SPOTDRAFT
PRIVACY NOTICE
Last updated: July 14, 2026
Draftspotting Technologies Private Limited and its subsidiaries, including Draftspotting Inc. and Draftspotting Limited (collectively, “SpotDraft”, “we”, “us”, “our”) values your privacy and is committed to ensuring that your privacy is protected. The purpose of this privacy notice (“Privacy Notice”) is to describe what information we collect about you while you use our services (“Services”) through our website, https://www.spotdraft.com/ (the “Website”) and applications (collectively, along with any replacement website or application, “Platform”), why we collect the information, how we use your information, how we protect and share your information, the choices we offer you, including your ability to access, update and remove information about yourself (“User” or “your” or “you”).
This Privacy Notice must be read in conjunction with the “Terms of Use” (https://www.spotdraft.com/terms) and all the terms and conditions therein. Please read and understand this Privacy Notice carefully, and its applicability to the Services that we provide you. If you do not agree with this Privacy Notice, do not access or use the Services.
We reserve the right to update this Privacy Notice periodically. Any changes will be posted on our website and will take effect immediately. Your continued access to the Services constitutes your acceptance of the changes. We encourage you to review this Notice periodically to stay informed about how we are protecting your data.
You can jump to particular topics by going to the headings below:
APPLICABILITY
WHAT IS PERSONAL INFORMATION?
INFORMATION WE COLLECT
HOW WE USE THE INFORMATION WE COLLECT
COOKIE POLICY
INFORMATION WE SHARE AND DISCLOSE
USE OF SUBPROCESSORS
HOW WE STORE AND PROTECT YOUR INFORMATION
YOUR PRIVACY RIGHTS
WITHDRAWING YOUR CONSENT
THIRD-PARTY ADVERTISING
HOW LONG WE KEEP YOUR INFORMATION
DATA TRANSFERS
CHILDREN’S POLICY
AMENDMENTS
TERMS OF USE
CONTACT US ABOUT THIS NOTICE
SUPPLEMENTAL EUROPEAN PRIVACY RIGHTS STATEMENT
SUPPLEMENTAL CANADA PRIVACY RIGHTS STATEMENT
SUPPLEMENTAL U.S. PRIVACY RIGHTS STATEMENT
SUPPLEMENTAL INDIAN PRIVACY RIGHTS STATEMENT
SUPPLEMENTAL SOUTH AFRICAN PRIVACY RIGHTS STATEMENT
APPLICABILITY
We ask for and collect certain information about you when you use the Services. This information is necessary for the adequate performance of our obligations towards you and to allow us to comply with our legal obligations. As specified in the table below, the type of information collected depends on the nature of your interaction, your choices, and the specific services you use. Without this information, we may not be able to provide you access to and allow the use of the Services.
WHAT IS PERSONAL INFORMATION?
Personal Information refers to any information that identifies, relates to, or is reasonably capable of being associated with an identifiable individual or household. This includes, but is not limited to names, addresses, geolocation data, online identifiers, and other unique characteristics. Personal Information can also include indirect identifiers such as device identifiers and aggregated data if it can reasonably be linked to an individual.
An identifiable natural person, or "Data Subject," is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
INFORMATION WE COLLECT
We and our third party service providers collect the following broad categories of information from you (collectively referred to as “Information”):
Context | Types of Information | Primary Purpose for Collection and Use of Information |
|---|---|---|
Client Information | We collect the name, email address, signature, call and message logs and job description/ job title data of our clients and their employees and other personnel with whom we may interact. | We are executing on a contractual obligation in contacting our clients and communicating with them concerning normal business administration such as billing, registration, and our services. |
Client and User Account Information | We collect personal information from our clients and users of our Services when they create an account with us to access and use our Services. This information could include business contact data such as name, email address, title, company information and phone number. | We are executing on our contract by delivering services to our clients and managing the associated client relationship. |
Cookies and First-Party Tracking | We use cookies and small data files. “Cookies” are small pieces of data that a website sends to a computer’s hard drive while a website is viewed. | We have a legitimate interest in making our website operate efficiently and in improving our marketing efforts and Services. See our Cookie Policy below. |
Cookies and Tracking Technologies | We participate in behavior-based advertising and the gathering of analytics. This means that a third- party uses technology (e.g., a cookie) to collect data about your use of our websites so that they can provide us with website and user analytics, as well as for the purposes of advertising products and services tailored to your interests on our website, or on other websites. | Where we engage in behaviour-based advertising or use tracking technologies for analytics purposes, we do so based on your consent, which you can provide or withdraw at any time through the cookie consent manager on our Website. For additional information on our use of cookies, please see our Cookie Policy below. Additionally, you can manage your cookie consent preferences in the cookie consent manager via our website’s cookie banner. |
Email Interconnectivity | If you receive an email from us, we may use certain tools to capture data related to when you open our message or click on any links or banners contained within. | We have a legitimate interest in understanding how you interact with our communications to improve relevance and engagement. |
Employment- related information | If you apply for a job posting or become an employee, consultant, intern, or contractor of SpotDraft, we collect the information necessary to process your application or to retain you as an employee, consultant, intern, or contractor. This may include, among other things, your name, address, email address, I-9 information, Social Security Number or Personal Public Service Number, work history, resume, EEO information, veteran status, disability status, healthcare information, and bank account information. Providing this information is required for employment or the relevant contract. | We use information about current employees to fulfil our contract of employment or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We are executing on a contractual obligation in using your information to have efficient staffing and workforce operations. |
Feedback and Support | We collect personal information from you contained in any inquiry you submit to us regarding our Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support and chat requests, or to report an issue. When you communicate with us through our live support chat or over the phone, your messages and calls may be recorded and analyzed for training, quality control, and for sales and marketing purposes. During such interactions, we will notify you of the recording via either voice prompt or script. | We have a legitimate interest in receiving and acting upon, your feedback, issues, or inquiries to improve support and service offerings. |
Mailing List | When you sign up for one of our mailing lists, we collect contact information such as your name, email address and company affiliation. | We collect this information based on your consent, which you provide when you sign up for our mailing list. You may withdraw your consent at any time by using the unsubscribe link in our communications or by contacting us directly. |
Payment Information | We collect payment and billing information when you receive certain Services. For example, we ask you to designate a billing representative, including name and contact information, upon registration. You might also provide payment information, such as payment card details, which we collect via secure payment processing services. | We are executing on a contractual obligation in obtaining payments for certain Services. |
Website Interactions | We use technology to monitor how you interact with our Services. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. | We have a legitimate interest in understanding how you interact with our Services to better improve them, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. |
Social Media | When an individual interacts with our Services through various social media networks, such as when someone follows us or shares our content on LinkedIn or other social networks, we may receive some information about individuals that they permit the social network to share with third-parties. The information we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third-parties. | We use this information to update and maintain the page to provide you with content and features of our Services, as well as to improve our product outreach. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We have a legitimate interest and/or may obtain your consent to collect this information. |
Usage Information | We and our third-party service providers collect information about your interactions with the Platform such as the pages viewed on the Platform and the User Account dashboard, content created or uploaded through use of the Platform and services, including tracking the event of any email sent through the platform, and capture audit logs around the email delivery and email opening by the parties who received the email. | We have a legitimate interest in monitoring our networks and visitors to our Services. Among other things, it helps us to monitor performance and to understand which of our Services and features are the most popular. |
Log File and Device Information | When you use the Platform, we and our third-party service providers automatically collect and store certain information in server logs. This includes details of how you used the Platform, such as access to your User Account, certain information that your web browser sends whenever you visit any website, internet protocol address, information inferred from your internet protocol address like location, ISP details, device information such as hardware configuration and operating system, browser types, referring / exit pages and URL’s, number of clicks, domain names, landing pages, pages viewed and other such information. We also collect device specific information (such as your hardware model, operating system version, unique device identifiers). The Company may associate your device identifiers with your User Account.
