To avail of certain services on our App, users may be required to provide certain information for the registration process namely: - a) your name, b) email address, c) PIN code, d) password etc., and/or your occupation, interests, and the like. The Information supplied by the users enables us to improve our sites and provide you with a personalized experience. All required information is service dependent and we may use the above-said user information to, maintain, protect, and improve our services (including advertising 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 or any other law for the time being in force. Cookies To improve the responsiveness of the sites for our users, we may use "cookies", or similar electronic tools to collect information to assign each visitor 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 (through registration, for example), we will have no way of knowing who you are, even if we assign a cookie to your computer. 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. Our web servers automatically collect limited information about your computer's connection to the Internet, including your IP address, when you visit our site. (Your IP address is a number that lets computers attached to the Internet know where to send you data -- such as the web pages you view.) Your IP address does not identify you personally. We use this information to deliver our web pages to you upon request, to tailor our site to the interests of our users, to measure traffic within our site and let advertisers know the geographic locations from where our visitors come.
Private Limited (hereinafter referred to as the
“Company” or “we” or “us” or “our”) which operates
a website and sub-pages having its address as
(hereinafter referred to as the “Website”) and a
Mobile Application having its name as, while
accommodating its variations as BULLSPREE
(hereinafter referred to as “Mobile Application”)
(The Website and Mobile Application are
hereinafter collectively referred to as “BullSpree
Platforms”) in India, through which the Company
hosts and offers access and participation to
various contests, games including financial
literacy games being conducted on the BullSpree
Platform hereinafter referred to as “BullSpree
Services”) through the Website, Mobile
Application, partner website(s) and mobile
application(s) (collectively referred to as the
“Portals”), collects, uses, shares and protects
information of any person accessing or utilizing
the BullSpree Platforms (hereinafter referred to
as the "User" or "you" or "your"
(B) The Company is committed to protecting the User’s privacy and has therefore, provided this Policy to familiarize the User with the manner in which the Company uses the information disclosed by the User to the Company.
- (i) information supplied by Users and
- (ii) information automatically tracked during User's navigation on the Portals.
(E) In order to avail any of the BullSpree Services on any of the BullSpree Platform Services, the Users would be required to provide certain information for the registration process namely:
- 1. Username
- 2. Password
- 3. Email address
- 4. Date of birth
(F) In addition to the above information, the Company would also require the User to submit information regarding the Users Vocation, Profession, Employment and Work Status.
(G) In the course of providing the User with access to the BullSpree Services, and in order to provide the User an access to the features offered through the Portal and to verify the User’s identity, the User may be required to furnish additional information, including but not limited to the User’s Permanent Account Number.
(I) All required information is specific and based on the kind of BullSpree Service the User wishes to participate in or access, and will be utilized for the purpose of providing services, including but not limited to the BullSpree Services requested by the User. The Company may also share such information with affiliates and third parties in limited circumstances, including for the purpose of providing services requested by the User; for promotion, marketing and advertising; complying with legal process; preventing fraud or imminent harm; and ensuring the security of its network and services.
3. Personal Information :
Personal Information is defined as information that can be used to identify the User and may include details such as the User’s name, age, gender, contact information, products and services the User is interested in or require more information about. Insofar as sensitive personal information is concerned, it will carry the meaning as may be defined by applicable laws from time to time. The following is the manner in which the Company collect, use, share and retain personal information:
Collection- The User agrees that the Portals may collect such personal information, whenever relevant, to help providing the User with information and to complete any transaction or provide any services to the User have requested or authorized. The User also consent to the collection of certain personal information in the course of the User applying and accessing any of the services provided by the Company.
In certain instances, the Company may also collect Sensitive Personal Information (hereinafter referred to as “SPI”) from the User on the Portal. SPI means such personal information which consists of information relating to the User’s physical, physiological and mental health condition; medical records and history; biometric information, sexual orientation and financial information, such as information regarding the payment instrument/modes used by the User to make such payments, which may include cardholder name, credit/debit card number (in encrypted form) with expiration date, banking details, wallet details etc. This information is presented to the User at the time of making a payment to enable the User to complete the payment expeditiously. Except for any financial information that the User chooses to provide while making payment for any BullSpree Services on the Portal, the Company does not collect any other SPI in the course of providing the BullSpree Services.
