Privacy Policy

Safeguarding Your Information and Trust

INTRODUCTION

This Policy is owned and operated by SPG Global and belongs to SPG Global Commodities Limited (“the Company”), henceforth referred to as “SPG Global Privacy Policy”.

In the course of using the SPG Global website and app or availing the products and services, SPG Global may become privy to the personal information of its users, including information that is of a confidential nature. SPG Global provides services to the users through its app and website, and is committed to protecting and respecting the privacy of the users and has taken all necessary and reasonable measures to protect the confidentiality of the user information and its transmission through the World Wide Web. SPG Global shall not be held liable for disclosure of the confidential information if such disclosure is in accordance with this Privacy Policy (“Policy”) or in accordance with the terms of any agreements entered with the users. SPG Global also assures not to disclose all information (except in some limited circumstances as mentioned below) that it learns during the transactions and payments made to the user’s account(s). “user (s)” shall mean and include all companies and private organizations that visit the website and provide information to SPG Global through any of the modes referred to in the clause on “Collection of Information” below. All words and expressions used in this policy shall have the meanings respectively assigned them in the prescribed Act.

APPLICABLE LAWS

The Policy is made based on the following laws:

1. The Information Technology Act, 2000
2. General Data Protection Regulation (GDPR)

 

TYPES OF INFORMATION WE COLLECT

We collect two basic types of information – personal information and anonymous information – and we may use personal and anonymous information to create a third type of information, aggregate information. In particular, we collect:

• Registration information you provide when you create an account, enter a promotion, or link your profile on a third-party site or platform with your registration account, such as your first name and surname, country of residence, gender, email address, username
• Transaction information you provide when you request information, contact Services, or purchase, a plan or service from us, such as your postal address and telephone number
• Details related to the name of the Company, Date of Incorporation, GST Number, Billing Address, Turnover, Operating Locations (Countries and States), Website details, Company Type, Contact Details such as Name of the Contact, Email Id, Phone Number and the Designation of the concerned person
• Information you provide in public forums on our sites and applications
• Information sent either one-to-one or within a limited group using our message, chat, post, or similar functionality, where we are permitted by applicable law to collect this information
• Information we obtain from a third party, such as a site or platform provider, about use of our applications on third-party platforms or devices
• Location information, including location information provided by a mobile or other device interacting with one of our sites, applications, or physical properties, or associated with your IP address or other online or device identifier, where we are permitted by law to process this information
• Activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the tenders you search, how often you use our services, and your preferences
• Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, or connect with our wireless Internet access services and other similar technologies, including your browser or device type, unique device identifier, and IP address
• Call recordings when you call our Customer Care, Chat, SMS, and mails while if you opt for Whatsapp, Email etc and other services
• Product Notifications: By signing up, you agree to receive product notifications that we consider integral to your overall product experience. These notifications may include important updates, promotions, and relevant information about our services. You can opt-out of receiving product notifications at any time by adjusting your account settings or following the instructions provided in the notifications.

 

HOW WE COLLECT YOUR INFORMATION

• We collect information you provide to us when you request or purchase product, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), or other activities on our sites and applications, respond to guest surveys, visit our physical properties, call our Customers centers, or otherwise (including emails and whatsapp) interact with us using one or more devices. You may provide information in a variety of ways, including by typing or using voice commands
• We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether or not you are logged in or registered.
• We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we validate postal address information using third party services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it.

 

USE OF YOUR INFORMATION BY THE SPG GLOBAL

The SPG Global that is the data controller for your information is responsible for and may use your information for the purposes described in this policy. Other group companies may access your information where they perform services on behalf of the data controllers (as data processors) and, unless prohibited under applicable law, for use on their own behalf (as data controllers) for the purposes described in this policy. Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:

• Provide you with the experiences, products, and services you request, view, engage with, or purchase
• Communicate with you about your account or transactions with us and send you information or request feedback about features on our sites and applications or changes to our policies
• Send you offers and promotions for our products and services or third-party products and services
• Personalize content and experiences
• Provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications
• Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations, including by using survey research and analytics tools; and
• Detect, investigate and prevent activities that may violate our policies, pose safety issues, or be fraudulent or illegal; and
• Notify you of product recalls or safety issues.
• SPG Global will use the Data including personal data in the legitimate manner and the information will not be further processed by SPG Global in any manner without asking for the consent.

 

SHARING YOUR INFORMATION WITH OTHER ENTITIES

We may disclose user’s information to such third parties to whom it transfers its rights and duties under the agreement entered into with the users. In such an event, the said third parties use of the information will be subject to such confidentiality obligations as contained in the policy.

