Privacy Policy

    Last updated: September 1, 2025

    Introduction

    Spharaka Networks Private Limited ("Spharaka" or the "Company") respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from the user ("you" or "customer") or that you may provide when you use the Spharaka platform or software - SaaS (Software as a Service) ("the Software"), and our practices for collecting, storing, using, maintaining, protecting and disclosing that information. This Privacy Policy is binding on all users of our Software, and your use of the Software constitutes your acceptance of this Privacy Policy. If you have any questions about this Policy, please use the contact information at the end of the policy.

    This policy applies to information we collect:

    • From the online registration you may have completed when you subscribed for the Software.
    • Through your use of the Software (including search queries input by you and results generated by the Software).
    • Regarding the computing environment by which you access the Software.
    • From the relevant individuals or their employers, credit card issuers, clearinghouses, data brokers, fraud databases, referrals from customers and users, as well as publicly available sources such as company websites.
    • Through cookies, web beacons, and other tracking technologies that may be deployed on our Software.

    Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By using the Software, you agree to this privacy policy. This policy may change from time to time (see "Changes to Spharaka Privacy Policy" below). Your continued use of the Software after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. Search results generated by our Software may contain links to sites not maintained by Spharaka. This privacy policy does not reflect the privacy practices of those sites.

    Corporate customers

    Spharaka's Software may only be used and accessed by authorized users employed by or affiliated with corporate customers and government entities (each, a customer) that have completed the online registration process, accepted Spharaka End User License Agreement (EULA) and been approved for access following Spharaka's review of the information input by the customer during the online registration process.

    Customers are responsible for ensuring that their authorized users comply with this Privacy Policy and the EULA. Customers may be held liable for any violations committed by their authorized users.

    Children under the age of 16

    The Software is not intended for access or use by, and we do not knowingly collect personal data from, children under 16 years of age. If you are under 16 years of age, do not access, use or provide any information or complete the online registration process for the Software, or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or username you may use. If we learn we have collected or received personal data from a child under 16 years of age, we will delete that information. If you believe we might have any information from or about a child under 16 years of age, please use the contact information at the end of the policy.

    Information we collect about customers and how we collect it

    We collect several types of information from and about customers who access the Software, including information:

    • By which the customer or its employees may be personally identified, such as name, postal address, e-mail address, domain name, telephone number, credit card number, employer identification number or any other information input as part of the online registration process or which the Software collects during customer use that is defined as personal or personally identifiable information under applicable laws.
    • Regarding a customer's use of the Software, including browsing activity, search queries and results.
    • About the computing environment a customer uses to access the Software.
    • Location data, including precise geolocation data when permitted by applicable laws and with your consent where required.
    • Device identifiers, including IP addresses, MAC addresses, and other unique identifiers.

    How do we collect this information:

    • Directly from a customer when provided to us as part of the online registration process or through Spharaka's personnel via the Customer assisted registration process.
    • Automatically as the customer uses the Software (including usage details, IP addresses and other information obtained through tracking technologies).
    • Directly from the relevant individuals or their employers, credit card issuers, clearinghouses, data brokers, fraud databases, referrals from customers and users, as well as publicly available sources such as company websites.
    • Through cookies, web beacons, pixel tags, and other tracking technologies deployed on our Software.

    Information a customer provides to Spharaka

    The information we collect from a customer includes:

    • Information that a customer provides when registering the Software.
    • Records and copies of a customer's correspondence (including e-mail addresses) with us.
    • A customer's search queries and results generated by the Software in response to those searches.
    • Information gathered when a customer reports a problem for troubleshooting while accessing using the Software.
    • Information gathered when a customer interacts with Spharaka's personnel for any other purpose, including reporting a problem with or difficulty using the Software.
    • Payment information, including credit card numbers, billing addresses, and other financial information necessary for processing payments.

    Information we collect automatically based on automatic data collection technologies

    As you use the Software, we may use automatic data collection technologies to collect certain information about your computing environment, browsing activity and patterns, including:

    • Details of your use of the Software, including which portions of the Software you access, usage patterns related to your access of the Software, information regarding referring websites or search engines, traffic data, location data, logs and other communication data and the resources that you access through the Software.
    • Information about your computing environment and internet connection, including, among other things, your IP address, operating system, browser information, software, hardware and geographical location.
    • Information about your device, including device type, model, manufacturer, unique device identifiers, and mobile network information.
    • Performance data and crash analytics to improve our Software.

    We do not collect personal data through these automatic data collection technologies, but we may tie this information to personal data about you that we collect from other sources, or you provide to us.

    Lawful Bases of Processing Your Personal Data

    We process your Personal Data by relying on one or more of the following lawful bases:

    • You have explicitly agreed to/consented to us processing your Personal Data for a specific reason
    • The processing is necessary for the performance of the contract we have with you or to take steps to enter a contract with you
    • The processing is necessary for compliance with a legal obligation we have
    • The processing is necessary for the purposes of a legitimate interest pursued by us
    • The processing is necessary to protect the vital interests of the data subject or another person
    • The processing is necessary for the performance of a task carried out in the public interest

    Where the processing is based on your consent, you have the right to withdraw your consent at any point in time. However, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

    How we use a customer's information

    We use information that we collect about a customer or that a customer provides to us, including any personal data:

    • To provide the customer with information, products or services that the customer may request from us.
    • To fulfil any other purpose for which a customer provides it.
    • To provide a customer with notices about its account, including expiration and renewal notices.
    • To verify compliance with the terms of the EULA and any other terms governing a customer's use of the Software.
    • To carry out our obligations and enforce its rights under the EULA and any other contracts entered between the customer and Spharaka, and as required by applicable law.
    • To notify the customer about changes to the Software or any other products or services Spharaka offers or provides.
    • To improve the performance of the Software.
    • In any other way that Spharaka may describe when a customer provides the information.
    • For any other purpose with the customer's consent.
    • To analyze usage patterns, trends, and preferences to improve the Software and user experience.
    • To detect, investigate, and prevent security incidents, fraudulent transactions, and other illegal activities.
    • To develop new products, services, features, and functionality.
    • For marketing and promotional purposes, including to inform you about our products and services, subject to applicable laws and with your consent where required.

