This Policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any sensitive and/or personal information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy, which describes how your personal and sensitive information is protected both electronically and physically.
In general, and as described in detail below, we collect several types of information from you, such as:
- Personal information required to verify your identity;
- Demographic information such as postcode, preferences and interests;
- Information regarding credit ratings, which may also be received from referral sources;
- Optional personal information you may wish to share in the furtherance of your goals in using our website;
- Information about your visits to and use of this website to help us maintain the appropriate features, functionality and user experience.
Spark works with a number of trusted partners that perform vital functions as part of our operations, including ASSCCL. Our partners are legally required to keep your information private and secure. You accept this Policy when you sign up for or use our products, services or any other features, technologies or functionalities offered by us on our website or through any other means (collectively the “Services”). Information We Collect From You and About You
We collect personal and financial information from you while you use the website, and most of this collection occurs during registration. Some information is required and some is optional, some will remain private and some will be displayed to other users. We always let you know which is which. Additional information may be gathered during your subsequent use of the website, whenever you choose to provide it.
Certain personal information must be supplied during the member registration processes, as indicated below, in order to, (a) enable registered users to login to the site; (b) determine eligibility for Services; (c) verify identities; (d) guard against potential fraud. This basic personal information includes:
- Your name;
- Your e-mail address;
- Your date of birth;
- Your home address and telephone number;
- Your Aadhaar card details;
- Your Permanent Account Number and Bank Account Information;
- Your Net Banking / Credit or Debit Card Information.
We will also use your required and optional information to facilitate activities and transactions that need to occur during your utilisation of Services, such as:
- Generating user profiles on the website and/or Spark;
- Assigning you a user credit grade based on your credit history, financial circumstances;
- Contacting you if there is a problem in processing the transaction you have opted for, or to discuss a problem with your account;
- Maintaining regular communications with you concerning transactions you initiate, such as requesting information or assistance, submitting an assurance request, making payments, transferring funds, etc.;
- Your Aadhaar card details;
- Your Permanent Account Number and Bank Account Information;
- Allowing you to add new bank account information and save to your online profile;
- Enabling our financial services partners to implement fund transfers and the receipt of beneficiary payments;
- Contacting you if there is a problem completing a transaction you have requested, or to discuss a problem with your account;
- Maintaining regular communications with you as may be necessary to execute transactions you request, such as submitting credit portfolios and transferring funds, etc.;
- To contact you for market research purposes, in an effort to improve Services and customize our website in accordance with your interests;
- To provide information to our partners for marketing and promotional purposes.
Communications from Us
When you register with Us, You may receive e-mails, SMS’s and OTP authorization that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of e-mail addresses and bank accounts, and confirmation of successful submissions of user requests. You will also receive progress updates on the status of your requests and submitted portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We will also send you responses to any e-mails you send us. From time to time, we will also send user surveys and requests for user feedback regarding user experience and site operations. The completion of these surveys or requests for feedback is strictly voluntary. If you do not wish to receive these surveys or user feedback e-mails, you may opt out by writing to firstname.lastname@example.org, or by following the unsubscribe instructions located at the bottom of each e-mail communication. We will send you e-mail notifications from time to time, and these are required elements of your transactions on our website, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status, such as when you are confirmed as a user of Services, or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that no one can make a change to your account without your knowledge, such as confirming the addition of a new e-mail address or linked external bank account. These notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or site policies. Generally, you may not opt out of these service related e-mails.
When you register with Us, we may ask you for your employer’s name and phone number. Spark stores this information for the sole purpose of verifying your employment.
Your employer may contact us at email@example.com to request that we remove this information from our database. How Long Will My Information Be Stored? We will retain your information for as long as your account is active, or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at firstname.lastname@example.org. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. How and When Your Information is Shared With Other Parties
We do not sell, share, rent, or trade your personal information with third parties other than as disclosed herein. Information is shared with other parties in the following ways:
- Required information (such as name, address and e-mail address) and optional information about users is displayed on profiles that you can update at any time. Certain information is optional (such as additional phone number) and you can choose not to supply it and/or can remove the optional information at any time;
- Information (such as gross income, length of employment);
- Financial and credit information about users is displayed to qualified investors on assurance listing pages;
- Information is shared directly between users and other or potential users (who are only able to view assurance postings but do not have access to the full loan listings);
- Information shared directly by users might contain personal information (such as name and e-mail address);
- Information may be shared with collection agencies and/or service providers, but only if they are contractually obligated to keep such information confidential.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personal information when we believe that disclosure is reasonably necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website.