Usage - The Portals seeks the User’s personal information either:
- (i) to validate and process the User’s request for the services at BullSpree Platform or information; or
- (ii) to improve the quality of the BullSpree Platform; or
- (iii) to assist the User to determine which services best meet his/her needs; or
- (iv) to facilitate the Company’s internal business operations, including the fulfilment of any legal and regulatory requirements; or
- (v) to provide the User with recommendation about services the User may be interested in, based on the User’s use of the BullSpree Platforms; or
- (vi) to provide the User with marketing communications and advertising that the BullSpree Platform believes may be of interest of the User; or
- (vii) to facilitate the User’s access to the BullSpree Services
- (viii) to facilitate the User’s usage of any information, entertainment, promotion and/or engagement services/facilities availed by the User’s though the BullSpree Platforms; or
- (ix) to facilitate the User’s participation in various contests or programs conducted by the Company, affiliates, subsidiaries or agents on the BullSpree Platforms.
Sharing- The Company will strive to keep the User’s personal information confidential and will place reasonable security controls to protect it. The User’s personal information will be kept confidential as required under applicable laws. The Company may share personal information with its affiliates when necessary to perform services on its behalf or on the User’s behalf, to provide advertising and promotional services, to provide search results and links (including paid listings and links), to process credit card payments, to provide customer service etc.
The Company may also share personal information with external organizations or individuals if the Company believes that access, use, preservation or disclosure of the information is reasonably necessary to:
- (i) meet any applicable law, regulation, legal process or enforceable governmental request;
- (ii) detect, prevent or otherwise address fraud, security or technical issues;
- (iii) protect against harm to the rights, property or safety of its customers or the public, as required or permitted by law.
- (iv) to protect and guard the rights and interests of the Company
In the event the Company sells or transfers all or a portion of its business assets, consumer information may be one of the business assets that are shared, disclosed or transferred as part of the transaction. The User hereby expressly grant consent and permission to the Company for disclosure and transfer of information to such third parties.
Retention and Security -The personal information so collected shall be retained only for a limited duration necessary to fulfil the purposes outlined herein unless a longer retention period is required or permitted by law and only for the purposes defined above. Once the purpose is achieved, all personal information is deleted in a safe and secure mode. The Company have adopted reasonable security practices and procedures as required under applicable law and have included strategic, operational, managerial, technical and physical security controls to safeguard and protect the User’s data and information.
4. Non-Personal Information:
(K) Non-personal information is defined as any data that does not personally identify the User and may include unique system or hardware identifiers, system or application software, and peripherals. Any non-personal information, which when clubbed with personal information becomes personal information, shall be treated as personal information.
(L) The following is the manner in which the Company collect, use, share and retain non-personal information :
- (i) Collection – The User agrees that the Portal may collect diagnostic, technical and usage related information for the usage purposes described below. By using the Portals, the User hereby expressly agree and grant consent to the collection, use and storage of this information by the Company.
- (iii) Sharing - To enable the third party developers to improve their software, hardware and services designed for use with the Portal, the Company may also provide any such third party developer with a subset of diagnostic information that is relevant to that developer’s software, hardware and/or services, as long as the diagnostic information is in a form that does not personally identify the User. The Company may also share information as provided by the User and data concerning usage of the BullSpree Services with third party service providers engaged by the Company, for the purpose of data analytics or other similar purposes, for the purpose of storage, improving the services on the BullSpree Platform. The Company also reserves the right to share, disclose and transfer information collected hereunder with its own affiliates. The Company may share any information as provided by the User and data concerning usage of the BullSpree Services with its commercial partners for the purpose of facilitating user engagement, for marketing and promotional purposes and other related purposes. In the event the Company sells or transfers all or a portion of its business assets, consumer information may be one of the business assets that are shared, disclosed or transferred as part of the transaction. The User hereby expressly grant consent and permission to the Company for disclosure and transfer of information to such third parties.
- (iv) Retention - The information so collected shall be retained only for a limited duration necessary to fulfill the purposes outlined herein unless a longer retention period is required or permitted by law and only for the purposes defined above. Once the purpose is achieved, all information is deleted in a safe and secure mode.
(M) To improve the effectiveness and usability of the BullSpree Platform for its Users, the Company uses "cookies", or such similar electronic tools to collect information to assign each visitor a unique random number as a User Identification (User ID) to understand the User's individual interests using the identified computer. Unless the User voluntarily identifies himself/herself (e.g., through registration), the identity of the such unregistered User remains anonymous, even if a cookie gets assigned to the User's computer. The only personal information a cookie can contain is information supplied by the User. A cookie cannot read data off the User's hard drive. The Company’s advertisers may also assign their own cookies to the User's browser (if the User clicks on their ad banners), a process that the Company does not control. The Company's web servers automatically collect limited information about User's computer's connection to the Internet, including User's IP address, when the User visits the Portal. (User's IP address is a number that lets computers attached to the Internet know where to send data to the User -- such as the web pages viewed by the User). The User's IP address does not identify the User personally. The Company uses this information to deliver its web pages to Users upon request, to tailor its Portal to the interests of its users, to measure traffic within the Portal and let advertisers know the geographic locations from where the visitors to the BullSpree Platform come.
