1 Scope of this notice
This Privacy Notice describes how VerSe Innovation Private Limited (“we”, “us,” “our”) collects, uses and discloses information about individuals who use our website, applications, platforms, services, tools and features, or otherwise interact with us (collectively, the “Services”). For the purposes of this Privacy Notice, “you” and “your” means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Notice.
Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Services.
2 Changes to this notice
We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to how we use or disclose information we collect, we will use reasonable efforts to notify you (such as emailing you at the last email address you provided us or posting notice of such changes on the Services) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.
3 Collection of information
When you use or access the Services, we collect certain categories of information about you from a variety of sources.
Information you provide to us
Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:
- Basic contact details, such as name, address, phone number, and email.
- Account information, such as username, password, and security questions that you select and the answers you provide. If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately.
- Business contact information, such as your job title, business telephone number and email, and business mailing address.
- Surveys, we may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
- User-generated content, such as messages, photos, survey responses, comments, reviews, and recordings, submitted by you through the Services (“UGC”). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Others may also have access to UGC and may have the ability to share it with third parties. You understand that, even after removal, copies of UGC may remain viewable in cached and archived pages and may have been copied or stored by Internet archives and others. If you choose to submit UGC to any public area of the Services, your UGC will be considered “public” and will be accessible by anyone, including us.
- Conferences, trade shows, and other events, we may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
- Commercial information, such as products and services purchased and shipping information.
- Any other information you choose to include in communications with us, for example, when sending a message through the Services or submitting information about you via a form through the Services.
Information we collect automatically
We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, pixels, SDKs, web beacons/clear gif, and other geolocation tracking technologies (“Tracking Technologies”). Usage Data includes:
- Device information, such as device type, operating system, device ID, unique device identifier, screen resolution, media access control (MAC) address, and internet protocol (IP) address.
- Location information, such as approximate location based on IP address.
- Other information regarding your interaction with the Services, such as operating system, browser type, log data, date and time stamps, pages you access on the Services, websites you access before and after visiting the Services, length of time spent on the Services, clickstream data, and ad impressions.
For more information on how we use Tracking Technologies and your choices, see the section below, Cookies & Other Tracking Technologies.
Information collected from other sources
We may obtain information about you from outside sources, including information that we collect directly from third parties and information that you choose to have shared with us. Such third parties and information includes:
- Analytics providers. Information such as location, traffic, usage, and interaction data on the website that we receive from analytics providers such as HubSpot and Google Analytics.
- Referrals and sharing features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information about people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).
- Conferences, trade shows, and other events. We may collect personal information (or receive it from event organizers) when we attend or host conferences, trade shows, and other events.
- Marketing databases. Information we receive from consumer marketing databases or other data enrichment companies, such as name, address, title, email, and phone number.
- Advertising partners. Information such as Usage Data and Tracking Technologies (defined above) that we receive from advertising providers such as Google and LinkedIn.
Any information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third Party Websites, Links & Embedded Content.
4 Uses of information
With respect to the categories of information we collect, we use information about you as described below:
- Services and purpose collected; communication with you: For the purpose for which you disclosed and we collected information about you, for example, to process and communicate with you in connection with your use of the Services, to process, fulfill and ship your purchases and orders, to process warranty claims, to process return requests, to register your product, to process your requests for information, analyze and display UGC you provide, to administer your account (where applicable) and our business activities, to provide customer support to users of the Services.
- Personalization; advertising; analytics: To tailor the content and information that we may send or display to you, to suggest personalized help and instructions, and to personalize your experience while visiting or using our Services; sharing it with our third party service providers to understand how our Services are used and to improve the Services; so we and our third party service providers to target advertisements for goods and services and to display those advertisements on other websites. For more information, please see the Cookies & Other Tracking Technologies section below.
- Marketing communications: To send you marketing communications about our business, products, Services, and other programs that may be of interest to you. In order to provide you with a personalized experience, these communications may be tailored to your preferences based on, for example, inferences we make using your visits to the Services or the links you click on in our emails. Please note that pixel tags, cookies and other online trackers may be used within emails to track your interactions with those websites and when emails are opened.
- Evaluation and improvement: To analyze, develop, and improve the content, materials, products, and the Services; to inform marketing and communication plans; to understand user demographics and preferences; to analyze the effectiveness of the Services; and to evaluate user experiences (e.g., analyzing which features and portions of the Services are most popular; for troubleshooting, for statistical purposes).
- Quality assurance: To perform quality assurance; to assist with fraud identification, and to assist our customer relationship representatives (for example, through representatives in our call center), we use tools to monitor and record certain user experience information, including, without limitation, audio of customer service calls and information resulting from such calls.