We work with a number of trusted partners that perform vital functions as part of our operations, including but not limited to e-sign providers, credit bureaus, collection agencies, data and background verification agencies and electronic payment service providers with whom personal information is shared only to the extent necessary for us to process the transactions you initiate or perform other specific services with our partners legally mandated to keep your information private and secure.
These third parties are prohibited from using your personal information for promotional purposes but are authorized to use your personal information only as necessary to provide these services to us. We may also disclose your personal information if We are involved in a merger, acquisition, or sale of all or portion of its assets, you will be notified via e-mail and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Sharing Your Information with Trusted Third Parties With your express consent we will share your information with our trusted third parties from whom you wish to avail of any products or services offered through the Spark application (“Trusted Third Party”). In the circumstance you would wish to procure or avail of any such services or products offered by a Trusted Third Party, including but not limited to account creation, payment or other related processes with such Trusted Third Party, you will expressly consent to ASSCCL sharing your data (including but not limited to your KYC information and documents) with such Trusted Third Party/ies as may be required.
You further understand that the sharing of such information will take place at such time you intend to avail of a service or product offered by a Trusted Third Party and that ASSCCL will not be liable for any and all breaches, leaks, loss or damage caused by the use of, or failure to protect your information by such Trusted Third Party. Any and all such liability will rest solely with the Trusted Third Party.
Where You Can Find and/or Correct Your Information You can access all of your personal information that we collect online and maintain by visiting your profile at www.assccl.com. This section of the site is password-protected to better safeguard your information. As a registered user, you can correct, update, amend your password, e-mail address, physical address, phone number at any time on the website. Further, in the event that you need to modify your bank account information disclosed to Spark or change any other information in your profile, you may do so by contacting us at email@example.com. You may also ask to have your personal information deleted/removed from a public forum on our site and make changes to sensitive account information in order to protect your privacy and security by contacting us at firstname.lastname@example.org. We will respond to your access request within 30 days.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, and particularly to prevent you from identity theft.
Some of our pages utilize framing techniques to serve content to from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to ASSCCL. Links to Other Sites
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at email@example.com.
Spark takes strong steps to safeguard your personal information through vigorous physical, electronic and operational policies and practices. All data is considered highly confidential. Data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls (there is no direct communication allowed between the database server and the Internet) and servers with hardened operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.
We also employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.
Protection of Account Numbers
When we contact you about your account to confirm a funds transfer, we only reference the last four digits of your bank account number; this is done for your protection so that you will recognize the source or destination account as one which you own. Further, we employ strict access standards ensuring that only the senior-most employees or partner representatives have access to your account numbers provided by you to ASSCCL, and other sensitive information. This access is only granted in order to complete transactions which you request or to provide regular ongoing service to your account.
We require the use of numbers in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password as a means of identifying yourself. You should never share your password with anyone, and if you ever receive an e-mail purporting to come from Spark that asks for your password, you should immediately report this development at firstname.lastname@example.org.
What You Can Do
In addition to our own substantial efforts, you can take several precautions to protect the security of your computer and personal information. For instance, you can start by using a well-chosen password. You should avoid using any information that others can easily learn about you, such as a family member’s name or birthday, and you can also use special characters in place of letters. We also recommend that you change your password frequently. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our site, be sure that you log out and close the browser window.
To protect your account, we send automatic notifications confirming certain actions taken on your account, such as changes to a password or external linked account. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered through these notifications can be undermined if other people have access to your e-mail account. Therefore, you might consider restricting access to the e-mail account you registered with on this site and/or changing your password on that e-mail account frequently.
If you use a computer that is accessed by other people, such as in a public library or Internet cafe, we recommend that you take special precautions to protect the security of your account and personal data. When you are finished using our site, you should log out completely, then close the browser window and clear the browser’s cache files.
You may contact us at: [email@example.com]