    Cross-Border Data Transfer

    Personal Data we hold about you may be transferred to other countries outside your residential country for any of the purposes described in this Privacy Notice. Such transfers may include transfers to countries that may not provide the same level of data protection as your country of residence.

    Any personal data that we transfer will be protected in accordance with this Privacy Notice as well as with adequate protections in place in compliance with applicable privacy laws. We implement appropriate safeguards, such as standard contractual clauses approved by relevant authorities, to ensure that your Personal Data receives an adequate level of protection in the countries where it is processed.

    Please note that these countries may have differing (and potentially less stringent) privacy laws, and that Personal Data can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, because of applicable governmental or regulatory inquiry, court order or other similar process.

    By using our Software and providing your Personal Data, you consent to such cross-border transfers of your Personal Data as described in this section.

    Disclosure of customer information

    We may disclose aggregated information about our customers, and information that does not identify any customer, without restriction. Such aggregated information may be used for any purpose, including for commercial and marketing purposes.

    We may disclose personal data that we collect, or you provide as described in this privacy policy:

    • To our customers, subsidiaries and affiliates.
    • To contractors, service providers and other third parties we use to support our business.
    • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all the Spharaka assets, whether as an ongoing concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by us about our customers is among the assets transferred.
    • To fulfil the purpose for which you provide the personal data.
    • With your consent.
    • To our business partners and third-party marketing partners with your consent where required by applicable law.

    We may also disclose your personal data:

    • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
    • To enforce or apply the terms of our EULA and other agreements, including for billing and collection purposes.
    • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Software, our customers or others.
    • To detect, prevent, or otherwise address fraud, security, or technical issues.
    • In connection with an investigation of suspected or actual illegal activity.

    Data security

    We have implemented reasonable measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration and disclosure. However, no method of transmission over the Internet or method of electronic storage is 100% secure.

    All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions, submission of any login credentials or any other sensitive data will be encrypted using the TLS/SSL protocol(s). We regularly review our security procedures and consider appropriate new security technologies and methods.

    The safety and security of your information also depends on you. You are responsible for keeping all usernames and passwords necessary to access the Software confidential. We strongly recommend using strong, unique passwords and enabling two-factor authentication where available.

    Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted through the Software. Any transmission of personal data is at your own risk.

    We are not responsible for circumvention of any privacy settings or security measures contained on the Software. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us using the contact information provided at the end of this policy.

    How Long Do We Keep Your Personal Data?

    We keep the Personal Data we collect about you for as long as it is required (usually 30 days) for the purposes set out in this Privacy Policy and for legal or regulatory reasons. The exact period will depend on the purpose for which we collect and use the data, including our obligations under applicable laws, contracts, and our legitimate interests.

    We take reasonable steps to delete or permanently de-identify your Personal Data that is no longer needed. However, we may retain certain information as required by law or for legitimate business purposes, including for accounting, audit, and compliance purposes.

    Your Privacy Rights

    Subject to applicable law, you may have the following rights regarding your Personal Data:

    • Right of Access: You have the right to get access to your Personal Data that is with us along with other supporting information.
    • Right to Rectification: You have the right to ask us to rectify your Personal Data that is with us that you think is inaccurate. You also have the right to ask us to complete your Personal Data that you think is incomplete.
    • Right to Erasure: You have the right to ask us to erase your Personal Data that is with us under certain circumstances.
    • Right to Restriction of Processing: You have the right to ask us to restrict the processing of your Personal Data under certain circumstances.
    • Right to Data Portability: You have the right to ask that we transfer the Personal Data you gave us to another organisation, or to you, under certain circumstances.
    • Right to Object: You have the right to object to the processing of your Personal Data under certain circumstances.
    • Right to not be subjected to Automated individual decision-making, including profiling
    • Right to withdraw consent if consent was taken while collecting personal data
    • Right to lodge a complaint with the Supervisory Authority: You have the right to lodge a complaint with a supervisory authority.

    Please note that these rights are not absolute and may be subject to limitations as provided by law. We may require specific information from you to help us confirm your identity and process your request. Applicable law may permit or require us to decline your request. If we decline your request, we will inform you of the reasons, subject to legal restrictions.

    If you wish to make a request to exercise any of your rights, you can contact us using the details in the 'Contact information' section of this notice. We will respond to your request within the timeframe required by applicable law.

    Changes to Spharaka privacy policy

    It is Spharaka policy to post any changes we make to our privacy policy on this page. The date the privacy policy was last revised on September 1, 2025. You are responsible for periodically reviewing this privacy policy to check for any changes.

    We may provide additional notice of significant changes through the Software or by sending you an email notification. Your continued use of our Software after any modification to this Privacy Policy will constitute your acceptance of such modification.

    Contact information

    For any further queries and complaints related to privacy or exercising your rights, you could reach us at: [email protected]

    Address: Registered office: MIG-5, 1st floor, KPHB Colony, Hyderabad, Telangana-500072

    Please allow up to 30 days for a response to your privacy-related inquiries.