- Lawful processes; protection of company: In accordance with and in response to regulatory authorities, courts with competent jurisdiction, valid law enforcement requests, governmental agency requests, emergency services, and other necessary third parties for legal, protection, security, and safety purposes (e.g., to protect the safety of our employees, agents, and customers, or any other person); to protect our rights or the rights of others, including to enforce our agreements, policies, and terms; to bring legal action; to protect our operations and assets.
- With your consent: With your consent, we may use and share information about you in ways not specifically described in this Privacy Notice.
We may deidentify information about you such that it cannot reasonably be used to infer information about you or otherwise be linked to you (or we may collect information that has already been deidentified), and we may use such deidentified information for any purpose. To the extent we possess or process any deidentified information, we will maintain and use such information in deidentified form and not attempt to re-identify the information, except solely for the purpose of determining whether our deidentification process satisfies legal requirements.
6 Disclosure of information
We may disclose information about you to third parties for legitimate purposes subject to this Privacy Notice, including the following categories of third parties:
- Affiliates: Our affiliates, subsidiaries, or others within our corporate group.
- Service providers: Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, website hosting, mailing, customer relationship management, marketing communications, web analytics, payment networks, and payment processing.
- Marketing providers: Third parties for marketing purposes.
- At your direction: Third parties to whom you request or direct us to disclose information, such as through your use of social media widgets or login integration.
- Advisors: Professional advisors, such as auditors, law firms, or accounting firms.
- Bankruptcy and other business transactions: Third parties in connection with or anticipation of an asset sale, merger, or other business transaction, including in the context of a bankruptcy.
We may also disclose information about you as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.
8 Third party websites, links & embedded content
We may provide links to third party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, in itself, imply any endorsement of the content on such platforms or of their owner or operators.
9 Children's privacy
Children under the age of 18 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 18 years of age.
10 Data security & retention
Despite our reasonable efforts to protect information about you, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.
Information you provide to us should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up to date. We retain information about you for as long as it is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain information about you, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or product.
11 California residents
This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “personal information” shall include “sensitive personal information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).
Processing of personal information
In the preceding 12 months, we have (i) collected the following categories of personal information about residents for the following purposes, and (ii) (where indicated below) disclosed for a business or commercial purpose (as identified below) to third parties the following categories of personal information:
| Category | Categories of purposes (defined in the Uses of Information section above) | Categories of recipients (defined in the Disclosure of Information section above) |
|---|---|---|
| Identifiers such as name, e-mail address, IP address | Services and purpose collected; communication with you Personalization; advertising; analytics Marketing communications Evaluation and improvement Quality assurance Lawful processes; protection of company With your consent |
Affiliates Service providers Marketing providers At your direction Advisors Bankruptcy and other business transactions |
| Commercial information such as records of products or services purchased | ||
| Internet or other similar network activity such as information regarding your interaction with the Services | ||
| Approximate geolocation data such as IP address | ||
| Audio, electronic, visual, thermal, olfactory, or similar information such as photographs, video recordings and voice recordings | ||
| Professional or employment-related information such as title of profession, employer, business contact information | ||
| Inferences drawn from other personal information |
We do not knowingly collect any categories of information considered “sensitive” under applicable law. The criteria we use to determine how long to retain personal information about you is described in the section above, Data Security & Retention.
Selling and/or sharing of personal information
We do not have actual knowledge that we “sell” or “share” (as those terms are defined under the CCPA and used throughout this section) personal information of residents under 16 years of age. However we do share certain categories of personal information for purposes of cross-contextual behavioral advertising, and, in the preceding 12 months, we have shared the categories of personal information about residents as noted in the table set forth in the Your Privacy Rights section below.
Right to know
In addition to those rights set forth in the Your Privacy Rights section below (as applicable), California law provides residents the right to request that a business that collects personal information about them disclose (1) the categories of personal information collected, disclosed, sold and/or shared; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collecting, selling, and/or sharing personal information; (4) the categories of third parties with whom we disclosed, sold, and/or shared personal information; and (5) the specific pieces of personal information we have collected about you. To exercise this right, use the methods set forth in the Exercise Your Rights section below.
Your California privacy rights
California’s Shine the Light law permits residents to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is shared with third parties for their direct marketing purposes. We do not consider our data processing activities to fall into the category of sharing personal information with third parties for their own direct marketing purposes. However, to the extent Shine the Light applies to our data processing activities, you can opt out of any such disclosures by (i) utilizing the Global Privacy Control as mentioned in the Do Not Track & Global Privacy Controls section above, or (ii) by clicking the “Your Privacy Choices” option in the footer of the website and changing your Cookie Settings as described on that webpage.
