Sprih Privacy Notice

This Privacy Notice was last updated on January 08, 2025.

We, Sprih Inc. (“Company”, “Sprih”, “we”, “us”, “our”) are a carbon accounting and management software company. We have developed a web-based Software-as-a-Service offering called Sprih, (“Application”) which helps organizations measure, benchmark, report their carbon footprint and manage their sustainability journey (“Services”). We operate the website www.sprih.com (“Website”), which showcases our Services. For ease of reference, the Website and Application is collectively referred to as “Platform”.

We respect data privacy rights and are committed to protecting personal data collected on the Platform. This privacy notice (“Privacy Notice”) sets forth how we collect, use and protect the personal data collected through the Platform.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY. BY CLICKING ON THE CONSENT CHECK BOX, AND PROVIDING US PERSONAL DATA, YOU CONSENT TO OUR USE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY NOTICE. IF YOU DO NOT AGREE TO THIS PRIVACY NOTICE, YOU MAY WITHDRAW YOUR CONSENT OR ALTERNATIVELY CHOOSE NOT TO PROVIDE YOUR PERSONAL DATA ON THE PLATFORM. SUCH AN INTIMATION TO WITHDRAW YOUR CONSENT CAN BE PROVIDED BY EMAIL ON privacy@sprih.com.

IF YOU ARE ACCESSING THE PLATFORM ON BEHALF OF A THIRD PARTY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH THIRD-PARTY TO THE TERMS AND CONDITIONS OF THIS PRIVACY NOTICE AND, IN SUCH AN EVENT YOUR USE OF THE PLATFORM SHALL REFER TO USE BY SUCH THIRD PARTY. IF YOU DO NOT HAVE SUCH AN AUTHORITY (TO PROVIDE ANY PERSONAL DATA OF A THIRD PARTY) OR DO NOT AGREE TO THE TERMS OF THIS PRIVACY NOTICE, THEN YOU SHOULD REFRAIN FROM USING THE PLATFORM.

This Privacy Notice is an electronic record complaint and construed in accordance with data protection laws of the applicable jurisdictions.

1. Key Definitions

1. “User/s”, “you”, “your” shall mean and include individuals who visit, access, and/ or use the Platform.
2. “Customer” shall mean an entity, organizer, individual which subscribes/ purchases the Application.
3. “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
4. “Processor” means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.

2. Collection of your Personal Data

We may collect Personal Data in the following ways:

1. Personal Data collected through Website:

We may receive Personal Data when you visit our Website, connect with us, book a demo of our Application or subscribe for regular updates from us through the website. We may receive Personal Data, including but not limited to your name, email address, contact number, company name, designation and any other information that you provide us.

2. Career Opportunities: If you apply for an employment opportunity either by reaching out to us or through our website www.sprih.com/careers, we may collect your information including but not limited to full name, email address, contact information, country, city, position you are applying for, information obtained during interviews and any other information you choose to provide.

3. Social media platforms: We may receive your Personal Data when you access our social media pages or interact with us on social media platforms including Facebook, Twitter, Instagram, and/or LinkedIn. Such Personal Data may include your social media handles, name, any personal data you share via direct messages, details about your profile, or any other personal data that you may share with us.

4. Communications:  We may collect information that you provide to us when you contact us to inquire about our Services or Platform. Such information may include your first name, last name, email address, phone number and any other information you provide, including your interests in relation to our Services or Platform. We use this information to communicate with you about your inquiry or interests and schedule a demo of our Services and Platform.

We may receive information including personal data from our Customers when we provide Services. We manage your personal data on behalf of the Customer and shall process personal data as per the instructions received from the Customer. If you have any questions related to the handling of your Personal Data by the Company or to exercise your rights, you can contact us at privacy@sprih.com.

For Personal Data collected and managed on behalf of Customer please refer to Clause 3 of this Privacy Notice.

3. Personal Data We Process on behalf of the Customer

This section concerns the Personal Data of the individuals collected by the Customer, and such processing may be facilitated by us.

1. The Company as a Data Processor: The Customer sets the purpose and means of processing of such Personal Data. We process such Personal Data only on behalf of and on the instructions of the Customer and for the purposes of rendering our Services to the Customer.
2. Customer Privacy Notice: If you are an individual using our Services and your Personal Data was shared with us by the Customer, the privacy Notice of the Customer, on whose behalf we collect and process the Personal Data, will apply. This means that any enquiry, request, objection or complaint that you as a user may have in connection with the collection and/or processing of Personal Data that forms part of your usage of Services should be addressed to and resolved by the Customer.
3. Personal Data: Depending on the nature of services and Customer requirements the Company processes Personal Data on behalf of Customer/s.