| We have a legitimate interest in collecting log-file and device data to ensure the security, stability, and performance of our Services. This information helps us detect and prevent fraudulent activity, monitor system usage, optimize compatibility across different devices, and understand how users interact with our Services to improve functionality. |
Geo-location Data | When you use certain features of the Platform, we may collect information about your location such as your IP address, which in turn would enable us to infer your city, region/state, country, continent, Internet Service Provider (ISP), longitude/latitude coordinates of location, type of connection (residential, business, etc.), and name of the organization that owns the connection (i.e., if it is a business connection or not) technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services. | We collect geolocation information based on our legitimate interest in enhancing service relevance, optimizing user experience, and ensuring compliance with applicable location-based legal requirements. |
User-generated Content (UGC) | Reviews, comments, or questions you submit, including feedback provided through surveys, contact forms, social media channels, or direct communications with our team. | We have a legitimate interest in collecting user-generated content to enhance our services and improve user experience. |
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. All the Information provided to the Company by you, including Personally Identifiable Information or any Sensitive Personal Information, is voluntary.
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third-parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.
We automatically collect certain information when you visit, use, or navigate the Services. This information may include your name, email address, device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
The Company has committed to complying with laws applicable to individual privacy and privacy breach notification that are enacted in the various jurisdictions in which it operates and offers its Services, collectively referred to as "Data Protection Laws."
This Privacy Notice does not apply to, nor do we take any responsibility for any information that is collected by any third party either using the Services or through any third-party links made available to you during your use of the Services or through any of the advertisements or through BOTS. Please note that you will be bound by the terms of use and privacy notices published by third-parties in respect of any information that you may provide to them, and the Company expressly disclaims any liability arising from the content available on such third-party websites or applications.
HOW WE USE THE INFORMATION WE COLLECT
We will use the Information collected from you for the following purposes:
To allow you to collaborate and communicate with other Users.
Ensuring the Services and/or the content on the Website is presented in an effective manner for your use.
To perform our obligations as per your requests and for providing you the Services. This includes sharing your Information in strict confidence with our personnel and contractors (“Personnel”), as they will need to access your Information to provide the Services, subject to the terms of this Privacy Notice.
To provide you with information pertaining to Services.
To notify you about any changes and improvements to Services and/or Website; or analytical purposes, including but not limited to assessing usage data, usage patterns, and other similar activities.
When you create a User Account, we keep a record of your communication to help solve any issues you might be facing.
We use information collected from cookies and other tracking technologies to improve your user experience.
To conduct analysis to ensure that the Services are provided in an efficient manner.
For marketing purposes, and conducting analyses internally for improving our services, their reach, and our business knowledge purposes.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To protect our Services and our confidential information. We may process your information as part of our efforts to keep our Services and our confidential information safe and secure, including fraud monitoring and prevention.
For employment and recruitment purposes.
For purposes required as per law.
In any other way that we may describe to you at the time you provide the information.
You hereby acknowledge and agree to the Company using your Information for the foregoing purposes. Except as otherwise provided herein, we will not disclose, publish, sell, rent, market or share with any third party your personal information without your express consent. Please do not include or provide any personal information unless specifically requested as part of the registration or other applicable processes. If any information you have provided or uploaded violates the terms of this Privacy Notice, SpotDraft may be required to delete such information upon informing you of the same and revoke your access if required without incurring any liability to you.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected for, we will request your consent, unless there is an exception which applies under applicable law. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations.
COOKIE POLICY
We and our third-party service providers use cookies, pixels, web beacons and similar online tracking technologies (collectively, “Cookies”) on the Platform Cookies allow us to collect such information as browser type, time spent on the Platform, pages visited, language preferences, unique identifiers, content you view, click on, or share, screen actions, and other traffic data.
We and our service providers use the information for security purposes, to power the interactive features of our Platform, to facilitate navigation, to display information more effectively, to personalize your experience, to develop and improve the performance, functionality, and design of the Platform, for advertising, and to help keep the Platform free of bugs or errors. We also gather statistical information about use of the Platform in order to continually improve its design and functionality, understand how it is used, and assist us with resolving questions regarding the Platform. Cookies are also used to track the actions of users of the Platform (including email recipients), conduct advertising, measure the success of our marketing campaigns, and compile statistics about usage of the Platform and response rates.
Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Platform. We may also use Cookies in online advertising to track responses to our ads.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
If you do not want information collected through the use of Cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular Cookie (or Cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Platform.
Analytics Tools
SpotDraft uses Analytics Tools to understand how users engage with our website. For example, we use Google Analytics collects information such as:
Frequency of site visits
Pages visited and time spent on them
Actions taken while browsing
Device and browser information (IP address, browser type, operating system)
Approximate geolocation data.
This helps us enhance our website’s performance and improve the overall user experience.