CONTROL OVER INFORMATION AND CHOICES

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with applicable law, your controls and choices may include:

• Correcting, updating, and deleting your registration account
• Choosing or changing your choices for subscriptions, newsletters, and alerts
• Choosing whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you
• Choosing whether we share your personal information with other companies so they can send you offers and promotions about their products and services
• Controlling targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers
• Choosing to control targeted advertising you receive within applications by using the settings and choices made available to you through your device(s), for example, by re-setting your device’s advertising identifier and/or opting out of interest based ads
• Requesting removal of your personal information from a public forum on one of our sites or application; and
• Requesting access to the personal information we hold about you and that we amend or delete it

You may exercise these controls and choices in various ways, contacting Customer Service Centre, following instructions provided in communications sent to you, or by using your device or other available settings (for example, by re-setting your device’s advertising identifier, unsubscribing emails, changing notification settings in your account and/or opting out of interest based ads).

Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact Customer Service Centre

DATA SECURITY, INTEGRATION AND RETENTION

SPG Global takes the security of its user’s information very seriously. SPG Global protects the user’s information using bank-level data security: 128 bit-encryption and a TLS 1.2 protocol. This creates an encrypted connection between the user’s browser and SPG Global servers. All information always remains encrypted. SPG Global doesn’t store any banking information (username, password etc) in any manner

All information provided to SPG Global is stored on its secure servers whether outside or within India

SPG Global uses commercially reasonable safeguards to preserve the integrity and security of the users’ information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment.

The information that is collected from the users may be transferred to and stored at a destination inside or outside India. By submitting information on the website, the users agree to this transfer, storing and/ or processing. SPG Global will take such steps as it considers reasonably necessary to ensure that the users’ information is treated securely and in accordance with the Policy.

In using the website, the users accept the inherent security implications of data transmission over the internet and the World Wide Web cannot always be guaranteed as completely secure. Therefore, the use of the website will be at the own risk of the users.

SPG Global assumes no liability for any disclosure of information due to errors in transmission, unauthorized third-party access or other acts of third parties, or acts or omissions beyond its reasonable control and the user agrees not to hold SPG Global responsible for any breach of security unless such breach has been caused as a direct result of gross negligence or wilful default by SPG Global.

In the event SPG Global becomes aware of any breach of the security of the users’ information, it will promptly notify the users and take appropriate action to the best of its ability to remedy such a breach.

CONSENT AND EXCLUSION

This Policy does not apply to any information other than information collected by SPG Global through the website and applications including such information collected in accordance with the clause on “Collection of Information” above. This Policy shall not apply to any unsolicited information provided by the users through this website or through any other means. This includes, but is not limited to, information posted to any public areas of the website. All such unsolicited information shall be deemed to be non-confidential and SPG Global shall be free to use, disclose such unsolicited information without limitation

SPG Global shall obtain digital consent from the provider of the sensitive personal data or information regarding purpose of usage before collection of such information. During the use of the website, SPG Global may collect and process information from the users as mentioned above,

While collecting information directly from the person concerned, SPG Global or any person on its behalf shall take such steps as are, in the circumstances, reasonable to ensure that the person concerned is having the knowledge of

1. the fact that the information is being collected
2. the purpose for which the information is being collected
3. the intended recipients of the information.

SPG Global or any person on its behalf shall, prior to the collection of information including sensitive personal data or information provide an option to the provider of the information to not to provide the data or information sought to be collected. The provider of information shall, at any time while availing the services or otherwise, also have an option to withdraw its consent given earlier to SPG Global Such withdrawal of the consent shall be sent in writing to the SPG Global. In the case of a provider of information not providing or later on withdrawing his consent SPG Global shall have the option not to provide goods or services for which the said information was sought.

COOKIES

SPG Global collects certain information from the user’s browser using small data files called “cookies.” SPG Global uses session ID cookies to confirm that customers are logged in. This type of cookie helps SPG Global recognize a customer if he or she visits multiple pages on the website during the same session, so that separate passwords are not required to access each page. These cookies terminate once the customer closes the browser. By default, SPG Global uses a persistent cookie that stores customer login ID (but not password) to make it easier for the customer to login when returning to the website. SPG Global encodes its cookies so that only SPG Global can interpret the information stored in them. The user may remove or block this cookie using the user’s browser settings to disable the feature. SPG Global also stores transaction history. SPG Global may collect additional information in ways not specifically described herein. For example, SPG Global may track information related to interactions with customer service or responses from surveys or other feedback tools. SPG Global uses this information to continually improve the service provided to the customers. SPG Global’s Privacy Policy does not cover the use of cookies by its partners and affiliates. SPG Global does not have access or control over these cookies. SPG Global’s partners and affiliates may use session ID cookies to provide a custom user experience and to track the success of SPG Global’s partnership with them. 

