Privacy Policy

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
(Information).

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.

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:

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.

10. We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. ALL INFORMATION GATHERED ON DVARA MONEY IS SECURELY STORED WITHIN DVARA MONEY CONTROLLED DATABASE. THE DATABASE IS STORED ON SERVERS SECURED BEHIND A FIREWALL; ACCESS TO THE SERVERS IS PASSWORD-PROTECTED AND IS STRICTLY LIMITED. HOWEVER, AS EFFECTIVE AS OUR SECURITY MEASURES ARE, NO SECURITY SYSTEM IS IMPENETRABLE. WE CANNOT GUARANTEE THE SECURITY OF OUR DATABASE, NOR CAN WE GUARANTEE THAT INFORMATION YOU SUPPLY WILL NOT BE INTERCEPTED WHILE BEING TRANSMITTED TO US OVER THE INTERNET. AND, ANY INFORMATION YOU INCLUDE IN A POSTING TO THE DISCUSSION AREAS IS AVAILABLE TO ANYONE WITH INTERNET ACCESS.

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]

For Personal Data related questions and grievances please contact
Name: Govindarajan Kadambi
CoFounder, Chief Product and Technology Officer
10th Flloor  IITM Research Park | No. 1 Kanagam Village, Taramani | Chennai – 600113

Phone: 044 6668 7000

Email: Govindarajan dot kadambi @ dvara dot com