Google Analytics operates through cookies that may remain on your device even after your session ends. You can control your preferences for Google Analytics through:
The cookie consent manager on our website.
Your browser settings (e.g., blocking or deleting cookies).
Installing the Google Analytics Opt-out Browser Add-on, which prevents Google Analytics from collecting data across websites.
Adjusting your ad settings via Google Ads Settings or mobile device settings.
For additional options, you may visit:
For more details on how Google collects and processes data, please see the Google Privacy and Terms page.
Note: Disabling Google Analytics may affect some functionality but will not prevent you from using our Services.
We also make use of the following tracking tools :
Google Tag Manager for event tracking
HubSpot for lead & attribution analytics
LinkedIn Insight Tag for campaign tracking
Microsoft Clarity for heat-maps and session recordings.
If you have further questions about the use of the above analytics tools, please contact us at privacyinfo@spotdraft.com .
INFORMATION WE SHARE AND DISCLOSE
We share Information about you for the following operating and maintaining the Services:
To conduct Analytics: We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful to you. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. We also test and analyze certain new features with some users before rolling the feature out to all users. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other pseudonymised information for compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
For Customer Support: We use your Information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services.
For Legal Reasons: We will also share Information including personal information with individuals or entities to the extent it believes in good faith it is required to ensure compliance with law/ regulations and/or pursuant to enforceable orders of government, law enforcement or regulatory authorities; address fraud, security or technical issues; protect against harm to the rights, property or safety of the Product, its other users or the public as required or permitted by law.
For Effective Provision of Services: We may share your personal information to our employees, contractors and agents or to our affiliates (and their employees, contractors and agents) who need to know the information in order to provide Services to you and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. We also share your personal information with our third-party service providers, who provide services such as website hosting (including through provision of tools that enable us to analyze your interactions on our Platform), data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
With our affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
In Business Transactions: In connection with mergers, acquisitions, or sales of business assets, where Personal Information may be considered a transferrable asset.
With Consent: Where you explicitly permit the sharing of your information, ensuring transparency and choice.
USE OF SUBPROCESSORS
SpotDraft engages certain third-party service providers (“subprocessors”) to support the delivery of our Services. We maintain an up-to-date list of these subprocessors, where we disclose the nature of the services provided. We may add or replace subprocessors as our business needs evolve and will update our subprocessor list accordingly.
In situations where we are required to provide notice under applicable law or a specific contractual obligation, we will notify users of such changes directly. By continuing to use our Services, you acknowledge and accept any changes made to our subprocessor list. If you have questions or concerns about our subprocessors, please contact us at privacyinfo@spotdraft.com.
HOW WE STORE AND PROTECT YOUR INFORMATION
The Information that you provide, subject to disclosure in accordance with this Privacy Notice, shall be maintained in a safe and secure manner. SpotDraft databases and information are stored on secure servers with appropriate firewalls.
We implement appropriate and reasonable technical, physical, and organizational safeguards to protect your personal information from accidental loss, unauthorized access, disclosure, alteration, or destruction. We conduct periodic reviews of our security measures pertaining to our information collection, storage, to guard against unauthorized access to systems.
Access to your personal information is limited to authorized personnel who require the data to perform their duties and who are trained on the importance of maintaining its confidentiality. Our service providers and business partners are contractually obligated to protect personal information and are prohibited from using it for unauthorized purposes.
Given the nature of internet transactions, SpotDraft does not take any responsibility for the transmission of information including User Information shared by you. Any transmission of User Information on the internet is done at your risk and SpotDraft shall not be responsible for the circumvention of the privacy settings or security measures either by you or any third party.
When you enter User information (such as log in credentials) in respect of your User Account (“User Information”) or when you upload any Information through the use of the Platform, we take reasonable efforts to ensure that your User Information and all other information submitted by you is safe and secure; however, the Company makes no representation, warranties or other assurances that the security measures are adequate, safe, fool proof or impenetrable.
As a User of the Services, you have the responsibility to ensure data security. You should use the Services responsibly and not share your User Information including your username or password or account information with any person. Do remember that you are solely responsible for all acts done under the account registered to you.
YOUR PRIVACY RIGHTS
Depending on your location, you may have the following rights regarding your personal information:
· Right to Access: You have the right to access your personal data. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
· Right to Rectification: You have the right to correct inaccurate or incomplete data.
· Right to Erasure: You have the right to request the deletion of your data under certain conditions. Where deletion or modification of certain information is necessary for the delivery of specific features of our Services, we will inform you of any functional impact at the time of your request.
· Right to Restrict Processing: You have the right to limit the use of your data in specific scenarios.
· Right to Data Portability: You have the right to receive your data in a machine-readable format to enable transfer to another service provider.
· Right to Object: You have the right to object to the processing of your data for specific purposes, such as direct marketing or automated decision-making. However, please note that in the event you withdraw your consent, we cannot ensure the continuity or quality of the Services being provided to you. Verification of your identity may be required to process requests.
· Right Not to Be Subject to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you.
To exercise any of the above rights, please email privacyinfo@spotdraft.com.
WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collecting of your personal information by SpotDraft, you may withdraw your consent at any time by sending a communication to SpotDraft at privacyinfo@spotdraft.com specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. However, please note that in the event you withdraw your consent, we cannot ensure the continuity or quality of the Services being provided to you.
If you wish to place a complaint with regard to privacy requirements or laws, access any of your Information or would like to update or correct any errors in your User Information, please contact our Data Protection Officer/Grievance Redressal Officer:
Aniruddha Majumdar (Lead Counsel)
Email: privacyinfo@spotdraft.com
If you have any questions about this Privacy Notice or SpotDraft handling practices, you may email us at privacyinfo@spotdraft.com.
THIRD-PARTY ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services. You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique Cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.
HOW LONG WE KEEP YOUR INFORMATION
In the event you do not use/ access the Services or your User Account for a period of twelve (12) months, we will delete your User Account. If your User Account is created pursuant to an order form signed by the entity of which you are a part, we will delete your User Account as agreed in the relevant order form. If you wish to avail the Services once your User Account is deleted pursuant to non-use or pursuant to your request, you will have to sign-up as a new User.
We retain your personal information only for as long as necessary to fulfil the purposes described in this Privacy Notice, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal obligations), or unless you request that we delete it.
