Last updated: July 2026

This Privacy Policy (“Policy”) applies to Spectacom Global Private Limited (“SGPL”, “Company”, “We”, “Us” or “Our”), a company incorporated under the Companies Act, 2013, having its registered office at 809 Udyog Vihar, Phase V, Gurugram, Haryana – 122016, India, and its subsidiaries, holding company and affiliates, wherever the context so requires. SGPL owns and operates the website www.devilscircuit.com and its associated mobile application (collectively, the “Platform”), through which SGPL organises sports events, obstacle races, and allied entertainment activities (“Services”).

This Policy describes how We collect, receive, store, use, process, disclose, transfer and otherwise handle information relating to You (“You”, “Your”, “User”, “Data Principal”) when You visit, register on, or otherwise interact with the Platform, register for, participate in, spectate at, or volunteer at Our events, or otherwise communicate with Us. This Policy does not apply to information collected by any third party, including third-party websites, applications or services that You may access through or in connection with the Platform, and We assume no liability in respect of the same.

Please read this Policy carefully before using or registering on the Platform, or accessing any content, information or Services through it.

By accessing or using the Platform, creating an account, registering for an event, or otherwise providing information to Us, You accept and agree to be bound by this Policy and consent to the collection, storage, use, processing, disclosure and transfer of Your information, including Personal Data (defined below), in the manner described herein. If You do not agree with this Policy, in whole or in part, You must not access or use the Platform or avail the Services.

This Policy is incorporated into, and must be read together with, Our General Terms & Conditions (“Terms”) and any event-specific Participant Waiver, Assumption of Risk and Consent Form that You execute in connection with an event (“Waiver Form”). In the event of any inconsistency between this Policy and a Waiver Form, solely in respect of health, medical or emergency-contact information disclosed for event participation, the Waiver Form shall prevail to the extent, and only to the extent, of such inconsistency; in all other respects, this Policy shall prevail. All capitalised terms used but not defined in this Policy have the meaning given to them in the Terms.

If You are under the age of 18 years: (i) You confirm that You are accessing the Platform through a parent or lawful guardian who is of legal age to form a binding contract under the Indian Contract Act, 1872, and that such person has accepted this Policy on Your behalf; and (ii) You confirm that You are accessing the Platform under the supervision of, and with the express permission of, such parent or guardian. Section 18 below sets out how We handle the Personal Data of minors and dependants in more detail.

We may update this Policy to reflect changes in Our practices or to comply with legal, regulatory or administrative requirements. Where We make a material change, We will provide reasonable notice, such as a prominent notice on the Platform and will update the “Last updated” date above. To the extent permitted by applicable law, Your continued use of the Platform after such notice constitutes Your acceptance of the revised Policy.

1. Definitions

• “Applicable Law” means the Information Technology Act, 2000 and rules made thereunder, the Digital Personal Data Protection Act, 2023 and rules made thereunder, and any other law, regulation, rule, notification or governmental order applicable to the collection, storage, use, processing, disclosure or transfer of information under this Policy, in each case as in force and to the extent applicable from time to time.
• “Data Principal” means the individual to whom the Personal Data relates, and includes “You” as used in this Policy.
• “Data Fiduciary” means SGPL, which determines the purpose and means of processing of Personal Data under this Policy.
• “Personal Data” means any data about an individual who is identifiable by or in relation to such data, including the categories described in Section 2
• “Services” means the organisation of sports events, obstacle races, sports entertainment and allied activities offered by SGPL, and any ancillary products, merchandise, or content offered in connection therewith.
• “Event Media” means photographs, video, audio and other recordings of participants, spectators and attendees captured by or on behalf of SGPL at or in connection with an event.
• “Post” means any feedback, review, comment, photograph or other content that a User voluntarily uploads to a publicly viewable area of the Platform.

2. Information We Collect

We collect the following categories of information about You, directly from You, automatically through Your use of the Platform, and, in limited circumstances, from third parties as described in this Section:

(a) Personal Data provided by You

This includes Your complete name, mobile number, email address, date of birth, gender, age, residential or billing address; government-issued identification details such as PAN, passport, driving licence, voter identification, or a masked or last-four-digits Aadhaar reference (the Company does not collect or store full Aadhaar numbers except where expressly permitted by law); income, business or professional details where relevant to an event category; team name, emergency contact details, category of participation and prior race history; health, medical and lifestyle information voluntarily disclosed by You; and any other information You voluntarily provide through the Platform, a Waiver Form, customer support, surveys, contests or Our social media channels.

