within group companies to serve ads when the User’s visits the Platform . These companies may use Personal Information about the User’s visit to the Platform and other websites in order to provide advertisements about goods and services of interest to the User.

iv. Dvara Money shall transfer information about the User in case Dvara Money is acquired by or merged with another Dvara Money.

v. Dvara Money may share the Personal Information with the Service Partners, Facilitators and such other third-parties on a need-to-know basis in case the User shows interest in availing the Services.


11. Grievance Redressal
In the event of any complaints, abuse or concerns with regards to content and or comment or breach of these terms, you may reach out to Dvara Money’s representative below at any time between 10.00 am and 6.00 pm Monday to Friday except public holidays.

i. Grievance Redressal Officer
Users are requested to address all their grievances at the first instance to the Grievance Redressal Officer. The contact details of the Grievance Redressal Officer are as provided below:
Name: Chandan A
Address: 10th Floor-Phase, IIT-Madras Research Park Kanagam Village, Taramani, Chennai 600113
Contact number: 080 370 77275
Email ID: [email protected]

ii. Nodal Officer
If the User does not receive a response from the Grievance Redressal Officer within 15 days of making a representation, or if the User is not satisfied with the response received from the Grievance Redressal Officer, the User may reach the Nodal Officer on the toll-free number below anytime between 10:00am and 6:00 pm on weekdays except public holidays or write to the Nodal Officer at the e-mail address below.
The contact details of Our Nodal Officer are provided below:

Name: Sachin Immanuel
Address: 10th Floor-Phase, IIT-Madras Research Park Kanagam Village, Taramani, Chennai 600113
Contact number: 080 470 91556
Email ID: [email protected]