12 Your privacy rights
Some U.S. states (for example, California) provide certain rights and options to their residents.
Additional rights
Depending on the laws applicable to our processing of personal information about you and the location in which you reside, you may have the ability to exercise the rights listed below. Subject to the foregoing and all applicable limitations, exemptions, or exceptions, these rights may include the right to:
- Right to confirm: Confirm whether we process personal information about you.
- Right to know: Obtain a list of third parties to whom we’ve disclosed your personal information, or if we do not keep a specific list, a list of third parties we generally disclose personal information to.
- Right to data portability: Access and receive the specific personal information we process about you in a structured, commonly used and machine-readable format, and to transmit it to another entity where this is technically feasible.
- Right to delete: Delete personal information about you.
- Right to correct: Correct personal information about you.
- Right to opt out of selling, sharing, and/or targeted advertising: Opt out of (i) the sale of personal information about you; and/or (ii) the use of personal information about you for targeted advertising purposes. Exercise this right by using the Global Privacy Control as noted in the Do Not Track & Global Privacy Controls section above or via “Your Privacy Choices.”
- Right to no discrimination: Not be discriminated against due to your exercise of the rights provided under applicable law that are applicable to our processing of your personal information.
- Right to complain: To lodge a complaint with a government regulator (e.g., your state attorney general) or supervisory authority, in the jurisdiction that you reside in, if you consider that the collection or use of personal information about you violates this Privacy Notice or applicable law.
We do not use personal information about you in furtherance of automated profiling decisions that produce a legal or similarly significant effect. We do not discriminate against users for exercising the rights granted to them under applicable law and that are applicable to our processing of personal information. To exercise these rights, please see the Exercise Your Rights section below.
Selling and sharing
We do not sell your personal information as the concept of “selling” is traditionally understood as being the exchange of something for money. However, we share your personal information with third parties for the purpose of cross-contextual behavioral advertising purposes (e.g., targeted advertising). U.S. state data protection laws hold such disclosures and sharing to be considered “selling” or “sharing.” Therefore, you have the right to opt out of such activities. In the preceding 12 months, we have sold or shared the following categories of personal information with the following categories of third parties and for the following purposes:
| Category of personal information | Categories of purposes | Categories of recipients |
|---|---|---|
| Identifiers | Analytical and targeted advertising purposes (including, without limitation, cross-contextual behavioral advertising). | Analytics, marketing, advertising, and remarketing partners and service providers |
| Internet or other electronic network activity information |
You may have the right to opt out of the selling and targeted advertising as described herein. You may exercise this right to opt out by utilizing the Global Privacy Control as mentioned in the Do Not Track & Global Privacy Controls section above, or by clicking the “Your Privacy Choices” option in the footer of the website and changing your Cookie Settings as described on that webpage. If you have any questions, concerns, or would like more information on our ability to opt out, you can contact us by emailing: grievance.officer@sparkstation.ai
13 Exercise your rights
If this Privacy Notice expressly stated above that you have certain rights, or applicable law grants you certain rights as it relates to the Services and information we collect about you, you may exercise any of these rights by contacting us using the information provided below. You may submit a request to us by:
- Emailing: grievance.officer@sparkstation.ai
Or by following the opt out methods and processes identified above. For clarity, to exercise your rights to opt out of targeted advertising, or the “selling” or “sharing” of personal information about you, you must follow the instructions provided under the Your Privacy Rights section noted above.
Additionally, you may have the right to appeal our decision regarding a request related to these rights by contacting us using the information provided below. If the appeal is denied, you may submit a complaint to the applicable government regulator or authority in the jurisdiction in which you are located (for example, the state Attorney General in the state in which you reside).
When you submit a request or an appeal, we will limit our collection of information about you to only what is necessary to securely fulfil your request or process your appeal. Making a request or appeal does not require you to create an account with us.
To verify certain requests—for example, requests to know, delete, or correct—we may need to collect additional information to verify your identity and the request before providing a substantive response to the request.
Some jurisdictions, depending on your location, permit you to authorize an agent to make requests on your behalf to exercise your rights. If you have a registered agent to act on your behalf, we have the right to authenticate such agent’s authority to act.
14 How to contact us
Bengaluru, Karnataka, India
Email: grievance.officer@sparkstation.ai
If you have any questions about this Privacy Notice or our collection, use, or disclosure of information, please contact us via email at grievance.officer@sparkstation.ai.
7 Social features
Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to access our pages on third party platforms, and from there “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use information about you. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service; for more information, see the section below, Third Party Websites, Links & Embedded Content.