The Customer has complete control over the Personal Data and the Company processes the Personal Data on the Customer’s behalf.

Further, the Personal Data collected on behalf of the Customer may differ based on the specific requirements, the Company will remain the data processor, and the Customer will be responsible for providing adequate privacy notices.

4. Customer Responsibility: The Customer represents that it has acquired all necessary consents and/or relies on other appropriate legal basis for the processing of Personal Data of end-Users. Customer confirms that end-users have been informed about that their Personal Data is transferred to the Company as a processor and other third parties used by the Company for the provision of Services.

We will process the Personal Data for as long as we provide Services to the Customer and the Customer maintains active accounts.

4. Cookies

We use cookies and/or similar in-house and third-party tracking tools to track user traffic patterns. Tracking tools also used are beacons, tags and scripts to collect and track information and to improve and analyse our Platform. You may choose to disable cookies through your browser settings. For more information, please refer to our Cookie Notice.

5. Accuracy

The User and the Customer shall be solely responsible for the accuracy, correctness, or truthfulness of the Personal Data shared with Us whether of its own or any third party. In the event the User or Customer is sharing any Personal Data on behalf of a third person, such User or Customer represents and warrants that they have the necessary authority to share such Personal Data with the Company, obtained a written consent from such third party and the Company shall not be responsible for verifying the same. The User and Customer understands and acknowledges that such Personal Data shall be subject to the terms and conditions of this Privacy Notice.

6. Use of your Personal Data

We use Personal Data for the following purposes:

1. to inform you about our Platform and Services and to respond to your requests;
2. to manage our relationship with you;
3. to inform you about our Services;
4. to communicate with you and send you updates and newsletters;
5. to address your inquiries and provide technical support;
6. to provide relevant features and improve our Platform and Services;
7. for internal record keeping;
8. to process job applications (if you apply for a job at our Company);
9. and to comply with our legal or statutory obligations.

7. Sharing and Disclosure

We do not sell, rent, share, distribute, lease or otherwise provide your Personal Data to third parties, without your prior consent. Keeping this in mind, we may disclose your Personal Data in the following cases:

1. Affiliates: We may provide your Personal Data to our affiliates to enable them to improve the Services, provide feedback and respond to their queries.
2. Service Providers: We may share your Personal Data with the service providers who work with us in connection with operating the Platform and/ or providing the Services. All such service providers are subject to stringent confidentiality restrictions consistent with this Privacy Notice.
3. Merger or Acquisition: We may transfer your Personal Data if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Platform, to a third party. Any such third party or resultant entity that receives your Personal Data shall have the right to continue to use your Personal Data in line with the purposes set out herein. In the event of such a sale or transfer, we may notify you.
4. Safety, Legal and Regulatory Authorities: We may disclose your Personal Data if we believe that we are required to do so: (a) by law; (b) to comply with legal process or governmental requests; (c) to enforce our agreements; (d) to protect our operations; (d) to protect the rights, privacy, safety or property of the Company, you or others; (e) to protect our reputation and (f) to permit us to pursue available remedies or limit the damages that we may sustain.

8. Data Retention

We will retain your Personal Data as long as it is required to be retained for the purpose of providing services. We may also retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. International Data Transfers

We may transfer your Personal Data to international locations depending on the underlying infrastructure of our services. All such transfers are subject to appropriate legal requirements as per the applicable privacy and data protection laws.

10. Data Security

Your Personal Data is stored on third party cloud servers. We implement security measures that are compliant with standards such as ISO 27001 and SOC 2 Type II. We are committed to maintaining information security and protecting customer data from potential breaches. Although we provide appropriate firewalls and protections, we cannot warrant the security of Personal Data transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we will take necessary measures to mitigate such events.

11. Children’s Personal Data

Our Platform and Services are not meant for children. We define “children” as anyone under the age of 18 years. If we learn that we have collected or received Personal Data from a child without verification of parental consent, we will delete the information. If you believe we might have any information from or about a child, please contact at privacy@sprih.com.

12. Privacy Rights

In accordance with applicable law, you have the following rights in respect of your Personal Data:

1. right to access Personal Data in our possession,
2. right to have us rectify or modify any such Personal Data,
3. right to have us erase/delete your Personal Data,
4. right to withdraw consent at any time where we are relying on consent to process Personal Data,
5. right to grievance redressal.