(N) Information collected by cookies and other technologies are treated as non- personal information. However, to the extent that IP addresses or similar identifiers are considered personal information by local law, the Company treat
any information linked to such identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information becomes personal information, the Company will treat the combined information as personal information.
6. Other Information
7. Information received from third-party services:
(Q) If in case, any person derives honest and bonafide access to the BullSpree Services, through BullSpree Platforms using a third-party service, such as Facebook, Google etc., such third-party services automatically provides the Company access to certain Personal Information such as the User’s name, account ID, email address, profile picture as used and uploaded by the User on the third-party service. Subject to the terms of service of such third-party service, the User may be able to control the Personal Information shared by the third- party services with the Company by way of privacy settings of third-party services. Any Personal Information shared by a third-party service, through which the User access the Services, will be subject to terms and conditions of such third-party services and the Company shall not be responsible in respect of the same. When a User accesses the BullSpree Services, through BullSpree
Platform using the third-party services, the Company does not save or store the User’s password for such third-party services. In case of loss of password or any of the data or content of such User, the Company shall be unable to retrieve the User’s account details, password and/or any data for the third-party services.
9. Security Procedures
(S) All information gathered on the Portal is securely stored within controlled database of the Company. The database is stored on servers secured behind a firewall; access to such servers being password-protected and strictly limited based on need-to-know basis. The User though understands and agrees that security risk cannot be completely eliminated while using the internet. The User accepts the inherent security implications of providing information over the internet and agree not to hold the Company responsible for any breach of security or the disclosure of Personal Information unless the Company is adjudged as being grossly and willfully negligent by a judicial authority of competent jurisdiction.
11. Conditions of Use
(V) The Company does not warrant that the portal, it’s servers, or email sent by it or on its behalf are virus free. The Company will not be liable for any damages of any kind arising from the use of the portal, including, but not limited to compensatory, direct, indirect, incidental, punitive, special and consequential damages, loss of data, goodwill, business opportunity, income or profit, loss of or damage to property and claims of third parties.
(W) The Company shall not be liable for any indirect, incidental, consequential, special or exemplary damage(s) arising due to loss of data or use arising out of or in connection with the User’s access or use of or inability to access or use the BullSpree Platform. The Company shall not be liable for any third-party products, software or service provided by any third-party applications on the Portal. The User shall assume all risks arising out of or resulting from any action or transaction undertaken by it with any third party application on the BullSpree Platform and the User agrees that the Company shall not be responsible or liable for any loss to the User due to its usage of such third party application.
(X) In no event will the Company be liable for any damages whatsoever in an amount in excess of an amount of INR 100.
12. Retention of Data
Y. The User’s personal information may be retained and may continue to be used until:
(ii) the Company is no longer required by applicable law, regulations, contractual obligations or legitimate business purposes to retain the User’s personal information and the retention of the User’s personal information is not required for the establishment, exercise or defense of any legal claim.
13. Applicable Law and Jurisdiction
14. Updating Information
(AA) The Company strives hard to keep its records updated and accurate with the latest information about its Users. The User hereby warrants to promptly update the information and simultaneously notify the Company if there are any changes, updates or modifications to the User’s information. The User shall be responsible to ensure that the information or data that the User provide from time to time is and shall be correct, current and updated and the User have all the rights, permissions and consents to provide such information or data. Further, the User may also review, update or modify its information and user preferences by logging into the User’s Profile page on the BullSpree Platform. The User may note that deletion of certain information or withdrawal of consent may lead to cancellation of the access to or the access to certain features and services available on the BullSpree Platform.
(BB) Additionally, the Company may not be able to process the User’s request of correction, updating or deletion, in case the same is not supported by valid documents or data retention is required by the applicable law or law enforcement requests or under any judicial proceedings or it is extremely difficult to implement (such as requests related to backup copies or if a new system is required to process the request or change of technical design) or risks the privacy of other users.
15. Queries and Complaints
(CC) The Company is committed to protect the User’s personal information collected and processed by it and looks forward to continued support from the Users for the same. In case of any feedback or concern regarding protection of the User’s personal information, or any privacy related feedback or concerns the User may contact customer support team at email@example.com
This document/agreement/understanding is an electronic record in terms of Information Technology Act, 2000 and rules and regulations thereunder and is generated by a computer system and does not require any physical or digital signatures. This document is published in accordance with the provisions of Rule 3 of the Information Technology (Intermediaries Guidelines) Rules, 2011.