The specific retention period depends on the nature of the personal information and the reasons for which it was collected. When determining how long to retain personal information, we consider several factors, including:
The amount, nature, and sensitivity of the information.
The potential risk of harm from unauthorized use or disclosure.
The purposes for processing and whether those purposes can be achieved through other means.
Any applicable legal, regulatory, or contractual requirements.
When we no longer have a legitimate business need to process your personal information, we will either delete or anonymize it. If immediate deletion is not possible (for example, because the information is stored in backup archives), we will securely store and isolate it from further processing until deletion becomes feasible.
In some cases, we may anonymize your personal information (so that it can no longer be associated with you) for research, statistical, or other business purposes. Aggregated, anonymized, or de-identified data may be retained indefinitely. Additionally, we may retain personal data for a commercially reasonable period to meet backup, archival, audit, dispute resolution, or legal compliance needs.
DATA TRANSFERS
Depending on your location, we store data in the Netherlands, USA and India. Where required, we implement appropriate safeguards for international data transfers, such as Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs), industry best practices, and compliance with applicable regulations. These measures ensure that personal data remains protected even when transferred outside these jurisdictions.
CHILDREN’S POLICY
The Services, Website, and Platform are only intended for Users who are of 18 (eighteen) years of age or older (or the age of majority in their country of use) and otherwise competent to contract. If you are not of the requisite age, you are not to provide any User Information or other information. SpotDraft shall have the right to revoke the provision of Services and delete accounts of Users not compliant with the aforesaid requirement without notice.
AMENDMENTS
This Privacy Notice is subject to change from time to time. If we make changes to this Privacy Notice, we will update the “Last Updated” date at the top of this Privacy Notice. If you disagree with the revised Privacy Notice, you may delete your User Account and/or refrain from visiting the Website or the Platform.
TERMS OF USE
This Privacy Notice shall form a part and shall be read in conjunction with the Terms of Use of SpotDraft.
CONTACT US ABOUT THIS NOTICE
If you have questions or comments about this Notice, please contact us via email at privacyinfo@spotdraft.com or via postal mail to:
Draftspotting Technologies Pvt. Ltd.
Ground Floor, No. 1193 & 1194, Sector VII, HSR Layout, Bangalore - 560102
SUPPLEMENTAL EUROPEAN PRIVACY RIGHTS STATEMENT
Last Updated: March 17, 2026
If you are a resident of the European Economic Area, we rely on our legitimate interest, contractual relationship, and you consent as described in this Privacy Notice to process your personal information. Additionally, subject to any exemptions as provided by law, you may have certain rights regarding the personal information we maintain about you. We offer you certain choices about what personal information we collect from you, how we use that information, and how we communicate with you. If at any time you wish to exercise your rights, please reach out to us in accordance with the “Contact Us” section below.
According to the GDPR and UK GDPR, you have the following rights:
· Right of Access. If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information along with certain other details. If you require additional copies, we may charge a reasonable fee.
· Right to Rectification. If your personal information is inaccurate or incomplete, you may be entitled to ask that we correct or complete it.
· Right to Erasure. You may ask us to erase your personal information in some circumstances, such as where we no longer need it, or you withdraw your consent (where applicable) and where there is no other legal basis for processing.
· Right to Restrict Processing. You may ask us to restrict or ‘block’ the processing of your personal information in certain circumstances, such as if you contest its accuracy or object to us processing it.
· Right to Data Portability. You may have the right to obtain your personal information from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and if the processing is carried out by automated means.
· Right to Object. You may ask us at any time to stop processing your personal information, and we will do so: (a) if we are relying on a legitimate interest to process your personal information, unless we demonstrate compelling legitimate grounds for the processing or your data is needed to establish, exercise, or defend legal claims; or (b) we are processing your personal information for direct marketing and, in such case, we may keep minimum information about you (for example, in a suppression list) as necessary for our and your legitimate interest to ensure your opt out choices are respected in the future and to comply with data protection laws.
· Right to Withdraw Consent. If we rely on your consent to process your personal information, you may have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
· Right to lodge a Complaint. If you have a concern about our privacy practices, including the way we handled your personal information, you can report it to the data protection authority that is authorized to hear those concerns.
Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply. We will not discriminate against you for exercising such rights.
Except as described in this Notice or provided for under applicable privacy laws, there is no charge to exercise your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking in account the administrative costs of providing the information or taking the action requested; or refuse to act on the request and notify you of the reason for refusing the request.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
Send users information about special offers and discounts on our products and services.
Develop and display personalized and relevant advertising content for our users.
Analyze how our Services are used so we can improve them to engage and retain users.
Support our marketing activities.
Diagnose problems and/or prevent fraudulent activities.
Understand how our users use our products and services so we can improve user experience.
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
Complaints. In the event you have concerns about our data processing, you have the right to file a complaint with your data protection authority.
For data protection authorities in the EU, please see here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
For the data protection authority in Switzerland, please contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html).
For the data protection authority in the UK, please contact the Information Commissioner’s Office (www.ico.org.uk).
We would, however, appreciate the opportunity to deal with your concerns before you approach a data protection authority with a complaint, and invite you to contact us in the first instance.
Contact Us
If you are a resident in the European Economic Area, we are the "data controller" of your personal information. We have appointed Lionheart Squared (Europe) Ltd. to be our representative in the EEA. You can contact them directly regarding our processing of your information via email at spotdraft@LionheartSquared.eu.
If you are a resident in the United Kingdom, we are the "data controller" of your personal information in certain circumstances. We have appointed Lionheart Squared Ltd. to be our representative in the UK. You can contact them directly regarding our processing of your information via email at spotdraft@LionheartSquared.co.uk .
If you have any questions or concerns with regard to this Privacy Statement, or you wish to exercise any rights described herein, please contact us via email at privacyinfo@spotdraft.com or via postal mail at:
Draftspotting Technologies Pvt. Ltd.
Ground Floor, No. 1193 & 1194, Sector VII, HSR Layout, Bangalore - 560102
SUPPLEMENTAL CANADA PRIVACY RIGHTS STATEMENT
Last Updated: March 10, 2026
SpotDraft will collect, store, use, and process your personal data in accordance with this Privacy Notice and our obligations under the Personal Information Protection and Electronic Documents Act ("PIPEDA") and any other applicable provincial privacy legislation across Canada (together referred to as "Canadian Privacy Laws").