Provision of this information is voluntary; however, certain information is mandatory for specific Services (such as event registration, or the processing of a payment or insurance claim), and Your inability or unwillingness to provide such mandatory information may mean We cannot provide the corresponding Service to You. Wherever feasible, We will indicate which fields are mandatory and which are optional.

(b) Sensitive categories of Personal Data

Certain of the information above— passwords; financial or payment instrument details; physical, physiological and mental health condition; medical records and history; and biometric information (including, where used, facial-recognition data generated for event photo-matching or timing purposes) requires a heightened standard of care and, where required by Applicable Law, Your explicit consent. Our facial-recognition and photo-matching technology is developed and operated in-house by SGPL, using certain third-party artificial-intelligence tools and service providers where necessary for this functionality; photographs captured for this purpose are initially stored by event photographers on physical storage media (data cards), which remain Our property and are returned to Us following the event, and access to this data, including where processed by a third-party service provider engaged by Us, is restricted to authorised personnel. Sections 5 and 6 describe how We collect, use and protect Health Information and Event Media specifically. Any information that is freely available or accessible in the public domain, or furnished under the Right to Information Act, 2005 or any other law for the time being in force, is not treated as Personal Data for the purposes of this Policy.

(c​) Transactional information

Where You avail Services through the Platform, We collect and store information about Your transactions, including transaction status, order and registration history, and Your interactions and preferences on the Platform. Where You complete a transaction with Us offline, including a corporate or bulk booking or an on-ground purchase, We collect and store the corresponding transactional information directly, and such information is subject to the same protections described in this Policy. This information is stored on servers, log files and storage systems owned by Us or by Our service providers. We also process one-time passwords and similar short messages used to verify Your device and secure Your account.

(d) Location and device information

Where You access the Platform through a mobile device, We may receive information about Your approximate or precise location (where You have granted the relevant device permission), IP address, device model, operating system, browser type and unique device identifiers. You may withdraw location-tracking consent at any time through Your device settings, though this may affect certain Platform functionality. We also use Your IP address to diagnose and resolve technical issues, administer the Platform, and derive broad, non-identifying demographic information.

(e) Information from third parties

We may receive information about You from event co-organisers, sponsors, payment gateways, ticketing partners, analytics providers, and background-verification providers, where such third parties are lawfully entitled to share the information with Us and represent to Us that they have obtained all consents necessary to do so.

(f) Non-Personal Information and cookies

We, and our authorized third-party partners, collect non-identifying and automated information—including but not limited to browser type, internet service provider, aggregate usage data, IP addresses, operating systems, session identification numbers, and cookie data—through cookies, web beacons, clear GIFs, pixel tags, and similar tracking technologies placed on the Platform. These technologies are deployed to ensure our Platform functions securely, to optimize performance, remember your preferences, analyze traffic trends, measure promotional efficacy, and maintain architectural security.

We categorize these tracking technologies as follows:

• Strictly Necessary Cookies: Mandatory for core operations, security protocols, system administration, and account authentication. These cannot be deactivated, and any attempt to block them may severely degrade or completely disrupt Platform functionality.
• Analytical/Performance Cookies: Allow us to recognize, track, and count visitors, analyze navigation patterns, and evaluate how users interact with the Platform. This includes our utilization of Google Analytics (a service provided by Google Inc.) which tracks anonymous traffic data. You acknowledge that data generated by these cookies (including IP addresses) may be transmitted to and stored by Google on servers outside of India, and is processed subject to Google’s independent privacy practices. SGPL disclaims all liability for data processing executed by Google or its sub-processors.
• Functionality Cookies: Implemented to recognize your device upon return, enabling us to automatically restore your customized preferences and settings.
• Commercial/Targeting Cookies: Placed by us or carefully selected third-party advertising networks to deliver targeted advertisements, track cross-platform user activity, and evaluate marketing campaign efficacy.

You may occasionally encounter cookies deployed by third-party companies, sponsors, or advertisers via hyperlinks or embedded content on the Platform. SGPL does not control, review, or supervise these third-party cookies. They are entirely exempt from this Policy, and you agree that SGPL bears no responsibility or legal liability for any data processing or privacy breaches occurring through your interaction with such third-party sites.

You retain the capability to accept, decline, or modify cookie configurations. While you may attempt to withdraw or modify your cookie tracking choices by adjusting your individual browser settings to decline tracking or by purging your browser cache, you acknowledge that doing so is at your own operational risk. If you block essential cookies, SGPL is completely absolved of any failure to provide functional Services or a secure user experience.

