This page is used to inform visitors regarding our policies with the collection, use, and disclosure of Personal Information if anyone decides to use our Service.

If you choose to use our services, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.

All visitors who use or access the mobile application and/or the website operated by Dvara Money Private Limited are covered under this Privacy Policy (“Policy”). In addition to this Policy, you will also be governed by the Terms and Conditions (“Terms“) accessible on the mobile and web application Spark App and/or the website (the mobile and web application and the website collectively referred to as the “Platform”). This Privacy Policy is a part of the Terms and Conditions [Terms and Conditions] to services provided by Company on Website and/or Mobile App. Use of the Platform and/or our services is available only to Persons who can enter into legally binding contracts under the Indian Contract Act, 1872 and to Persons resident in India. Persons who are “incompetent to contract” within the meaning of the Indian Contract Act, 1872 including minors, un-discharged insolvents and persons of unsound mind are not eligible to use the Platform or the services. However, in the event any Person under the age of 18 years wishes to use the Platform or if a Person wishes to use the Platform for and on behalf of a minor, then the following shall apply: (i) The Parent/Guardian hereby undertakes that the use of the Platform and/or our services shall at all times be for the benefit of the minor and we shall honour any transactions / instructions on the assumption that the same are being carried out / provided by the Parent/Guardian for the benefit of the minor without independent verification thereof; (ii) the Parent/Guardian shall indemnify the Company against any and all claims/losses arising on account of use of the Platform and/or services for and on behalf of the minor.

Dvara Money Private Limited (hereinafter shall be referred to as “Company”, “We”, “Us”, “Our” and terms of similar meaning) owns and operates the Platform and provides services vide the Platform.

By accessing the Platform or otherwise using the Platform, you (hereinafter referred to as “You”, “Your”, “User” as applicable) expressly consent to Our collection, storage, use and disclosure of the Information (as defined hereunder) in accordance with the terms of this Policy.

1. Fundamentals of the Policy

We have designed this Policy keeping in mind certain fundamental principles to protect and preserve the integrity of the Information shared by the User including:

  1. Managerial, organisational, business practices and technical systems in the Company are designed in a manner to anticipate, identify and avoid harm to the User;
  2. Technology used in the processing of personal data is in accordance with commercially accepted or certified standards;
  3. Legitimate interests of businesses including any innovation is achieved without compromising privacy interests;
  4. Privacy is protected throughout processing of Information, from the point of collection to deletion of personal data.

2. What do we Collect?

To enable Us to provide services to You or for You to access/utilise the Platform, You may be required to provide certain personal, non-personal and other information, as indicated below (such information and correspondences hereinafter collectively referred to as “Data/Information”):

By using Company Website/Platform or its services, you give Company your consent to collection, storage, and use of the Personal Information and non-personal information as elaborated below (including any changes thereto as provided by you) for any of the services that we offer.

  1.  We may require you to provide us with certain information (for availing the Services, making initial registration and for use of functionality provided in Platform) that personally identifies You (“Personal Information“). Personal Information includes the following categories of information: (i) Contact Data (such as your e-mail address, address, phone number); and (ii) Demographic Data (such as your gender, your date of birth etc) (iii) your occupation, interests, and the like., but does not include information freely available and/or accessible in the public domain. Please note that this list is illustrative and not exhaustive, and We may require you to provide certain additional Personal Information as and when required for the provision of services.
  2. We may receive information about Your external storage, camera, location, unique identifier number for Your device, device key guard (whether biometric, pattern or pin based and IP address for enhancing the User’s experience, for security purposes, to serve better and in line with the Service requirements of Company. Company would employ reasonable security measures to preserve the security & integrity of the information that are collected from the User’s.
  3.  We may receive information based on User decision to use all the functionality provided on the Platform and decides to enrol for investment purposes, in accordance with the KYC norms and regulatory requirements, user shall provide its name, gender, contact number, PAN card details, bank account details (including account number, bank name, etc) address details (including a copy of the address proof), Aadhar Card Details, credit card or debit card details, medical records and history and a cancelled cheque leaf.
  4. We may receive SMS Inbox Information based on specific consent provided by You.  Such SMS Inbox Information includes SMS text messages pertaining to Your expenses arising out of transactions made from cards, banks, wallets through text messages (SMS) received by you from providers of services and/or banks (including but not limited to retail outlets, financial institutions, and utility companies). The collection of such information is only limited to the extent that such data is available in the relevant messages. We may also record the identity of the product or service and the price or fee paid or payable in respect thereof. You can choose to opt-out of such expense tracking facility by visiting Our Platform’s permission settings.
  5. Company will require the User to provide a virtual signature (physically on the mobile screen or an image of the signature on a plain white paper). Company will use this signature only for the limited purpose of completing the enrolment process and it will not be used for any transactions other than filling forms for enrolment. This signature provided by the user will not be shared with any third parties.
  6. Sometimes, You may not be actively submitting such information. Unidentifiable information may be collected using various technologies, such as cookies, tags, and web beacons. Your browser automatically transmits to Us some of this unidentifiable information. These kinds of information allows Us to provide better service, customize sites based on consumer preferences, compile statistics, analyze trends, and otherwise administer and improve Our Platform. This type of information does not identify You personally.
  7. In a case of an error in the app we collect data and information (through third party service providers) on your phone, called as Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.
  8. We may receive information about you from other sources, add it to our account information and treat it in accordance with this 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. The Platform does use third party services that may collect information used to identify you. We are herewith providing link to third-party service provider’s privacy policy used by the Platform:

When You send emails or other communications to Us, we may retain those communications in order for Us to process Your inquiries, respond to Your requests.

