Collection of Information

• In order to enable us in providing you with the best-in-class services, we require certain information be shared by you with us. Spear Head Live may collect the following types of information:
• “Personal Information” which shall mean information which could reasonably be used to identify you personally, which may include, but not limited to the following:
• Basic details which you provide during the registration process such as Name, Phone Number, Email Address, Communication or Permanent Address.
• Photograph provided during registration or during the profile update.
• Proof of Identity and Address documents such as PAN Card, Driving License, Passport etc.
• Transactions performed which can identify you as an individual through your customer ID or other relevant unique identifier.
• Demographic details such as gender, city, PIN code or nearest location.
• Usage logs/Server logs/Cookies which may contain details of your personal or sensitive personal information.
• Service specific information or identifiers such as IMSI, MSISDN, Customer ID etc.
• Device specific information or identifiers such as IMEI, OS specific identifiers.

For the purpose of this policy, sensitive personal data or information has been considered as a part of Personal Information, which may include, but not limited to the following:

• Passwords or authentication information for any of our services or apps.
• Financial information, such as details of bank account, credit card, debit card, or other payment instrument details etc.

“Non-Personal Information” which shall mean information that does not identify you or any other individual, and includes session, web beacons and usage and transaction data, aggregate log data and aggregate information. We use this information to inter-alia deliver our web pages to you upon request, to tailor our services to the interests of our users, to measure traffic within our services, to improve the quality, functionality and interactivity and let advertisers know the geographic locations from where our users/ visitors come.

• We are mandated under law to collect the following information, which is mandatory for provision of services to you:
• Basic details which you provide during the registration process such as Name, Phone Number,
• Photograph provided during registration.
• Proof of Identity Documents such as Pan Card, Driving License, UIDAI, Passport.
• Proof of Address Documents such as Driving License, Passport, Utility Bills.

In the Customer Acquisition Form (CAF), we have clearly highlighted fields which are mandatory and those that are optional. In case you refuse to provide your information or deny consent for the usage of the information provided or later withdraw your consent, we may choose to discontinue or deny the services for which the information was collected.

Use of Information

• The information provided by you to us is used for a number of purposes connected with our business operations which may include the following:
• Verify your identity, access, privileges assigned and relationship with us.
• Provisioning of products/services, testing or improvement of services, recommending various products or services.
• Processing your requests, enquiries and complaints, customer services and related activities;
• Communicating to you about bills, invoices, existing or new offers, content, advertisements, surveys, key policies or other administrative information;
• Analytics and reviews for improvement of our services;
• Improving your experience while using our services by presenting advertising, products and offers tailored to you;
• Completing your purchase;
• Support to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law or anti-fraud activities/systems;
• Other usages that you may consent to.

We will strive to keep your personal information confidential and will place reasonable security controls to protect it. Your Personal Information will be kept confidential as required under applicable laws.

However, any comments, messages, blogs, scribbles etc. posted / uploaded / conveyed / communicated by you on the public sections of the apps/website becomes published content and is not considered personal information subject to this Policy. You may request that such information be taken down and, we may attempt to remove any such information if it is technically feasible to do so and as per the applicable laws.

Further, with respect to Non-Personal Information automatically collected and stored in files, we shall use this information to understand and analyze trends, to administer our services, to learn about user behaviour while using our services, to gather demographic information about the user base as a whole and to measure traffic patterns on our network. As Non-Personal Information does not personally identify you, we may use and disclose Non-Personal Information at our discretion.

