Privacy Policy

Last Updated on 10 March 2025

This Website^[a][b] (“Platform”) is operated by Dream Suite Platforms Private Limited having its registered office at Unit No. 1201-1202, 12th floor, Wing A, One BKC, G Block, Plot No. 66, Bandra Kurla Complex, Bandra East, Mumbai 400051 (hereinafter referred to as “Company”, “We”, “Us”, “Our”). We offer [.] (“Services”). ^[c]

This Policy provides for the practices for the collection, possession, storage, handling and dealing of personal identifiable information/ data and sensitive personal data (hereinafter collectively referred to as “Personal Information”) of the User. This Policy is an electronic record in terms of Information Technology Act, 2000 and rules thereunder.

The Company urges the User to read and understand this Policy and the Terms of Service available at [.] (“ToS”) carefully for details on the way. By accessing Our Platform or availing Our Services, You consent to the collection, process, use, disclosure, store and transfer of Your Personal Information in accordance with this Policy and for the purposes stipulated herein.

1. Who does this Policy apply to?

This Policy will apply to (a) all persons accessing Our Platform; and (b) all persons using any of Our Services offered on Our Platform (hereinafter referred to as “User, “You”, “Your”).

2. What data do we collect? 

In the course of providing the Services to the Users through the Platform, We may collect the following personal information (“Personal Information”): [LK Comment: Client to confirm the personal data that is being collected.]

1. First name and last name
2. Phone number and email address
3. The User’s billing information (like name, address, age, PAN number, bank details, wallet/ or UPI details etc.) to process payments made through the Platform for Services. All such information is stored and processed by third party payment gateways, and You are encouraged to review their privacy policy and contact them directly for responses to Your questions.
4. The User’s financial information like transaction history, etc. for the financial transactions on the Platform.
5. Any other information/ documents the User may provide or upload on the Platform while using the Services on Platform.
6. [•]
7. In addition to the above, We may collect some data automatically when You use the Services on the Platform, such as navigational data, Your preferences and usage patterns, manner of usage of Services etc.

3. How do We collect Your data?

1. We collect data and process Personal Information when You:

1. Register on Our Platform or avail Services on Our Platform.
2. Voluntarily complete a customer survey or provide feedback on any of Our message boards. [LK Comment: Client to confirm if this is applicable.]
3. Use Our Platform, by collecting session tokens.
4. From data that You share through the chat/ messaging function on Platform. You are responsible for any content You share on chat and messaging features. This content will also be accessible to other Users who can then share that information further^[d]. We recommend that You consider carefully what You share and with whom You share such information. [LK Comment: Client to confirm if there is chat function on the Platform]

2. We may receive Your personal information from Our partner Sporta Technologies Pvt Ltd. (“Dream11”) with whom^[e] We have entered into a marketing and advertising arrangement and such data shall flow as per the agreement entered into by the Company and Dream11. In relation to such transfer the Company is an independent data fiduciary under the applicable laws and the processing of such Personal Information by the Company shall be done as per this Policy. [LK Comment: Client to ensure appropriate consent mechanisms in Dream11 Privacy Policy.]^[f]

4. How We use Your Personal Information [LK Comment Client to confirm]

We use the Personal Information for the following purposes:

1. Providing Our Service: The processing of Personal Information is important to facilitate the User to use Services vide the Platform.
2. Marketing and advertising: We use Personal Information to provide Users with special offers, and promotions, and for other marketing, advertising, and promotional purposes, including general updates about Us and Our Services and new offerings of the Company or any third-party partner services. These communications will be sent in accordance with Your communications preferences, if You specifically opt-in for receiving the same. At any time, You may opt out of such communications as per Paragraph 8.2(e) below.^[g]
3. Enabling You to opt for services of third party: We use Personal Information to direct the Users to the services or new offerings of any third-party partner services. If a User avails any new offerings of Our third-party partners (“Third Party Service Providers”), the User will be subjected to the own rules, policies, and practices of such third-party partner and not this Policy.
4. Lead Generation: For generating business enquiries and leads.
5. Improving the Services: To analyze User’s choices, browsing pattern including the frequency of visits and duration for which a User is logged on, to diagnose problems with Our servers, for improving Our systems and Platform and Services. We may combine the information that We receive from third parties with the information You give to Us and information We collect about You for the purposes set out above. We analyse the log files of Our Platform that may contain Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring, app crashes, page viewed and exit websites and applications, operating system, date/time stamp, and clickstream data. This helps Us to administer the website, to learn about user behavior on the site, to improve Our product and services, and to gather demographic information about Our user base as a whole.
6. Other services: We shall approach the User for the User’s consent for any other specific purpose not listed in this Policy.
7. Comply with legal obligations: To meet Our legal obligations under the applicable laws.
8. Facilitation of Payments: For facilitating the payments by the User on the Platform. We share Your Personal Information with Our partner payment processors for easing Your transaction on the Platform. [LK Comment Client to confirm]^[h]
9. Collection of money in relation to Services: In order to ensure the receipt of payment for the transactions done on the Platform it is important that such information is available with Us.
10. Legitimate Interests: To fulfil Our legitimate interests, or those of a third party in conducting and managing Our business and Our relationship with You as described in this Policy.
11. Security: In order to protect You and other Users from fraudulent activities and transactions and to protect You from unauthorized access.
12. Market research, data solutions and report creation: We may use Your Personal Information for market research and data solution purposes. This is done via functionality reporting on the data collected from You.
13. Anonymization: We may anonymize and/or de-identify information collected from You through the Services or via other means, including via the use of third-party web analytic tools. As a result, Our use and disclosure of aggregated and/or de-identified information is not restricted by this Policy, and it may be used and disclosed to others without limitation. Personal Information which We may convert into the anonymized format is Our property. We may use it, in Our sole discretion and without any compensation to the User, for any legitimate purpose including without limitation the transfer and commercial sale of the anonymized format to the third parties. Company may without restriction, share, use, reproduce, license, or otherwise exploit such anonymized data for its business purposes.

5. Where is Your Personal Information stored?

The Personal Information that We collect in respect of the User is hosted [.]. The storage of Personal Information by Our Third Party Service Providers shall be subject to their policies. ^[i][LK Comment: Client to confirm if the information will be stored and hosted in India only or outside India too.]

6. Why and when We transfer/ disclose Your Personal Information?

We may transfer the User’s Personal Information within India and outside India (provided that such country offers the same or greater level of protection for Personal Information than India), in the following manner:

1. To affiliated companies and entities, within India or outside India, that have been contracted to offer services on behalf of the Company. These service providers or vendors are only permitted to use the disclosed Personal Information in accordance with the instructions provided by the Company via binding documents enforceable by law. ^[j]
2. To Third Party Service Providers with whom We have a fiduciary-to-fiduciary relationship to enable them to sell and provide their services to You through the Platform. Such Third Party Service Providers operate as independent fiduciaries and determine the purpose of processing Your Personal Information in accordance with their own policies, rules, and standards, and not this Policy. We do not control, monitor or assume responsibility for the processing of Your Personal Information by such Third Party Service Providers and protection of rights of data subjects under the applicable laws, data retention and storage, their security measures or other measures undertaken by them to ensure compliance with the applicable laws. The processing of Your Personal Information by such Third Party Service Providers shall be subject to their respective policies, and We encourage You to review their policies for further details on how they process Your Personal Information.
3. To Our partner payment processors for processing of the payment for the transactions done on Platform. [^[k]LK Comment: Client to confirm]
4. If required by law, legal process, litigation, and/or requests from governmental or regulatory authorities, or for the purpose of national security, law enforcement, or other issues of public importance, including cyber incidents, prosecution and punishment of offences, to disclose the User’s Personal Information.
5. In connection with a sale, divesture, or transfer of Company (including any shares) or any combination of its products, Services, assets, affiliates, and/or businesses. The User’s Personal Information may be among the items sold or otherwise acquired in these types of transactions. We may also sell, assign or otherwise transfer such Personal Information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings.

