PRIVACY POLICY

Last updated August 5, 2020

This privacy policy (�Policy�) explains our policy regarding the collection, use, disclosure and transfer of your information by Spren ( referred to as the "Company"), which operates various application, websites, including sub-sites, platforms, applications, m-web platforms and other platforms (collectively referred to as �Application�) for delivery of information, products, offerings and content via any mobile or internet connected device or otherwise (collectively the "Services"). This Policy forms part and parcel of the Terms of Use and other terms on the Application(�Terms of Use�). Capitalized terms which have been used here but are undefined shall have the same meaning as attributed to them in the Terms of Use.

When you use our services, you�re trusting us with your information. We understand that this is a big responsibility and we work hard to protect your information and put you in control. This Privacy Policy is meant to help you understand what information we collect, why we collect it and how you can update, manage, export and delete your information

This Privacy Policy is applicable to persons who installs, browse or uses the Services (�User�). For the purpose of this Policy, wherever the context so requires "you" or "your" shall mean User and the term "we", "us", "our" shall mean Spren .

As we update, improve and expand the Services, this Policy may change, so please refer back to it periodically. By accessing and using the App , Sites or otherwise using the Services, you consent to collection, storage, and use of the personal information you provide (including any changes thereto as provided by you) for any of the Services that we provide.

We respects the privacy of the Users using the Services and is committed to protect it in all respects. The information about the User as collected by the Company is:

(a) information supplied by Users

(b) information automatically tracked while using services

(collectively referred to as "Information").

1. INFORMATION RECEIVED, COLLECTED AND STORED BY US

A. INFORMATION SUPPLIED BY USERS

Registration data:

When you register on the Sites for the Service, we ask that you to provide basic contact information such as your name, email address. When you register using your Gmail accounts, we shall retrieve Information from such account to continue to interact with you and to continue providing the Services.

The information provided by you during registration is only sent to Google for authentication and is only stored on your device and not stored on our servers.

B. INFORMATION AUTOMATICALLY COLLECTED/ TRACKED WHILE USING SERVICES

Spren App Configuration

During Application start after agreeing to our Terms and Conditions we get the latest rules and configuration from our servers for all the installed applications on the phone. This requires sending us the list of apps that are installed on the phone.This allows us to block promotional notifications and group chat notification from the user.

The App checks for the latest configuration from our servers once every 24 hours.

The list of application name sent by you is not stored or logged on our servers. No other user information including userid is sent during this.

Analytics services

We use Google Firebase and Analytics to track the user behaviour on our Application. Google Analytics specifically has been enabled to support gaining understanding of the usage patterns of the service and improving the service accordingly. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us.

Certain types of information is automatically collected via Google Firebase � this includes Mobile ad IDs, IDFVs/Android IDs, Instance IDs, and Analytics App Instance IDs. Additionally we take Channel Name, Package Name of the App of the Notification that was received by our user.

Channel Name, Package Name helps us to improve the blocking promotional and group chat notifications functionality of the app.

Google Analytics Data Retention Policy

All data collected in the Google Analytics platform is stored for 90 days and deleted after that.

c) Information collected voluntarily- Help Us Improve - Spren Improvement Program

The User during "Sign up" or by going to the App settings -> "HELP US IMPROVE" section can agree or disagree to signing up to the "Spren Improvement Program".

The user by agreeing to participate in "Spren Improvement Program" allows the Application to send us anonymous data along with Notifications text to our servers for below mentioned categories which are enabled by default but can be changed by the user at any time.

Promotional Formats
OTP Formats
Transaction Formats
Order formats
Appointment formats
Trip Alert formats
Bill formats

The user at all time while using the App can withdraw from the "Spren Improvement Program" by going to the Settings - > Help us Improve section of the application and unchecking the agreement to send data anonymously.

The user at all time while using the App can change the categories that they want to share by going to the Settings -> Help us Improve section of the application and unchecking the formats that they dont want to send us.

Any Changes done to the above configuration would reflect instantly or after next app start

The User can also manually report individual notification as Promotional format, Otp format, transaction format, Order Formats, Bill Formats, Trip alert formats, Content Promotional formats by clicking on the notification details options available inside the application. The Full List of options will always be shown to the user before sending.

Obfiscation

All The data sent through sections "Analytics Services", "Help us Improve" from app removes all PII information like name, email, phone , account details, Balance etc and makes all data anonymous before sending it to us.

For Example Notification with text as

"Dear John, Your Order no is 123456"

before sending it to us becomes

"Dear [name], Your Order no is {num}{num}{num}{num}{num}{num}".

INTERACTION / LINKS TO THIRD PARTY APPLICATION

The Service during use contains links ( Notifications ) to other application that have been installed on the device by the user. The privacy policy of these applications may differ from ours. If you can't find the privacy policy of any of these applications via a link from the application's homepage, you should contact the application owners directly for more information.

INFORMATION USE BY THE COMPANY

The information as supplied by the users enables us to improve the Services and provide you the most user-friendly experience. We may use your email address for administrative purposes.

4. INFORMATION SHARING

We do not provide or share any data / information / reports to third party websites / advertisers / ad-servers /third party company or individuals.

5. ACCESSING AND UPDATING USER INFORMATION

When you use the Services or Sites (or any of its sub sites), all user information like notification data, preferences, settings are stored on the phone and during backup is stored on the users Google Drive. Any changes to such information are only possible by using the app.

Since no user data (notification data, preferences, settings) is stored on our cloud servers we cannot be requested to make the change on your behalf.

6. INFORMATION SECURITY

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store user data. All information gathered on Spren is securely stored within the Company controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.

7. UPDATES / CHANGES

The internet is an ever-evolving medium. We may alter our Policy from time to time to incorporate necessary changes in technology, applicable law or any other variant. In any case, we reserve the right to change (at any point of time) the terms of this Policy or the Terms of Use. Any changes we make will be effective immediately on notice, which we may give by posting the new policy on the Spren App, Google Playstore, our website. Your use of the Sites or Services after such notice will be deemed acceptance of such changes. We may also make reasonable efforts to inform you via email if provided by you. In any case, you are advised to review this Policy periodically on the sites to ensure that you are aware of the latest version.

8. QUESTIONS / GRIEVANCE REDRESSAL

Redressal Mechanism: Any complaints, abuse or concerns with regards to the use, processing and disclosure of Information provided by us can be reported to the designated Grievance Officers by emailing the grievance to spren.dev@gmail.com

We request you to please provide the following information in your complaint:-

a) Identification of the information provided by you;

b) Clear statement as to whether the information is personal information or sensitive personal information;

c) Your e-mail address;

d) A statement that you have a good-faith belief that the information has been processed incorrectly or disclosed without authorization, as the case may be;

e) A statement, under penalty of perjury, that the information in the notice is accurate, and that the information being complained about belongs to you;

f) You may also contact us in case you have any questions / suggestions about the Policy using the contact information mentioned above.

We may reach out to you to confirm or discuss certain details about your complaint and issues raised.

The Company shall not be responsible for any communication, if addressed, to any non-designated person in this regard.

9) Permissions Explained

Storage
The App requests permission to access the phone's storage only in order to store the notifications and related media. The App does not access any other files outside its own directory

Notification Access

The App requests Notification access permission to manage notifications on your behalf.

Battery Optimization

The App request Battery Optimization permission so that android doesnt kill the Application Process which would not allow us to manage the notifications on your behalf.