Privacy Policy

Kestrels Services Pvt. Ltd. (“us”, “we”, or “Spoint”) is the author and publisher of the internet resource (“Website and Application”) on the world wide web as well as the application provided by Spoint, including but not limited to the software and applications of the brand names ‘Spoint’, referred to as the “Services”).


Your privacy is important to us, at Spoint. So we’ve developed a privacy policy to explain how we collect, use, share, and protect personal information about the Users of the Services, and the visitors of Website (jointly and severally referred to as “you” or “Users” in this Privacy Policy).  This Privacy Policy has been created to demonstrate our effort and commitment to the protection of your privacy and your personal information. Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms and Conditions. We encourage you to familiarize yourself with our policies and let us know if you have any questions. The Privacy Policy is in compliance with GDPR policies, though the same at this present time apply only to EU member countries’ citizens and use of their personal data.


Spoint offers a technology platform on and Mobile Application.


By accepting this Privacy Policy, you admit that Spoint won’t be responsible for the use of the Website and application in any way, by any user which might seem to be Defamatory to anyone.

At Spoint, we value your concerns about privacy & security while browsing our Website. We make every effort to guarantee that the information you provide will not be misused. If for some reason the following privacy and security policy does not answer your questions, please contact us. We value your feedback and look forward to improving our services to better meet your needs. By using the Website’s services, you agree to the provisions of this policy.


Our goal in this policy is to be completely transparent about the data we collect, why we collect it, and how we use it, in order to make your experiences of browsing and using our services on this Website valuable.


By confirming that you are bound by this privacy policy (by the means provided on this Website), by using the services or by otherwise giving us your information, you agree to the practices and policies outlined in this privacy policy and you hereby consent to our collection, use and sharing of your information as described in this privacy policy. We reserve the right to limit the usage of the Website and application to just viewing. We reserve the right to change, modify, add or delete portions of the terms of this privacy policy, at our sole discretion, at any time. If you use the services on behalf of someone else or an entity, you represent that you are authorized by such individual or entity to accept this privacy policy on such individual’s or entity’s behalf.


If you do not agree with this privacy policy at any time, kindly do not divulge any personal information nor utilize any of the services provided by us. However, if you do wish to comply with the policy so as to avail our services; all Personal Information that you provide to us when registering communicating through the Website or app that you otherwise provide on the Website or by phone, online chat, email or postal mail, will be stored by us, regardless of whether you are a Site Visitor or a Registered User. You represent and warrant to us that you have the right and authority to provide us all Personal Information you provide about yourself or others.


The Website and application is not responsible for User Content, the quality, the truth or accuracy of the listings and the Website makes no representations about any User Content on the Website. The Website and Mobile application reserves the right in its sole discretion to remove User Content or other material from the Website from time to time, Website does not assume any obligation to do so and to the extent permitted by law, disclaims any liability for failing to take any such action.


In no event shall the Website be liable to you or any user on account of any use, misuse or reliance on the Website for any damages whatsoever, including direct, special, punitive, indirect , consequential or incidental damages or damages for loss of profits, revenue, use, or data whether brought in warranty, contract, intellectual property infringement, tort (including negligence) or other theory, even if Spoint is aware of or have been advised of the possibility of such damage, arising out of or connected with the use (or inability to use) or performance of the Website. We do not assume any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, content, product, services or processes disclosed on the Website or any other material or information accessible from the Website.


The foregoing limitations shall apply notwithstanding any failure of the essential purpose of any limited remedy and to the fullest extent permitted under applicable law.

What information does the Website access?

As a general rule, this Website and Mobile application does not collect Personal Information about you when you visit the Website. You can generally visit the Website without revealing Personal Information, unless you yourself choose to provide such information.

This Website and application records technical and behavioural information which includes your visits, current location and logs of route travelled daily, check-ins of commercial places or places of interest and the following information for statistical purposes -your server’s address; the name of top-level domain from which you access the Internet (for example, .gov, .com, .in, etc.); the type of browser you use; the date and time you access the Website; the pages you have accessed; the documents downloaded and the previous Internet address from which you linked directly to the Website.