7. How do We protect Your Personal Information?

1. Security Safeguards and Procedure

1. We value the security of the User’s Personal Information and hence We have implemented technical and organizational security measures that are designed to help protect the User’s Personal Information from unauthorized access, disclosure, use and modification. From time-to-time, We review Our security procedures to consider appropriate new technologies and methods.
2. Please be aware, however, that no data security measures can guarantee 100% security.
3. If We learn of a security breach, We may (a) attempt to notify the User electronically so that the User can take appropriate protective steps; or (b) post a notice on the Platform, or (c) take suo-motto steps to rectify the breach without any notice to the User. If the User have any questions about the security of the User’s Personal Information, please contact the Grievance Officer.

2. How long We keep Personal Information

1. We shall retain the User’s Personal Information only for as long as is necessary, and after such reasonable time, it is destroyed appropriately and securely or anonymized in accordance with the law.
2. We shall retain the User’s Personal Information (other than in anonymized form) for: (i) as long as User’s account is active and We have a continued relationship with the User; (ii) as long as needed in order to comply Our legal, statutory and contractual obligations; (iii) as long as needed to provide Services to the User and shall be subject to periodic update or deletion of unnecessary data.

8. What are Your Rights and obligations in relation to Your Personal Information?

1. Save and except the rights provided herein in this Policy, all rights to the Personal Information shall belong to the User. The Users shall ensure the following:

1. To provide true and accurate details of Personal Information.
2. To keep their information up to date.
3. To regularly review this Policy.
4. To keep their account credentials confidential and notify the Company of any security breaches.
5. We urge the Users to not upload on the Platform any identity proof issued by government authorities including but not limited to User’s aadhaar card.

2. You have the following rights pertaining to the Personal Information shared by You with Us:

1. Right to know what Personal Information We hold and to have the information communicated to You;
2. Right to access the copies of Your Personal Information. We may charge You a small fee for this service;
3. Right to request that the Personal Information held by Us be corrected, rectified or deleted;
4. Right to object to the processing of the Personal Information or to request restriction thereof;
5. Right to opt out of targeted advertisements. This can be done by managing Your preferences [here]. Please note that it may take up to thirty (30) business days for Us to process opt-out requests. Please note that, even after You opt out from receiving marketing or promotional messages from Us, You may continue to receive transactional and service-related messages, certain administrative notices, service notices, or legal notices from the Company;
6. Right to withdraw Your consent to submit or process any or all Personal Information or decline to provide any permissions on its Platform as covered above at any time.

3. Any such request to update, delete or correct the Personal Information, or to withdraw consent regarding sharing and use of Personal Information should be shared with the Grievance Officer as per Paragraph 13 below. Please note that We may take time to process such requests, and Your request shall take effect no later than 5 (Five) business days from the receipt of such request, after which We will not use Your Personal Information for any processing unless required by Us to comply with Our legal obligations.
4. In case You choose to object processing of the Personal Information, withdraw consent in regard to the Personal Information or delete the Personal Information shared, then Your access to the Platform and Services may be limited, or We might not be able to provide the Services to You.
5. We will evaluate any request for deletion of Personal Information on a case-to-case basis and take the requisite action as per applicable law. In this regard, please note that information sought to be deleted may remain with Us in archival records for the purpose of compliance of statutory enactments, or for any other lawful purpose. Therefore, You are requested to carefully evaluate what types of information they would like to provide to Us.
6. If You wish to exercise Your rights for protection of Your Personal Information with respect to the processing carried out by Third Party Service Providers, You must contact them directly and We shall not have any obligation in relation to it. If You reach out to Us in this regard, We may provide reasonable assistance to You to reach out to such Third Party Service Providers. [LK Comment: Client to confirm]

9. Third party website/apps ^[l]

1. We may through Our Platform, (a) provide links to third-party platforms and/ or (b) allow Third Party Service Providers to provide their services to You through Our Platform, if You opt for such services. Such Third Party Service Providers may include, without limitation, the following:

1. the following SEBI registered investment advisors intending to offer their investment advisory services:

1. [Sigfyn], a SEBI registered investment advisor with registration number [.]. Their privacy policy and terms of use is available at [.].