WEB BEACONS

The web pages of the website contain electronic images known as “web beacons” (sometimes called single- pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how the website is used. Web beacons may also be used in some of SPG Global’s emails to so as to know which emails and links recipients have opened, allowing it to gauge the effectiveness of its customer communications and marketing campaigns.

REFERRALS

If the user wishes to introduce SPG Global / the website to any other person / entity, the user will be asked to provide such person / entity’s name and email address. SPG Global will automatically send such person / entity an email inviting it or to visit the website. SPG Global stores this information for the purpose of sending this email and keeping a record of the number of persons/ entities so referred by the users. SPG Global may send additional emails to the said person / entity in connection with services offered by SPG Global. Such person / entity may contact SPG Global at contact@SPG Global.com to request that this information be removed from SPG Global’s database.

DATA RETENTION

User information will be retained for as long as the user account is active or as needed to provide services to the user or otherwise required under any other law for the time being in force. If the user wishes to cancel its account or requests that SPG Global no longer uses its information to provide services, the user may contact SPG Global at contact@SPG Global.in. SPG Global will retain and use user information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements or for other business purposes.

CHANGES TO PRIVACY POLICY

In the event SPG Global modifies this Privacy Policy, the same will be updated on the website. This policy may be changed, but any changes will be posted, and changes will only apply to activities and information on a going forward, not retroactive basis. The users are encouraged to periodically review this page for the latest information on its privacy practices. In case of any material changes to the Policy, the users will be notified by email (sent to the email address specified in the user’s account) or by means of a notice on this website prior to the change becoming effective.

SEVERABILITY

SPG Global has made every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy.

NO WAIVER

The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

NON-DISCLOSURE

SPG Global pledges that it shall not sell or rent users’ personal details to anyone. SPG Global will protect every bit of the users’ business or personal information and maintain the confidentiality of the same. With this seal of trust, SPG Global makes its services available to the users for assessment and analysis that include credit and behavior scoring, market and product analysis.

SPG Global guarantees that it is going to keep all information confidential except in the following cases:

• SPG Global may disclose users’ information to governmental and other statutory bodies who have appropriate authorization to access the same for any specific legal purposes.
• SPG Global may disclose users’ information if it is under a duty to do so in order to comply with any legal obligation, or in order to enforce or apply the Terms of Use (displayed on the website), or to protect the rights, property or safety of SPG Global, its users or others. This includes exchanging information with other companies / agencies that work for fraud prevention and credit reference.
• SPG Global may disclose users’ information to its agents under a strict code of confidentiality.
• SPG Global may disclose users’ information to such third parties to whom it transfers its rights and duties under the customer agreement entered into with the users. In such an event, the said third parties’ use of the information will be subject to such confidentiality obligations as contained in this Policy.
• SPG Global may disclose users’ information to any member of its related or group companies including its subsidiaries, its ultimate holding company and its subsidiaries, as the case may be.
• In the event that SPG Global sells or buys any business or assets, it may disclose the users’ information to the prospective seller or buyer of such business or assets. user, email and visitor information are generally one of the transferred business assets in these types of transactions. SPG Global may also transfer or assign such information in the course of corporate divestitures, mergers or dissolution.

RIGHT TO RECTIFICATION AND ERASURE

To opt out of email correspondence form SPG Global or make a change to (or delete) the user information stored in SPG Global’s records, please contact SPG Global at contact@SPG Global.com.

The user may address to:

SPG Global Commodities Limited
Address: A-18, Sector 64, Noida, Gautam Budh Nagar, Uttar Pradesh – 201301 India

SPG Global will respond to the user’s request within 30 days.

DATA PROTECTION OFFICER

SPG Global has designated Mr. Rahul Sharma, Chief Compliance Officer of the Company as the grievance officer in compliance with Rule 5(9) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. In case of any grievance regarding the use of your Information, please write at

Email: compliance@spggcl.com

Address: A-18, Sector 64, Noida, Gautam Budh Nagar, Uttar Pradesh – 201301 India

With all relevant details of your grievance. SPG Global will respond to all relevant user queries within 30 days.