To create an account on the Website and Mobile application, you must provide us with at least your name, email address and/or mobile number, date of birth, and access permission to login through your Google or Facebook account and agree to our Terms and Conditions and this Privacy Policy, which governs how we treat your information. You understand that, by creating an account, we and others will be able to identify you by your App profile. However, we will not be liable under any circumstance for the generation of your profile or the information you provide therein. Spoint will also not be liable for the photographs that the Users might upload, the use and misuse thereof. 

When you use the Website you provide us with your IP address. We may use cookies or similar electronic tools/technologies to store this information. We may store a cookie on your computer which in turn would store information about your geographical location or we may have your location tracked to share with you other users with whom you may wish to share.

We may use cookies to automatically collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform, improve our services, and provide you with targeted advertising on the Platform and elsewhere across your different devices.

Additionally, we allow our business partners, advertising networks, and other advertising vendors and service providers (including analytics vendors and service providers) to collect information about your online activities through Cookies. We link your contact or subscriber information with your activity on our Platform across all your devices, using your email or other log-in or device information. These third parties may use this information to display advertisements on our Platform and elsewhere online tailored to your interests, preferences, and characteristics. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

The cookie stored on your computer may be refreshed once every month so that the information stored in the cookie is the latest and most relevant to you. We retain the right to bust the cookie (forcibly reset the cookie) before the expiry of one month from the date of last refresh for any technical reasons. However, any such cookie bust will not target any specific user and will apply to all the users of the Website.

All the information that you shall provide us is voluntary, including sensitive personal information. You understand that Spoint may use certain information of yours, which has been designated as ‘sensitive personal data or information’ under the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 for the purpose of providing you the Services and for sharing the information only with affiliates who are subject to this policy, as will be explained further below.

Does the Website share my information with companies/third parties/government agencies?

We respect that you do not want your personal information shared with other companies and therefore we are not in the business of selling it to others. We share information only as described below and with our group and affiliates who are subject to this privacy policy.


  • Third party advertisers;


  • Third party service providers: We may employ other companies and individuals, payment gateways to perform functions on our behalf. Examples include delivering e-mail, online chats, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links) and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Policy and as permitted by the applicable law.


  • Service Transfers: As we continue to develop our services, we might sell or buy business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the customer consents otherwise).


  • Protection of Website: We release personal information when we believe, release is appropriate to comply with the law; enforce or apply our Terms and Conditions of Use and other agreements; or protect the rights, property or safety of our App, our users or others. This includes exchanging information with other, government or regulatory authorities for fraud protection and credit risk reduction or as it may be necessary for due compliances or as per the requirement of the applicable law for the time being in force. Obviously, however, this does not include selling, renting, sharing or otherwise disclosing personally identifiable information from customers for commercial purposes in a way that is contrary to the commitments made in this Privacy Policy.
  • Business Partners
  • If you choose to register on the Platform using your social network account details (e.g., Facebook, Google, Apple account), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with your social network such as your app ID, access token and the referring URL.

How long do we keep hold of your information?

We retain your information for as long as it is necessary to provide you with the service. We may also retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data.

The security of your personal data.

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.



We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

Data protection principles

Data Minimization

The company keeps only the absolutely required personal data for processing. This means that no data other than what is adequate, relevant and necessary is either requested or stored.


The personal data shall either be anonymous, consented or where there is a clear legitimate processing purpose to retain the same.

Confidentiality of processing

Any unauthorized collection, processing or use of personal data is prohibited. The company applies the ‘need to know’ principle. The access to personal data shall only be limited to the task in question.


The company keeping in mind the confidentiality has carefully implemented the roles and responsibilities to the employees.


As provided by GDPR, pseudonymisation is implemented by the company, whereby data is stored to transform personal data in such a manner that the resulting data cannot be attributed to a specific data subject without the use of additional information.