Separate from automated site data, you expressly agree that if you transmit personal correspondence to us (such as emails, letters, or support requests), or if other users or third parties forward correspondence to us regarding your specific activities, entries, or postings on the Platform, SGPL reserves the unconditional right to collect, compile, and store such information within our systems for security, verification, and legal defence purposes

3. How We Use Your Information

We use the information described in Section 2 for the following purposes (collectively, the “Purposes”):

1. a) to create and verify Your account, identity and access privileges;
2. b) to register You for, and enable Your participation in, Our events and Services, and to improve those Services;
3. c) for internal business purposes, including event operations, logistics, IT support and data analysis;
4. d) to resolve disputes, manage Your requests and complaints, and diagnose and troubleshoot technical problems;
5. e) to promote a safe environment at Our events and on the Platform, and to protect the security and integrity of the Platform, the Services and participants, spectators and volunteers;
6. f) to design and improve Our Services and customer-relationship processes;
7. g) to collect payment from You for the Services;
8. h) to inform You about Our events, offers and updates;
9. i) to customise Your experience on the Platform;
10. j) to detect, prevent and investigate fraud and other unlawful or prohibited activity in connection with the Platform or an event;
11. k) to enforce Our Terms and this Policy;
12. l) to process and fulfil Your requests, and respond to Your comments and queries;
13. m) to audit, monitor and enhance Our internal processes;
14. n) to contact You through email, SMS, WhatsApp, telephone or other channels in relation to the Services;
15. o) to enable Our service providers, sponsors and event partners to communicate with You in connection with the Services You have requested or an event You are registered for;
16. p) to identify and respond to security incidents and threats, and to support audits or investigations by Us or by regulatory authorities in India or abroad;
17. q) to communicate important notices or changes to the Services, the Platform, this Policy or the Terms;
18. r) to comply with legal, regulatory and reporting requirements applicable to Us;
19. s) to perform Our obligations, and enforce Our rights, under any contract between You and Us; and
20. t) for any other purpose that is reasonably related to, and consistent with, the specific purposes listed above, or for which We have separately obtained Your consent at the time of collection.

Where We conduct optional surveys, We use Your responses to tailor Your experience and to send You personalised offers and communications through channels such as email, WhatsApp, SMS or push notification. You may opt out of promotional communications; You cannot opt out of administrative, transactional or safety-related communications necessary for Us to provide the Services. We may monitor or record calls or chats with Our customer support team for training, quality, legal compliance, or to establish or defend a legal claim. We will not share Your Personal Data with another User of the Platform without Your express consent, other than as reasonably necessary to operate a team-based or group event registration You have opted into.

4. Health and Medical Information (Event Participation)

Where You register for or participate in an SGPL event, We, directly or through independent on-ground medical personnel engaged by Us, may collect health information disclosed by You in a Waiver Form, registration form, or medical declaration, or generated at the venue during or after the event, including by paramedical or ambulance personnel responding to an incident (“Health Information”). We use Health Information solely to: (a) assess Your fitness or eligibility to participate; (b) enable on-ground medical, paramedic and safety personnel to respond appropriately to an injury or medical emergency; (c​) process insurance or liability claims arising from the event; and (d) comply with event-safety and other applicable regulatory requirements.

Health Information is shared strictly on a need-to-know basis, and only with Our on-ground medical and safety team; empanelled event insurers, solely for claims processing; emergency responders, hospitals and ambulance services, where necessary to respond to a medical emergency; and, where legally required, regulatory or law-enforcement authorities. Health Information is never used for marketing, profiling or any commercial purpose, and is never sold or licensed to any third party. We retain Health Information only for as long as necessary for the purposes above and for the applicable limitation period for injury-related or insurance claims under Applicable Law.

By executing a Waiver Form and disclosing Health Information, You provide the explicit consent required under Applicable Law for the processing of this category of information, on the terms set out in this Section and the Waiver Form.

5. Event Photography, Videography and Likeness

At Our events, We and Our photography, videography, broadcast and media partners may capture Event Media of participants, spectators and attendees, including through fixed cameras, drone footage, and, where deployed for a particular event bib-scanning used solely to help participants locate their own event photographs and to verify race results and timing.

By registering for or attending an event, You grant SGPL and its licensees, sponsors and media partners a worldwide, perpetual, irrevocable, royalty-free, non-exclusive licence to use, reproduce, publish, broadcast, adapt and distribute Event Media featuring You for event highlights, archival records, results and timing verification, and for Our promotional, marketing and sponsorship activities, including on social media, television and sponsor content, subject to the Waiver Form and Terms applicable to the event.