If you choose not to provide your Personal Information that is mandatory to process your request, We may not be able to honour Your request.

3. What do we do with the Information?

We will always process the Information only in accordance with this Privacy Policy, Your Consent/request and as permitted by applicable law. We may process the Information You provide in the following manner:

  • To provide services to you as set forth in our Platform;
  • To allow our professionals, business partners to assist us with providing services to You, to connect with You to provide their services/products You may specifically consent to be contacted for;
  • To provide automated expense tracking service to analyse Your spending, organize Your expenses and to provide analytics on the same to you.
  • To contact You and to customise Our communication with You and the marketing material we share with You;
  • To analyse and suggest any other related product/service that shall be suitable for you;
  • To avoid fraud and other prohibited or illegal activities;
  • To respond to authorized information requests from governmental authorities or when otherwise required by law;
  • To enforce the legal terms (including without limitation Our policies and Terms) that govern your use of Our services, and/or for the purposes for which you provided the Information;
  • To protect the security or integrity of the Platform, Our business, services and other users; and/or
  • To publish any testimonials or reviews that You may have provided on the Platform.

We do not sell, trade, or otherwise transfer to third parties Your Information. This does not include trusted third parties who assist Us in operating Our Platform, conducting Our business, or servicing You. When we provide Your Data/Information to individuals and entities which assist us with Our business activities, it is Our practice to require those individuals and entities to keep such Information confidential and to use Your Personal Information only to perform services requested by you and for no other purpose.

In the event of an audit, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Our business, assets or stock (including in connection with any bankruptcy or similar proceedings), We may share/transfer/assign the Data/Information we have collected to the relevant third party.

4. How long do we hold Information?

We retain Personal Information only for as long as we have Your consent. We retain Your Personal Information for as long as We have an ongoing relationship with You and You continue to access/use the Platform. However, we retain copies of Your Information if there is a legal obligation to which We are subject or keeping in view the legitimate interests of the Company (litigation or statutory requirements).

If you wish to opt-out of collection, use, processing or transfer of Personal Information furnished to Us, You may do so at any time.  Please write to us at the co-ordinates provided below. However, please note that in the event You opt-out of providing Personal Information to Us, We would not be able to provide certain services to You and Your access to the Platform and/or Services will be restricted.

5. How safe is your Information?

We use reasonable security measures to protect Information from unauthorized access, maintain data accuracy and help ensure the appropriate use/disclosure of Information. We host the Platform in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders.

6. Third-Party Links

Our Website may contain links to or integrations with other services including social media services and platforms whose information practices may be different than ours. You should consult these other services’ privacy notices as we have no control over information that is submitted to, or collected by, these third parties.

7.   Miscellaneous

  1. As we update, improve and expand the Website, we may update this Privacy Policy and the same will be made available on the Website.
  2. We will not be responsible for the accuracy or filtration of any of the content posted on Our Platform by any user, however, We will be entitled to remove any content posted by any user on Our Platform which We, at Our sole discretion, consider offensive, discriminatory, racist, defamatory, inappropriate in nature or unlawful.
  3. Company reserves the sole discretion to process Your requests, depending upon the Legitimacy and relevance of request to our Business(es).
  4. Operation of Platform will require the Platform to have an active internet connection. You are responsible to have active internet connection/WIFI at your own cost. We shall not be responsible for Platform not working at full functionality due to any reasons mentioned in this clause.
  5. You need to make sure that Your device stays charged at all times during usage of the Platform. if Your device runs out of battery and due to which you can’t turn it on to avail the Services, Company cannot accept responsibility for the same.
  6. The Platform is currently available on Android and shall be subject to constant updates depending upon system requirements. It shall be your responsibility to download the updates, if you want to continue using the Platform. Company does not promise that it will always update the Platform so that it is relevant to you and/or works with the Android version that you have installed on your device. However, You agree to always accept updates to the Platform when offered to you.
  7. These terms and conditions are effective as of 2021-30-07

We would be happy to address any questions regarding this Privacy Policy. Please reach to us at 44 6668 7169 or write to us at [email protected]. In the event you don’t hear back from us in 15 days, please reach out to the Grievance Officer- Compliance Team at [email protected] or 44 6668 7169