Sharing and Disclosure

• We do not sell or rent personal information to any third-party entities. We limit the disclosure of the Personal Information to certain circumstances, as provided below:
• Mergers or acquisitions: In a scenario where we or our assets are merged or acquired by the other business entity, or during restructuring of business or re-organization, we may have to share information provided by you with the other business entities. Rest assured, if such a transaction occurs the other business entity or the newly combined business entity would be required to follow this Privacy Policy.
• Partners: we engage a number of vendors, consultants, contractors and take support of our group companies or affiliates (hereon referred to as our Partners). Our Partners provide a host of services including contact information verification, payment processing, customer service, website hosting, data analysis, infrastructure provision, IT services, and other similar services. These Partners play a key role in seamless delivery of our products and services to you. These Partners and their employees operate under a contract and strict security & confidentiality restrictions. We may provide our partners access to your information through our systems or may share your Personal Information with them to enable them to provide their services to you.
• Customer Initiated Sharing: Whenever you request us to share your information with a third party website or application (for example, login to a third party using your Spear Head Live ID), we will provide a fresh notice and obtain consent from you regarding the details of the information that will be shared, before sharing the same. In such a case, Spear Head Live will not be in control of the information (shared with the third party website/application or data generated based on your usage on that website) and Spear Head Live privacy policy will not be applicable for any such use, access etc. Any processing, use, sharing of Information provided by you to such third party website/application shall be as per the respective privacy policy of such applications or websites . The customer shall read and provide consent to the third partys privacy policy before requesting Spear Head Live to share the information.
• Government or judicial process: We may share your Personal Information with the government / government authorities or agencies and legal or judicial authorities for any investigation or to comply with legal process or in response to a request by any of these authorities or to enforce applicable terms and conditions or to protect our, our users and Partners rights, privacy, safety or property.
• Legal Reasons: The information provided by you may be shared with our other entities and affiliates to help in detecting and preventing identity theft, frauds and other illegal activities; correlate or map related accounts to prevent misuse of our products & services and to provide you our services.
• Protection of Spear Head Live: To protect your rights and/or those of our Partners, and to allow Spear Head Live to pursue available remedies or limit the damages that it may sustain in case of unauthorised use / misuse of our products or the content thereon, by third parties.

Storage, Retention and Security

• We have adopted reasonable security practices and procedures, in line with international standard IS/ISO/IEC 27001, to include strategic, operational, managerial, technical, and physical security controls to safeguard and protect your data and information. We have implemented such measures, as stated above, to protect against unauthorized access to and unlawful interception of Personal Information. Additionally, we have adopted measures to ensure that your personal information is accessible to our employees or partners employees strictly on the need-to-know basis.
• Our website, portals, and network equipment have industry standard security precautions in place to protect the loss, misuse and alteration of information which is in our environment. Whenever you change or access your account information, we facilitate the use of secure systems. The information in our custody and control is protected by adherence to reasonable security procedures in order to safeguard against unauthorized access. We apply encryption or other appropriate security controls to protect Personal Information when stored or transmitted by us.
• Your information or data will primarily be stored in electronic form. However, certain data can also be stored in physical form.

We may enter into agreement with third parties to collect, store, process your information or data but under full compliance with applicable laws. These third parties may have their own security standards to safeguard your information or data and we will require such third parties to adopt reasonable security standards to safeguard your information / data on commercially reasonable basis.

We have taken appropriate steps for the security and protection of all our digital platforms including internal applications, however, we shall not be responsible for any breach of security or the disclosure of Personal Information for reasons outside our control, such as hacking, social engineering, cyber terrorism, espionage by third parties, or any events by way of force majeure such as sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government.

Third Party Websites, Applications and Services

Spear Head Live website may include links to other websites/applications. Such websites/application 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 website/application you are visiting. That policy may differ from ours. If you can’t find the privacy policy of any of these websites/application via a link from the website’s homepage, you should contact the website/application directly for more information.

Access, Correction and Deletion

We strive hard to keep our records updated and accurate with your latest information. You shall be responsible to ensure that the information or data you provide from time to time is and shall be correct, current and updated and you have all the rights, permissions and consent to provide such information or data. Based on technical feasibility, we will provide you with the access to all your personal and sensitive personal information that we maintain about you. We will perform verification before providing you access to this information. You may request access, correction or updation, and deletion of the information by contacting Spear Head Live dedicated resource. You may note that deletion of certain information or withdrawal of consent may lead to cancellation of your registration with us or your access to our services. Additionally, we may not be able to process your request of correction, updation or deletion, in case the same is not supported by valid documents or data retention if 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.

Queries and complaints

We are committed to protect your personal information collected and processed by us and look forward to your continued support for the same. In case of any feedback or concern regarding protection of your personal information, you can contact us at support@spearheadlive.in Alternatively, you may also direct your privacy-related feedback or concerns to the Privacy Grievance Officer whose details are as mentioned below: If you have questions or concerns about this Policy, please contact Spear head live at support@spearheadlive.in