6. How We Share Your Information

We may disclose Your information, including Personal Data, to the following categories of recipients, for the Purposes described in this Policy:

1. a. Our affiliates, group companies, personnel, agents and professional advisors, for the Purposes and for accounting, tax, audit and administrative purposes;
2. b. service providers and data processors who process information on Our behalf, including IT and hosting providers, analytics providers, payment gateways, ticketing platforms, logistics partners, timing and results providers, AI-based photo-matching and facial-recognition service providers, and event-management contractors, each of whom is engaged under a written agreement that requires confidentiality and data-protection obligations at least equivalent to those undertaken by Us under this Policy, including appropriate technical and organisational security measures;
3. c. co-organising, cooperation or sponsorship partners in connection with a jointly organised event or promotion, who may separately process Your information under their own privacy policy, which We recommend You to review;
4. d. courts, tribunals, regulators, the Data Protection Board of India, law-enforcement or other government authorities, where required by Applicable Law, a court order, or a valid governmental request;
5. e. any party as reasonably necessary to protect the rights, property, safety or interests of SGPL, Our personnel, participants, sponsors or the public, or to investigate suspected fraud, safety incidents or unlawful activity; and
6. f. a successor entity in connection with a merger, acquisition, sale of assets, or restructuring of SGPL’s business, provided such entity remains bound by the terms of this Policy in respect of Personal Data already collected; We will notify You of any such change through the Platform or other reasonable means.

We do not sell Your Personal Data to any third party for monetary consideration. We may share aggregated or anonymised information, which does not identify You, with third parties at Our discretion, including for research, analytics or promotional purposes.

7. Cross-Border Transfer of Personal Data

Your Personal Data may be stored, hosted or processed on servers located outside India, including by Our cloud infrastructure and IT service providers. We will only transfer Personal Data outside India in accordance with Applicable Law, and will not transfer Personal Data to any country or territory restricted by the Central Government of India from time to time under Section 16 of the Digital Personal Data Protection Act, 2023. Where We transfer Personal Data outside India, We will require the recipient to be contractually bound to apply protections substantially equivalent to those required of Us under this Policy and Applicable Law. To the extent feasible, We endeavour to store Personal Data and health-related data within India.

8. Data Security

We maintain reasonable security safeguards and procedures, including technical and organisational measures to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration, in compliance with applicable laws

You are responsible for maintaining the confidentiality of Your Account credentials and for all activity that occurs under Your Account. You agree to notify Us immediately of any unauthorised use of Your Account or any other suspected breach of security, and to log out of Your Account at the end of each session. We are not liable for loss or damage arising from Your failure to keep Your login credentials, password or one-time passwords confidential; please never share these with anyone, including anyone claiming to represent SGPL.

Payment information transmitted through the Platform is protected using industry-standard encryption. While We take reasonable steps to secure Your information, no method of transmission or storage is completely secure, and We cannot guarantee absolute security against a sufficiently determined unauthorised third party. Subject always to Our statutory obligations, We are not liable for unauthorised access, disclosure or loss of Your information that results from causes beyond Our reasonable control, including a security breach on a third-party website or platform, or a Force Majeure Event.

A “Force Majeure Event” means any event beyond Our reasonable control, including but not limited to acts of God, fire, explosion, war, civil unrest, strikes, epidemic or pandemic, governmental action or restriction, or failure of a third-party hosting, telecommunications or internet service provider.

9. Personal Data Breach Notification

If We become aware of a personal data breach that affects Your Personal Data, We will, in accordance with Applicable Law, notify the Data Protection Board of India and take reasonable steps to notify affected Data Principals without undue delay.

10. Retention of Personal Data

We retain Personal Data only for as long as necessary to fulfil the Purposes for which it was collected, including to meet legal, accounting, insurance, safety or reporting requirements, or as otherwise required or permitted under Applicable Law. As a general guide: account and registration data is retained for the duration of Your relationship with the Platform and for a reasonable period thereafter to address post-event queries and claims; transactional and payment data is retained in accordance with applicable financial record-keeping requirements; Health Information is retained as described in Section 4; biometric and facial-recognition data generated for event photo-matching or timing purposes is retained by Us and by any third-party service provider engaged for this purpose, save where retention for a longer period is necessary to resolve a dispute or claim; and Event Media is retained for archival, results-verification and promotional purposes for as long as it continues to serve those purposes, consistent with the licence described in Section 5.