2. the following account aggregators registered with RBI, who share personal financial data with the investment advisors:

1. [OneMoney], an account aggregator holding RBI license. Their privacy policy and terms of use is available at [.].

3. We do not make any representations or warranties with respect to such third-party platforms. Further, We are not responsible for the practices employed by such platforms, applications, or services linked to or from the Services or Platform, including the information or content contained there. Such third-party websites and services are subject to that third party’s own rules, policies, and practices, and not this Policy.
4. If You opt for and provide consent for availing such services from the Third Party Service Providers, We may share some of Your Personal Information with such Third Party Service Providers to enable You to avail such services and facilitate their services through Our Platform. Such Third Party Service Providers operate as independent fiduciaries and determine the purpose of processing Your Personal Information independently in accordance with their own policies, rules, and standards, and not this Policy. We do not control, monitor or assume responsibility for the processing of Your Personal Information by such Third Party Service Providers and their compliance with the applicable laws. The processing of Your Personal Information by such Third Party Service Providers shall be subject to their respective policies, and We encourage You to review their policies for further details on how they process Your Personal Information.
5. The Third Party Service Providers offering investment advisory services (“Third Party IAs”) to You, with whom We have shared Your Personal information, may procure Your finance or credit related personal information from various sources legitimately available to such Third Party IAs including their account aggregators to render their services effectively. We are not investment advisors and do not provide any investment advisory services. We merely connect Our Users to investment advisors and facilitate them in providing their services to the Users who wish to avail such services. In providing these Services, such Third Part IAs may display such financial details on Our Platform to provide You their services. However, the Third Part IAs have sole control on such data and such data is not accessible or visible to Us. We have undertaken adequate technological measures to ensure the non-visibility and non-access of such information to Us. [LK Comment: Client to confirm if this fine or should we provide exact details of technology.]^[m]

10. Should children access this Platform?

Our Services are not intended for or directed to children under the age of eighteen years. We do not knowingly collect or process personal data of children below the age of eighteen years. If We are made aware that a child under the age of eighteen years has provided their personal information, We will delete the information from Our records. [LK Comment: Client to confirm]

11. How do We update this Policy?

1. This Policy is current as of the last updated date set forth above.
2. We may periodically change this Policy to keep pace with new technologies, industry practices, and regulatory requirements, among other reasons. While, We expect most such changes to be minor, We request the Users periodically to review the changes.

12. Governing Law

1. This Policy shall be governed by and construed in accordance with the laws of India and the Parties agree that they are bound by the laws of India for the purposes of this Policy. The Parties agree that the Company shall not be required to follow laws of any other jurisdiction, whether or not such User belongs to a different jurisdiction other than India.
2. Parties shall try to resolve any dispute arising out of or in relation to this Policy by mutual discussions, failing which the same shall be submitted to arbitration under the provisions of the Arbitration and Conciliation Act, 1996. The place of arbitration shall be Mumbai, Maharashtra, India and the language of arbitration, English. Subject to the foregoing, the courts at Mumbai, Maharashtra, India shall have exclusive jurisdiction. [LK Comment: Client to confirm]

13. How to contact Us?

Any complaints with regards to use, processing or disclosure of Personal Information provided by the User or breach of the terms of this Policy may be taken up with the Grievance Officer. The details of the Grievance Officer are as follows:

Grievance Officer: [.]

Email: [.] 

The Grievance Officer shall acknowledge and dispose of the complaint within such time period as prescribed under the applicable laws.