Under Canadian Privacy Laws, you are entitled to request access to the personal data we hold about you and to ask that any inaccurate information be corrected. To process your request, we will ask you to verify your identity by email and may request additional information to authenticate your request and locate the relevant records. In some cases, we may charge a reasonable fee for providing access to your personal data, and we will notify you of any such fee before proceeding.
Your right of access is not absolute. There are circumstances in which we may be unable to disclose certain personal data, for instance, where the information includes the personal data of other individuals or is protected by legal privilege. If we are unable to fulfil your access or correction request, we will make reasonable efforts to explain the reasons, subject to any applicable legal or regulatory restrictions.
If you wish to be removed from our electronic mailing or messaging lists, please contact us as described in the "Contact Us" section below. Should you have concerns about how we handle your personal data, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada. Further information about the Commissioner's office is available on its website.
If you are a resident of Quebec, SpotDraft will collect, store, use, and process your personal data in accordance with this Privacy Notice and our obligations under An Act Respecting the Protection of Personal Information in the Private Sector (CQLR, c. P-39.1), as amended by the Act to Modernize Legislative Provisions Respecting the Protection of Personal Information (commonly referred to as "Law 25"), under which you are entitled to the following rights:
Right of Access. You may request that we provide you with a summary of the personal data we hold about you, along with details of how that data is being processed.
Right to Correction. If any personal data we hold about you is inaccurate, incomplete, or outdated, you may ask us to correct or update it. Where your account settings permit, you may also make these changes directly.
Right to Withdraw Consent. Where our processing of your personal data relies on your consent, you may withdraw that consent at any time by notifying us. We will inform you of any practical consequences of doing so at the time of your request. Any processing that took place before your withdrawal remains lawful.
Right to Erasure. You may ask us to erase your personal data or cease processing it where, for example, the data is no longer required for its original purpose. Please note that we may be required or permitted by applicable law to retain certain personal data even after such a request.
Right to Data Portability. You may request that we provide your personal data to you in a structured, commonly used, and machine-readable format.
Right to Transparency in Automated Decision-Making. Where we use automated decision-making processes that may affect you, we will clearly disclose the existence and nature of such processing in this Privacy Notice.
Right to De-Indexation. Under certain conditions, you may request that hyperlinks publicly associated with your name be removed from search indexing.
SpotDraft operates globally and maintains a presence across multiple jurisdictions. The personal data we collect from you will be stored primarily in the United States and may also be transferred to and processed in other countries outside Quebec or Canada where we or our service providers operate or maintain infrastructure. These countries may not offer the same level of data protection as Canadian or Quebec privacy laws.
The safeguards we apply to your personal data are governed by the legal requirements of the jurisdictions to which your data is transferred, including obligations to disclose information to law enforcement or government authorities in those jurisdictions.
Where we transfer your personal data outside Quebec or Canada, we ensure that appropriate and suitable protective measures are in place in accordance with applicable data protection laws. If you would like to obtain information about our policies and practices concerning service providers located outside Quebec or Canada, or if you have questions about how your personal data is collected, used, disclosed, or stored by service providers outside your country of residence, please reach out to us using the details provided in the “Contact Us” section below.
Contact Us
If you have any questions or concerns with regard to this Privacy Statement, or you wish to exercise any rights described herein, please contact us via email at privacyinfo@spotdraft.com or via postal mail at:
Draftspotting Technologies Pvt. Ltd.
Ground Floor, No. 1193 & 1194, Sector VII, HSR Layout, Bangalore - 560102
SUPPLEMENTAL U.S. PRIVACY RIGHTS STATEMENT
Last Updated: March 17, 2026
If you are a resident of the United States, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.
If you live in the following States, you may have the following rights:
California Privacy Disclosures
The California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), grants residents of California certain rights over their personal information (also referred to in this Notice as personal data). This section outlines those rights, along with other applicable U.S. state privacy rights, and explains how you may exercise them. The provisions below do not apply to information that has been de-identified, aggregated, or made publicly available, as such information does not constitute personal information under the law.
Your Privacy Rights
Right to Know. You may be entitled to request that we disclose the categories and specific pieces of personal data we have collected about you, the purposes for which it was collected, and any third parties with whom it has been shared.
Right to Delete. You may be entitled to request that we erase the personal data we have collected or maintain about you. Please be aware that exercising this right may limit your ability to use certain features of our Services. Once we have verified your deletion request, we will remove your personal data from our systems and direct any relevant service providers or third parties to do the same, where applicable.
Right to Control Use. You may be entitled to control or restrict how your personal data is used, including the right to opt out of the sale or sharing of your data for cross-context behavioral advertising, the right to object to or opt out of automated decision-making or profiling, and the right to opt out of or limit the use of sensitive personal data.
Right of Access. You may be entitled to obtain a copy of your personal data in a portable format and to have that data transmitted to another entity.
Right of Correction. You may be entitled to request that we amend any personal data that is inaccurate or outdated. Upon verifying a valid correction request, we will use commercially reasonable efforts to update your personal data, accordingly, taking into account its nature and the purposes for which it is maintained.
Exercising Your Rights
We will not penalize or discriminate against you for exercising any of the rights described above.
To submit a verifiable request, please contact us by email at privacyinfo@spotdraft.com. Please note that these rights are subject to certain conditions and exceptions under applicable law, and we may decline a request where we are unable to verify your identity or your authority to act on behalf of another individual.
In most cases, we will attempt to verify your identity using the information we already hold. If that is not sufficient, we may ask for additional details solely for the purpose of authentication and fraud prevention. Any new personal data collected during the verification process will be deleted as soon as practicable after your request has been processed, unless retention is required by law.
You may also designate an authorized agent to submit a request on your behalf. An authorized agent is a natural person or a business entity registered with the Secretary of State that you have empowered to act for you, provided that you have given the agent written permission that we can verify, and you have confirmed your own identity directly with us. These requirements do not apply where the agent holds a valid power of attorney.
We endeavor to respond to all verified requests within the timeframes prescribed by law and in a portable format, unless the request is excessive, repetitive, or manifestly unfounded. If additional time is needed, we will notify you in writing of the reason and the expected extension period.
For further information about your rights under the CCPA, please visit https://oag.ca.gov/privacy/ccpa.
