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SPOTO Privacy Policy

How SPOTO collects, uses and protects personal information

Effective Date: 2 October 2026 Last Updated: 2 October 2026

Key Points

  • We collect the information needed to run each role on SPOTO — Player, Team, Partner, Referee, Sponsor and Audience.
  • Payment details are handled by regulated third-party payment gateways; SPOTO does not store your full card or bank credentials.
  • KYC information may be required before releasing certain payouts (Prize Money, Referee fees) under Indian payment/tax law.
  • You can request account deletion at any time; limited records may be retained afterward where legally required.
  • You may access, correct or request deletion of your personal information, subject to applicable law.
  • We do not knowingly collect data from users below the minimum age required for the relevant feature.
Complete Privacy Policy

Overview

1. Introduction 2. Data Controller / Responsible Entity

Information We Collect

3. Information We Collect 4. Account Information 5. Player Information 6. Team Information 7. Partner Information 8. Referee Information 9. Audience Information 10. Payment Information 11. KYC Information 12. Device Information 13. Location Information 14. Camera and Photo Access 15. Contacts

Collection & Use

16. How Information Is Collected 17. How SPOTO Uses Personal Information 18. Public Sports Information 19. Tournament Information 20. Purposes and Lawful Processing 21. Marketing

Sharing

22. Information Sharing 23. Payment Providers 24. Fraud and Security Monitoring 25. Prediction Information 26. Promotional Rewards 27. Tipping Information 28. Prize Distribution Information 29. Partner Data 30. Referee Data 31. Sponsor Data

Technology & Analytics

32. Cookies 33. Analytics

Children and Safety

34. Children and Minors

Security & Retention

35. Data Security 36. Data Retention 37. Account Deletion 38. Data Retained After Account Deletion

Your Rights

39. User Data Rights 40. Data Correction

Third Parties & International Processing

41. Third-Party Service Providers 42. International Data Processing 43. Data Breaches

Platform Features

44. Location Privacy 45. User-Generated Content 46. Notifications 47. Advertising 48. App Tracking

Store Disclosures

49. Google Play Data Safety 50. App Store Privacy Disclosures

Legal

51. Legal Disclosures 52. Business Transfers 53. Data Protection Framework 54. Privacy Policy Updates 55. Grievance Redressal 56. Contact Us
Overview

This Privacy Policy explains how Transkwik Private Limited ("SPOTO", "we", "us") collects, uses, shares and protects personal information when you use the SPOTO website and mobile applications (the "Platform"). By using the Platform, you agree to the collection and use of information as described here.

Transkwik Private Limited is the entity responsible for determining how and why your personal information is processed on the Platform. Registered Office: 1-83 Maddulaparva, NTR District, Andhra Pradesh – 521215, India. Head Office: Plot No. 1313, Vrushabadri Residency, Venkataramana Colony, KPHB, Hyderabad, Telangana – 500085, India. Privacy queries can be sent to info@spotoapp.in.

Information We Collect

We collect information you provide directly (such as when you register or fill in a profile), information generated through your use of the Platform (such as match history), and limited technical information from your device, as detailed in the sections below.

When you create an account we collect information such as your name, mobile number, email address, and password (stored in encrypted form). This information is used to create and secure your account and to identify you to other Users where relevant (for example, your Team).

For Player profiles, we collect information such as your preferred sport(s), skill level, playing position, profile photo, and match statistics generated from Tournaments you participate in.

For Teams, we collect the Team name, logo, roster of Players, and the identity of the Team administrator(s) who manage registrations on the Team's behalf.

For Partners, we collect organiser/business name, contact details, and information needed to create and run a Tournament, such as venue details, Tournament rules, fee structure and Prize Money amounts.

For Referees, we collect profile information such as sport(s) officiated, years of experience, certifications (where provided), availability, and a history of Matches officiated and ratings received.

For Audience Members, we collect the information needed to follow Tournaments and Matches, submit free Predictions, and, if used, send Tips to Players or Teams.

When you make or receive a payment (Participation Fee, Tip, Prize Money, or Referee fee), payment processing is handled by our third-party payment gateway provider(s). We receive confirmation of the transaction (such as amount, status and a transaction reference) but do not store your full card number, CVV or net-banking credentials.