Depending on the nature of the request, we may ask you to complete a Personal Data request form or seek certain details to verify the request. All requests for Personal Data will be handled within a reasonable period of time. If you would like to exercise ANY of these rights, please contact at privacy@sprih.com

13. Information for Data Subjects in EU And UK

Residents of the European Union (“EU”) and United Kingdom (“UK”) should note that this Privacy Notice has been updated in accordance with the requirements of the EU General Data Protection Regulation (the “GDPR”) and the UK GDPR, the United Kingdom Data Protection Act 2018, the Privacy and Electronic Communications Regulations, and any regulation superseding any of the foregoing (“UK Privacy Laws”). As per the provisions of the GDPR and UK Privacy Laws we shall be considered the Controllers of the Personal Data collected as a result of your use / access of the Platform and Processors of the Personal Data collected as a result of your use of our Services.

Legal Basis (for EU residents and UK residents): We will not process your Personal Data without a lawful basis to do so. We will process your Personal Data only on the legal bases of consent, contract, or on the basis of our legitimate interests, provided that such interests are not overridden by your privacy rights and interests.

Transfer of your Personal Data across borders (for EU Residents): The Personal Data we collect (of EU and UK residents) is stored on servers located in India. Personal Data might be processed outside the EU and UK. We collect and transfer Personal Data outside the EU and UK in accordance with the provisions of the GDPR and UK Privacy Laws. If you have questions, please contact privacy@sprih.com.

Your Rights (For EU and UK Residents):

You have the right to request us:

1. to let you know what Personal Data belonging to you, we hold in our possession,
2. withdraw consent at any time where we are relying on consent to process your Personal Data,
3. right to have us rectify or modify any such Personal Data,
4. right to have us erase/delete your Personal Data,
5. right to restrict us from processing such Personal Data,
6. right to object to our use of your Personal Data,
7. right not to be subject to a decision based solely on automated processing, including profiling,
8. you have the right to lodge a complaint with a data protection authority.

UK residents have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. We may need to request specific information from you to help us confirm your identity or also contact you for further information in relation to your request. If you would like to exercise ANY of these rights, please contact privacy@sprih.com.

Governing Laws: For any EU and UK residents, this Privacy Notice shall be governed respectively by the provisions of the GDPR and UK Privacy Laws.

14. Choice and opt-out

We may send you communications including but not limited to (a) notices about your use of our Platform and/or Services, including those concerning violations of use, (b) updates, (c) promotional information regarding our Services, and (d) newsletters. You may opt out of receiving promotional emails and newsletters from us by following the unsubscribe instructions provided in those emails. Alternatively, you can opt out, at any time, by emailing at privacy@sprih.com with your specific request.

15. Links to other websites/ platforms

Our Platform may contain links to other websites/ platforms/ applications of your interest. Please note that we do not have any control over such other websites/ platforms/ applications, and you will be accessing these websites/ platforms/ applications at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites/ platforms/ applications and those are not governed by this Privacy Notice. You should exercise caution and look at the privacy notice applicable to such websites/ platforms/ applications.

16. Governing laws and jurisdiction

This Privacy Notice shall be construed and governed by the laws of India. You agree that the courts in Pune, India shall have exclusive jurisdiction over such disputes.

17. Changes to this Privacy Notice

Sprih reserves the right to update this Privacy Notice from time to time. Please revisit this page periodically to stay aware of any changes to this Privacy Notice. Please revisit this page periodically to stay aware of any changes to this Privacy Notice, which we may update from time to time. If we modify this Privacy Notice, we will make it available through the Platform and indicate the date of the latest revision. If such modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change via email or through our Platform. Your continued use of the application and/or Services available after such modifications will constitute your: (a) acknowledgment of the updated Privacy Notice; and (b) agreement to abide and be bound by that such Privacy Notice.

18. Contact Information

If you have any questions or concerns or grievances regarding this Privacy Notice or if you wish to withdraw their consent in relation to the processing of their Personal Data, you can reach out to our appointed grievance redressal officer (also known as compliance officer) via email at privacy@sprih.com.

OFFICE ADDRESS:

Sprih, Inc. (US)

16192, Coastal Hwy, Lewes, DE 19958

Sprih Innovations Pvt Ltd. (India)

Office No. 4, Ashirwad Apts.

Limayewadi, Sadashiv Peth,

Pune, Pune City, Maharashtra, 411030