Opt-Out of Sale of Personal Data. California residents have the right to opt out of the "sale" of their personal data. SpotDraft does not sell your personal data to third parties for monetary or other valuable consideration, and accordingly we do not maintain an opt-out process for such activity.
Opt-Out of Sharing of Personal Data. California residents have the right to opt out of the "sharing" of their personal data. Unless otherwise stated in a privacy or cookie notice on a specific SpotDraft website, we do not engage in such sharing.
Children. Our Services are not intended for use by individuals under the age of sixteen (16), and we do not knowingly sell or share the personal data of minors under that age.
Sensitive Personal Data. We do not use or disclose sensitive personal data for purposes beyond those permitted under the CCPA, and therefore we do not offer a mechanism to limit such use or disclosure.
California "Shine the Light." Under California Civil Code Section 1798.83, California residents who have an established business relationship with us may request a list of the categories of personal data disclosed to third parties for direct marketing purposes during the preceding calendar year, together with the names and addresses of those third parties. SpotDraft does not disclose personal data to third parties for their direct marketing purposes.
Colorado Privacy Disclosures
Under the Colorado Privacy Act ("CPA"), residents of Colorado are entitled to the following privacy rights in relation to their personal data: the right to confirm whether we are processing your personal data and to access that data, provided such access does not require disclosure of a trade secret; the right to correct inaccuracies in your personal data; the right to request deletion of personal data we have collected from or about you; and the right to obtain a portable copy of your personal data in a readily usable format that permits transfer to another entity without hindrance, to the extent technically feasible.
Submitting a Request. To exercise your rights under the CPA, please contact us as described in the "Contact Us" section below. You may also appoint an authorized agent to submit a request on your behalf.
Verification. Before acting on any request, we will verify your identity (and, where applicable, the identity of your authorized agent) to the degree of certainty required by law. This may involve asking you to confirm your request via email, providing certain contact details or government-issued identifiers, and matching at least two data points against information we already hold. These rights are not absolute and remain subject to the exceptions and exemptions set out in the CPA. For further information, please visit https://coag.gov/resources/colorado-privacy-act/.
Appeals and Complaints. If you wish to appeal a decision regarding your privacy request, please email us using the details in the "Contact Us" section with the subject line "ATTN: Privacy Appeals," describing your original request and the basis for your appeal. Complaints may also be filed with the Colorado Attorney General at https://coag.gov/file-complaint/.
Opt-Out of Sale. Colorado residents may opt out of the "sale" of their personal data. SpotDraft does not sell personal data for monetary or other valuable consideration and therefore does not maintain a sale opt-out process.
Opt-Out of Targeted Advertising. Colorado residents may opt out of the use of their personal data for targeted advertising. Unless otherwise indicated in a specific SpotDraft privacy or cookie notice, we do not engage in targeted advertising.
Opt-Out of Profiling. Colorado residents may opt out of profiling that produces legal or similarly significant effects. SpotDraft does not engage in such profiling activities.
Connecticut Privacy Disclosures
Under the Connecticut Data Privacy Act ("CTDPA"), residents of Connecticut are entitled to the following privacy rights: the right to confirm whether we are processing your personal data and to access that data, provided such access does not require disclosure of a trade secret; the right to correct inaccuracies in your personal data; the right to request deletion of personal data we have collected from or about you; and the right to obtain a portable copy of your personal data processed through automated means in a readily usable format that permits transfer to another controller without hindrance, to the extent technically feasible, provided no trade secrets are revealed.
Submitting a Request. To exercise your rights under the CTDPA, please contact us as described in the "Contact Us" section below. You may also appoint an authorized agent to act on your behalf.
Verification. Before responding to any request, we will confirm your identity (and, where applicable, your agent's identity) to the degree of certainty required by law. This may include email verification, requesting certain identifying information, and matching at least two data points against our existing records. These rights are not absolute and are subject to applicable exceptions and exemptions. For further information, please visit https://portal.ct.gov/AG/Sections/Privacy/The-Connecticut-Data-Privacy-Act.
Appeals and Complaints. If you wish to appeal a decision we have made regarding your privacy request, please email us using the details in the "Contact Us" section with the subject line "ATTN: Privacy Appeals," describing the nature of your request and the reason for seeking review. Complaints may also be filed with the Connecticut Attorney General at https://portal.ct.gov/DCP/Complaint-Center/Consumers---Complaint-Center.
Opt-Out of Sale. Connecticut residents may opt out of the "sale" of their personal data. SpotDraft does not sell personal data for monetary or other valuable consideration and therefore does not maintain a sale opt-out process.
Opt-Out of Targeted Advertising. Connecticut residents may opt out of the use of their personal data for targeted advertising. Unless otherwise stated in a specific SpotDraft privacy or cookie notice, we do not engage in targeted advertising.
Opt-Out of Profiling. Connecticut residents may opt out of profiling that produces legal or similarly significant effects. SpotDraft does not engage in such profiling activities.
Nevada Privacy Disclosures
SpotDraft does not currently engage in the "sale" of personal data as defined under Nevada law. Notwithstanding, Nevada residents may submit a request directing us not to sell any personal data we maintain about them to third parties who would in turn sell or license that information to others. To exercise this right, please contact us as described in the "Contact Us" section below.
Virginia Privacy Disclosures
Under the Virginia Consumer Data Protection Act ("VCDPA"), residents of Virginia are entitled to the following privacy rights: the right to confirm whether SpotDraft is processing your personal data and to access that data; the right to request correction of inaccuracies in your personal data; the right to request deletion of your personal data; and the right to obtain a portable copy of the personal data you previously provided to us in a readily usable format that permits transfer to another entity without hindrance, where processing is carried out by automated means and to the extent technically feasible.
Submitting a Request. To exercise your rights under the VCDPA, please contact us using the details in the "Contact Us" section below.
Verification. Before acting on any request, we will verify your identity (and, where applicable, your agent's identity) to the degree of certainty required by law. This may involve email verification, requesting certain identifying information, and matching at least two data points with information already in our records. These rights are not absolute and remain subject to the exceptions and exemptions provided under Virginia law. For further information, please visit https://lis.virginia.gov/cgi-bin/legp604.exe?211+ful+SB1392ES1.
Appeals and Complaints. If you wish to appeal a decision regarding your privacy request, please email us using the details in the "Contact Us" section with the subject line "ATTN: Privacy Appeals," describing your request and the grounds for review. Complaints may also be filed with the Virginia Attorney General at https://www.oag.state.va.us/contact-us/contact-info.