Where required before releasing a payout above applicable thresholds (for example certain Prize Money or Referee payments), we or our payment provider may collect Know-Your-Customer (KYC) information such as a PAN, bank account details, or a government-issued ID, as required under applicable Indian payment and tax regulations.

We collect limited technical information about the device and app version you use to access the Platform, such as device type, operating system version, and app crash or performance logs, to help us maintain and improve the Platform.

With your permission, we may collect approximate or precise location information to show nearby Teams, Tournaments and venues, or to display distance information on Tournament and venue listings. You can control location permissions through your device settings.

With your permission, the app may access your device camera or photo library so you can upload a profile photo, Team logo, or Tournament-related image. We only access the camera or photo library for the specific action you initiate.

If you choose to invite friends or teammates to join a Team or Tournament using a contact-invite feature, we may request access to your device contacts for that specific purpose. We do not access your contacts unless you initiate this feature.

Collection & Use

We collect information directly from you when you register or use a feature, automatically through your use of the Platform (such as app analytics), and from third parties such as our payment gateway provider (for transaction confirmations).

We use personal information to create and manage your account, operate core features (Team discovery, Tournament registration, fixtures, live scores, Predictions and Tips), process payments and payouts, communicate with you about your account or a Tournament, maintain the safety and integrity of the Platform, and comply with legal obligations.

We do not use personal information for purposes incompatible with these stated uses without notifying you and, where required, obtaining your consent.

Certain information is inherently public within the context of a Tournament, such as a Player's or Team's name, match scores, results and public rankings, since these are core to how a sports competition is displayed to other participants and the Audience.

Tournament details created by a Partner (name, venue, date, format, fees, Prize Money) are published on the Platform so that Teams and Players can discover and register for the event.

We process personal information on grounds that include performing our contract with you (providing the Platform's features), your consent (for optional features such as location, camera or contacts access), our legitimate interests in operating and securing the Platform, and compliance with legal obligations (such as tax and KYC requirements).

We may send you information about SPOTO features, Tournaments or promotions relevant to you. Where required by applicable law, this is subject to your consent, and you can opt out of marketing communications at any time through in-app settings or by contacting us.

Sharing

We share personal information with other Users where necessary for the Platform to function (for example, your Player profile is visible to a Team you join, and Tournament results are visible to other participants), with service providers who help us operate the Platform, and where required by law.

Payment-related information is shared with our third-party, RBI-regulated payment gateway provider(s) to process Participation Fees, Tips, Prize Money and Referee payments. These providers process your information under their own privacy and security policies.

We may share limited information with fraud-prevention and security service providers to detect and prevent fraudulent registrations, payment fraud, multiple-account abuse, or manipulation of Predictions or Match results.

Information about the Predictions you make (such as which Match and outcome you selected) is used to determine Prediction results and, where applicable, promotional reward eligibility, and to detect abuse such as use of multiple accounts.

If you become eligible for a promotional reward linked to a Prediction, we may collect the information needed to deliver that reward (for example, to credit it to your account or, where applicable, process a payout).

When you send a Tip, we process the transaction details and the identity of the recipient Player or Team so the Tip can be delivered and reflected in your and the recipient's transaction history.

To distribute Prize Money, we (or our payment provider) may need to verify the identity and payment details of the recipient Team representative or individual Player, as described under KYC Information above.

Partner account and Tournament-management information is used to operate the Tournament-creation tools, process settlement of collected fees, and, where relevant, communicate with Sponsors about sponsorship opportunities linked to the Partner's Tournament.

Referee profile and assignment history is shared with Partners seeking to book a Referee for a Match, and Match-result submissions by a Referee are used to update fixtures and results.

Where a Sponsor engages with a Tournament through the Platform, we process the Sponsor's contact and sponsorship-tier information as needed to facilitate the sponsorship arrangement with the relevant Partner.

Technology & Analytics

The SPOTO website uses cookies and similar technologies to keep you logged in, remember preferences, and understand how the website is used. You can control cookies through your browser settings; disabling some cookies may affect website functionality.

We use analytics tools to understand feature usage and app performance (for example, which screens are used most, or where errors occur), so we can improve the Platform. Analytics data is generally aggregated and used for product improvement rather than to identify you individually.