Data protection control

The company is compliant with applicable data protection laws (GDPR) for EU member citizens. The compliance is done with regular data protection audits and proper documentation. The responsible data protection authority can perform its own controls of compliance with the regulations of this Policy, as permitted under national law.

Link to third party sites

At times, the Website may provide links to other websites, which we believe may be of interest to you. We are not responsible for the content or services on these Website, and if you choose to explore these links we suggest you review their privacy policies. Spoint cannot guarantee that these links will work all the time and have no control over availability of linked pages. However prior permission is required before hyperlinks are directed from any website/portal to this Website. If a hyperlink is to be placed on your website/portal we encourage you to place a hyperlink to on your website/portal for direct access to this Website.


As per our Privacy Policy, no prior permission is required to link from your website/mobile application, however, it is not permitted to load Website pages within the frame of your website/portal.


We will share all information we collect from you, including the personal information with any third party if we in good faith believe it is required for the purposes of our compliance with any applicable law, regulation, legal process or enforceable governmental request/ action or any manner required for the purposes of protecting our rights or interests. Third party websites and advertisers or internet advertising companies working on their behalf, sometimes use technology to send or serve advertisements similar to the services that appear on our Website directly to your browser. They automatically receive your IP address based on your browsing history. They may also use cookies, JavaScript, web beacons and other technologies to measure the effectiveness of their advertisements and to personalize advertising content. Please be advised that we do not have access to or control over cookies or other features that they may use, and the information practices of these advertisers and third party websites are not covered by this Privacy Policy. Therefore, we are not responsible for the information or content they may contain, nor are we responsible for the privacy practices employed therein. Please contact them directly for more information about their privacy policies. This Policy applies solely to information collected by us. We encourage our users to read the privacy policies of these other web sites before proceeding to use them.



Any personal information will be used to allow you to login to your account or to resolve specific service issues, inform you of our new services or features, or for helpline verification, or to communicate with you in relation to your use of the Website/Application. Any other information we collect will be used for-


  1. Our business purposes and this may include the viewing or advertising of services or relating to any associated services;
  2. Analytical purposes, data usage;
  3. Sharing location with friends/other users;
  4. Improving the Website or Application, or your user experience; and
  5. Providing targeted advertisements to you.



For those customers who have registered for the mailing list, their personal information is kept until we are notified that they no longer want their information stored.


Persons who supply us with their profile on-line may receive communication from us via emails, pertaining exclusively to new products and services or any upcoming events. In order to provide and improve our services and to share relevant ads with you, we may use and disclose to our advertising and analytics partners non-personally identifiable information that we collect, including cookie data, some log data, and mobile data.


This Website complies fully with all the applicable and relevant laws of India. We have always cooperated with all law enforcement inquires. We may disclose all or part of your personal details in response to a request from the law enforcement authorities or in a case of bona fide requirement to prevent an imminent breach of the law.

General Matters

The Accuracy and Confidentiality of Your Account Information is Your Responsibility: You are responsible for maintaining the secrecy and accuracy of your email address and other account information at all times. We are not responsible for personal data transmitted to a third party as a result of an incorrect email address.


Confidentiality and Security: We use commercially reasonable security measures to protect the loss, misuse, and alteration of the information under our control. However, we cannot absolutely guarantee the protection of any information shared with us.


Policy Changes: Our Services are a dynamic, innovative environment, which means we are always seeking to improve the Services we offer you. We often introduce new features, some of which may result in the collection of new information and so we may update this privacy policy to reflect changes to our information practices. If we make any change in how we use your personal information we will notify you by means of a notice on this Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Spoint makes all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds all such employees to strict confidentiality obligations Notwithstanding the above, Spoint is not responsible for the confidentiality, security or distribution of your personal information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, Spoint shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of Spoint including, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.


Questions and Suggestions: If you have any questions or suggestions or wish to make a complaint you can write to us on the Contact page of the website.

Lead Supervising Authority

Spoint has appointed Ashish Dhanani as the person with responsibility for data protection compliance within the organisation. He can be contacted at Questions about this policy, or requests for further information, should be directed to him

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