Opt-Out of Sale. Virginia residents may opt out of the "sale" of their personal data. SpotDraft does not sell personal data for monetary consideration and therefore does not maintain a sale opt-out process.
Opt-Out of Targeted Advertising. Virginia residents may opt out of the use of their personal data for cross-contextual or targeted advertising. Unless otherwise stated in a specific SpotDraft privacy or cookie notice, we do not engage in such activities.
Opt-Out of Profiling. Virginia residents may opt out of profiling that produces legal or similarly significant effects. SpotDraft does not engage in such profiling activities.
Contact Us
If you have any questions or concerns with regard to this Privacy Statement, or you wish to exercise any rights described herein, please contact us via email at privacyinfo@spotdraft.com or via postal mail at:
Draftspotting Inc.
New York, USA
447 Broadway, 2nd Floor, 1410,
New York, NY 10013, USA
SUPPLEMENTAL INDIAN PRIVACY RIGHTS STATEMENT
Last Updated: March 17, 2026
If you are a resident of India, or if your digital personal data is processed within the territory of India or in connection with the offering of goods or services to individuals within India, you may have certain rights under the Digital Personal Data Protection Act, 2023 ("DPDP Act") and the Digital Personal Data Protection Rules, 2025. This statement supplements our Privacy Notice and should be read together with it. Where this statement conflicts with our Privacy Notice in relation to the processing of your digital personal data under Indian law, this statement shall prevail.
Under the DPDP Act, SpotDraft is a "Data Fiduciary" and you are a "Data Principal."
We process your personal data on the basis of your consent, which must be free, specific, informed, unconditional, and unambiguous, given through a clear affirmative action. Your consent is limited to such personal data as is necessary for the specified purpose for which it was sought. In limited circumstances, we may also process your personal data without consent for certain legitimate uses recognized under Section 7 of the DPDP Act.
You have the following rights:
Right to Access. You may request a summary of the personal data we hold about you, the processing activities we have undertaken, and the identities of all Data Fiduciaries and Data Processors with whom your personal data has been shared.
Right to Correction and Erasure. You may ask us to correct inaccurate or misleading personal data, complete incomplete personal data, or update outdated information. You may also request the erasure of your personal data, and upon receipt of such a request, we will erase your personal data unless retention is necessary for the specified purpose or for compliance with any law for the time being in force.
Right to Withdraw Consent. Where our processing of your personal data relies on your consent, you may withdraw that consent at any time, with the ease of doing so being comparable to the ease with which you gave your consent. The consequences of withdrawal shall be borne by you, and such withdrawal shall not affect the lawfulness of any processing carried out prior to withdrawal. Upon withdrawal, we will within a reasonable time cease, and cause our Data Processors to cease, processing your personal data unless such processing without your consent is required or authorized under the provisions of the DPDP Act or any other law for the time being in force in India.
Right to Grievance Redressal. You have the right to a readily available means of grievance redressal in respect of any act or omission regarding the processing of your personal data or the exercise of your rights. We have appointed a Grievance Redressal/ Data Protection Officer to address your concerns. Please note that you must exhaust the grievance redressal mechanism provided by SpotDraft before approaching the Data Protection Board of India with a complaint.
Right to Nominate. You may nominate any individual who shall, in the event of your death or incapacity, exercise your rights as a Data Principal on your behalf.
Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply. We will not discriminate against you for exercising such rights.
Your Duties as a Data Principal. You are required to comply with all applicable laws when exercising your rights; not impersonate another person while providing your personal data for a specified purpose; not suppress any material information while providing your personal data for any document, unique identifier, proof of identity, or proof of address issued by the State or any of its instrumentalities; not register a false or frivolous grievance or complaint with SpotDraft or the Data Protection Board of India; and furnish only such information as is verifiably authentic while exercising the right to correction or erasure.
Children. Our Services are not directed at individuals below the age of 18 years. We do not knowingly process a child’s personal data without verifiable consent from a parent or lawful guardian where required by applicable law. We will not process children’s personal data in a manner likely to cause a detrimental effect on their well-being, or for tracking, behavioural monitoring, or targeted advertising, except as permitted by law.
Data Breach Notification. In the event of a personal data breach, we will notify each affected Data Principal without delay in a clear and plain manner, as required by applicable law. We will also notify the Data Protection Board of India without delay and, where required, provide such further information relating to the breach within the prescribed time period, including within 72 hours or such extended period as may be permitted by the Board.
Cross-Border Data Transfers. We may transfer your personal data outside India where permitted under applicable law. Where we do so, we will comply with any restrictions or requirements under the DPDP Act and applicable rules, including any country or territory restrictions or any general or special order issued by the Central Government relating to the making available of personal data to a foreign State, or to any person, entity, or agency under its control. We will also comply with any other applicable laws in India that impose a higher standard of protection or additional restrictions on cross-border transfers.
Enforcement. The Data Protection Board of India is the enforcement authority under the DPDP Act and is empowered to investigate non-compliance, impose penalties, and mandate remediation.
Contact Us
SpotDraft has appointed a Data Protection Officer to address your concerns regarding the processing of your personal data. If you have any questions or concerns with regard to this Privacy Statement, or you wish to exercise any rights described herein, please contact:
Name: Aniruddha Majumdar
Email: privacyinfo@spotdraft.com
If you are not satisfied with our response after exhausting the grievance redressal mechanism provided by SpotDraft, you may file a complaint with the Data Protection Board of India.
You may also reach us via postal mail at:
Draftspotting Technologies Pvt. Ltd.
No. 1193 & 1194, Sector VII, HSR Layout, Bengaluru – 560102
Bengaluru, India
SUPPLEMENTAL SOUTH AFRICAN PRIVACY RIGHTS STATEMENT
Last Updated: March 17, 2026
If the processing of your personal information falls within the scope of the Protection of Personal Information Act, 2013 ("POPIA"), this statement applies to such processing. This statement supplements our Privacy Notice and should be read together with it. Where this statement conflicts with our Privacy Notice in relation to the processing of your personal information under South African law, this statement shall prevail. Additionally, subject to any exemptions as provided by law, you may have certain rights regarding the personal information we maintain about you. We offer you certain choices about what personal information we collect from you, how we use that information, and how we communicate with you. If at any time you wish to exercise your rights, please reach out to us in accordance with the "Contact Us" section below.