Children and Safety

The Platform is intended for use by individuals who meet the eligibility requirements described in the Terms & Conditions. Certain features (such as receiving a payment) have minimum age requirements displayed at the relevant step. We do not knowingly collect personal information from children below the age at which they are permitted to use the relevant feature under applicable law.

Security & Retention

We use technical and organisational measures, including encryption of stored passwords and secure transmission of data, to help protect personal information against unauthorised access, alteration or disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

We retain personal information for as long as your account is active and as needed to provide the Platform's features. After account deletion, certain information may be retained for a limited period as described below and in the Account Deletion page.

You can request deletion of your account and associated personal information at any time through the Account Deletion page. We will act on verified deletion requests, subject to the limited retention described in the next section.

Even after account deletion, we may need to retain certain records where required for tax and accounting purposes, payment and transaction records, fraud-prevention records, security logs, resolution of an open dispute, or other legal compliance obligations, for the period required under applicable law.

Your Rights

Subject to applicable Indian data protection law, you may have rights to access the personal information we hold about you, request correction of inaccurate information, request deletion (as described above), and raise concerns about how your information is processed.

You can update most profile information directly within the app. For information you cannot update yourself, contact info@spotoapp.in with details of the correction needed.

Third Parties & International Processing

We engage third-party service providers for functions such as payment processing, cloud hosting, analytics, and customer support. These providers are given access only to the information needed to perform their function and are expected to protect it appropriately.

Some of our service providers (for example, cloud hosting or analytics providers) may process data on servers located outside India. Where this occurs, we take steps to ensure the provider offers an appropriate level of protection for the transferred information.

If we become aware of a data breach that is likely to risk your rights or interests, we will take reasonable steps to investigate, contain and remediate the breach, and will notify affected Users and relevant authorities where required by applicable law.

Platform Features

Location information collected to show nearby Teams, Tournaments or venues is used for that purpose and is not shared publicly with other Users beyond what is needed to display distance on a listing (for example, "2 km away").

Content you choose to share on the Platform, such as a profile photo, Team logo, or public comment, may be visible to other Users as part of the normal operation of the relevant feature.

We may send push notifications or in-app notifications relating to your account, Tournament updates, Match reminders, or Prediction/Tip activity. You can manage notification preferences through your device or app settings.

Where the Platform displays advertising or Sponsor branding, this is generally shown based on the Tournament or Platform context rather than individual profiling, unless we notify you otherwise and, where required, obtain consent for a different approach.

Where required by the operating system or applicable law (for example, Apple's App Tracking Transparency framework), we will request your permission before tracking your activity across other companies' apps or websites for advertising purposes.

Store Disclosures

Our Google Play Data Safety section reflects the categories of data actually collected and shared by the production SPOTO Android application, consistent with this Privacy Policy, and is kept up to date as the app's data practices change.

Our Apple App Store privacy "nutrition label" disclosures reflect the categories of data actually collected by the production SPOTO iOS application, consistent with this Privacy Policy, and are kept up to date as the app's data practices change.

Legal

We may disclose personal information where required to comply with a legal obligation, such as a valid request from a law enforcement or government authority, or to establish, exercise or defend a legal claim.

If Transkwik Private Limited is involved in a merger, acquisition, restructuring, or sale of assets, personal information may be transferred as part of that transaction, subject to this Privacy Policy or a policy offering at least comparable protection.

We aim to process personal information in a manner consistent with applicable Indian data protection law, including the Digital Personal Data Protection Act, 2023, as it comes into force and its rules are notified.

We may update this Privacy Policy from time to time. Material changes will be notified through the Platform or by email, and the "Last Updated" date at the top of this page will be revised.

For privacy-related grievances, contact our Grievance Officer at info@spotoapp.in. Full grievance-handling details are available on the Grievance Redressal page.

For any questions about this Privacy Policy or our data practices, contact info@spotoapp.in, or write to Transkwik Private Limited at the Registered Office or Head Office addresses listed above.

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info@spotoapp.in · Transkwik Private Limited
Registered Office: 1-83 Maddulaparva, NTR District, Andhra Pradesh – 521215, India
Head Office: Plot No. 1313, Vrushabadri Residency, Venkataramana Colony, KPHB, Hyderabad, Telangana – 500085, India
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