According to POPIA, you have the following rights:
Right to be Notified. When we collect your personal information, we will take reasonably practicable steps to ensure you are aware of the information being collected, the source of the information, the purpose of collection, whether the supply is voluntary or mandatory, and other details necessary to enable fair and reasonable processing, including your right to object and your right to lodge a complaint with the Information Regulator.
Right of Access. You have the right to request confirmation, free of charge, as to whether we hold personal information about you. You may also request a record or description of your personal information, including the identity of all third parties, or categories of third parties, who have or have had access to that information. A prescribed fee may apply for the provision of such records, and we will provide you with a written estimate before proceeding.
Right to Correction or Deletion. You may request the correction or deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully. You may also request the destruction or deletion of a record that we are no longer authorised to retain. Where we cannot reach agreement on a correction request, you may request that we attach an indication noting that a correction was requested but not made.
Right to Object. You may object, on reasonable grounds relating to your particular situation, to the processing of your personal information where we rely on your legitimate interest, a public law duty, or our legitimate interests or those of a third party, unless legislation provides for such processing. Separately, you may object at any time to the processing of your personal information for purposes of direct marketing. If you object under either ground, we will consider your objection and, where required by applicable law, cease processing the personal information concerned.
Right Not to be Subject to Automated Decision-Making. You have the right not to be subject to a decision that results in legal consequences for you or affects you to a substantial degree, where that decision is based solely on automated processing intended to provide a profile of you, unless the decision is taken in connection with a contract and appropriate measures have been taken to protect your legitimate interests, or the decision is governed by a law or code of conduct that specifies such measures.
Right to Withdraw Consent. If we rely on your consent to process your personal information, you may withdraw that consent at any time, but this will not affect the lawfulness of any processing carried out prior to withdrawal, or any processing that is justified on another legal basis under POPIA.
Right to Submit a Complaint. If you have a concern about our privacy practices, including the way we handled your personal information, you can submit a complaint to the Information Regulator. You also have the right to institute civil proceedings for breach of any provision of POPIA, and a court may award damages, including aggravated damages, as it considers just and equitable.
Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply. We will not discriminate against you for exercising such rights.
Except as described in this Notice or provided for under applicable privacy laws, there is no charge to exercise your legal rights. However, a prescribed fee may apply for access to records of your personal information, and we will advise you of any such fee in advance.
POPIA requires us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a Contract. We may process your personal information when we believe it is necessary to carry out actions for the conclusion or performance of a contract to which you are a party.
Legal Obligation. We may process your information where we believe it is necessary to comply with a legal obligation imposed on us by law.
Protecting Your Legitimate Interest. We may process your information where it is necessary to protect a legitimate interest of yours.
Public Law Duty. We may process your information where it is necessary for the proper performance of a public law duty by a public body.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to pursue our legitimate business interests or the legitimate interests of a third party to whom the information is supplied.
Direct Marketing. We will not process your personal information for the purpose of direct marketing by means of unsolicited electronic communication unless you have given your consent or you are an existing customer and we are marketing our own similar products or services, provided you were given a reasonable opportunity to object when your contact details were collected and on each subsequent occasion. Where your consent is required and has not previously been withheld, we may approach you once to request such consent. All marketing communications will identify the sender and provide you with a means to request that such communications cease.
Special Personal Information. POPIA prohibits the processing of special personal information, including information concerning religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometric information, and criminal behaviour, unless a specific authorisation under POPIA applies. Where SpotDraft processes any such information, we do so only in reliance on an applicable authorisation and in accordance with the conditions for lawful processing.
Children. POPIA prohibits the processing of personal information of children unless a specific authorisation applies, including where consent has been given by a competent person, where processing is necessary for the establishment, exercise, or defence of a right or obligation in law, where processing is necessary to comply with an obligation of international public law, or where the information has been deliberately made public by the child with the consent of a competent person. Our Services are not directed at individuals below the age of 18 years, and SpotDraft does not knowingly collect the personal information of children unless permitted by applicable law.
Security Compromise Notification. Where there are reasonable grounds to believe that your personal information has been accessed or acquired by an unauthorised person, we are required to notify the Information Regulator and you as the affected data subject as soon as reasonably possible after the discovery of the compromise, taking into account the legitimate needs of law enforcement and any measures reasonably necessary to determine the scope of the compromise and to restore the integrity of our systems. Such notification will include a description of the possible consequences, the measures we have taken or intend to take, recommendations for you to mitigate the possible adverse effects, and if known, the identity of the unauthorised person.
Cross-Border Data Transfers. POPIA permits the transfer of personal information outside South Africa only where the recipient is subject to a law, binding corporate rules, or a binding agreement providing an adequate level of protection substantially similar to POPIA, or where you have consented, or where the transfer is necessary for the performance of a contract between you and SpotDraft, or where the transfer is necessary for the conclusion or performance of a contract concluded in your interest between SpotDraft and a third party, or where the transfer is for your benefit and it is not reasonably practicable to obtain your consent. SpotDraft transfers personal information to the United States and India for the purposes of delivering our Services, and we ensure that appropriate safeguards are in place for all such transfers.
Enforcement. The Information Regulator is the supervisory authority under POPIA and is empowered to investigate complaints, conduct assessments, issue enforcement and information notices, and impose administrative fines of up to R10 million. POPIA also creates certain criminal offences that may carry fines and/or imprisonment depending on the nature and severity of the offence.
Complaints. In the event you have concerns about our data processing, you have the right to file a complaint with the Information Regulator. We would, however, appreciate the opportunity to deal with your concerns before you approach the Information Regulator with a complaint, and invite you to contact us in the first instance.
The Information Regulator (South Africa)
Email: POPIAComplaints@inforegulator.org.za
Website: https://inforegulator.org.za
Contact Us
SpotDraft has designated an Information Officer to address your concerns regarding the processing of your personal information. If you have any questions or concerns with regard to this Privacy Statement, or you wish to exercise any rights described herein, please contact:
Name: Aniruddha Majumdar
Email: privacyinfo@spotdraft.com
You may also reach us via postal mail at:
Draftspotting Technologies Pvt. Ltd.
Ground Floor, No. 1193 & 1194, Sector VII, HSR Layout, Bangalore - 560102