Where You request erasure of Your information, We will honour that request, save that We may retain certain information where permitted or required by Applicable Law including to prevent fraud or abuse, to exercise or defend a legal claim, or to comply with a legal or regulatory obligation.

11. Third-Party Links and Embedded Content

The Platform may contain links to, or embed content from, third-party websites or platforms, including payment gateways, event-registration partners, sponsor microsites, and social-media plug-ins (“Third-Party Sites”). This Policy does not apply to, and We accept no responsibility for, the privacy or data-security practices of any Third-Party Site, which are governed solely by that Third-Party Site’s own privacy policy. We recommend You to review the privacy policy of any Third-Party Site before providing information to it.

12. User-Generated Content and Public Posts

Any Post that You voluntarily submit to a publicly viewable area of the Platform may be viewed by other Users and is not governed by the confidentiality protections of this Policy. By submitting a Post, You grant SGPL a non-exclusive, worldwide, royalty-free, sub-licensable licence to use, reproduce and display that Post for the Purposes described in this Policy, including promotional use. We reserve the right, but assume no obligation, to remove or moderate a Post that violates Our Terms or Applicable Law. Please exercise discretion before posting Personal Data in a public area of the Platform, as We are not responsible for information You choose to make public.

13. Your Rights as a Data Principal

All information You disclose to Us is deemed to be disclosed willingly. We process Your Personal Data on the basis of Your consent, or, where permitted under Applicable Law, on the basis of a legitimate use recognised by the Digital Personal Data Protection Act, 2023 alongwith the notified rules. If You share Personal Data about another individual with Us, You confirm that You have the authority to do so and that the individual concerned has been made aware of, and does not object to, this Policy applying to their information.

You may exercise the following rights by writing to info@devilscircuit.com, or through the Platform’s Settings, where available. We will acknowledge Your request within a reasonable time and respond substantively such period as Applicable Law may prescribe, and We may need to verify Your identity before actioning a request:

1. (a) Right to access: to obtain a summary of the Personal Data We hold about You and the processing activities undertaken;
2. (b) Right to correction and updation: to have inaccurate or incomplete Personal Data corrected or completed;
3. (c​) Right to erasure: to request deletion of Your Personal Data that is no longer necessary for the purpose for which it was collected, subject to Section 10;
4. (d) Right to withdraw consent: to withdraw consent at any time, with effect from the date of withdrawal and without affecting the lawfulness of processing carried out before withdrawal; on withdrawal, We will cease the corresponding processing and, subject to Section 10, delete or anonymise the relevant Personal Data within a reasonable period, save that if You withdraw consent or decline to provide mandatory information, We may be unable to continue providing the corresponding Service to You;
5. (e) Right to nominate: to nominate another individual to exercise Your rights under this Policy in the event of Your death or incapacity;
6. (f) Right to grievance redressal: to raise a grievance with Our Grievance Officer (Section 15), and, if unsatisfied with Our response, to escalate to the competent supervisory authority; We encourage You to use Our grievance mechanism first so that We have a fair opportunity to address Your concern.

You should be aware that information You have shared on a third-party website, or that another User has independently copied or re-shared, may remain available even after You delete it from the Platform, as this is outside Our control. You should only share Personal Data with people You trust.

14. Marketing Communications

We will only send You promotional or marketing communications (as distinct from transactional, administrative or safety-related communications necessary for Us to provide the Services) where You have provided the consent required under Applicable Law. You may withdraw Your marketing consent at any time through the Platform’s Settings or by writing to info@devilscircuit.com, and We will act on that request within a reasonable time. This Section does not affect Our ability to send You transactional, administrative or safety-related communications relating to an event You have registered for.

15. Grievance Officer and Contact

We have appointed the following Grievance Officer to address questions, concerns or grievances regarding this Policy or Our handling of Your Personal Data, and to assist You in exercising Your rights:

Name: Neelesh Kumar

Designation: Grievance Officer

Email: info@devilscircuit.com

Postal Address: Spectacom Global Private Limited, 809 Udyog Vihar, Phase V, Gurugram, Haryana – 122016, India

We will acknowledge Your query or grievance and aim to resolve it within a reasonable period. If You suspect any misuse of, or unauthorised access to, Your Personal Data, please let Us know immediately at the email above.

16. Third-Party Hosting and Sub-Processors

Certain data collected through the Platform is stored with reputable third-party cloud infrastructure providers, which may store such data on servers located outside India, subject to Section 7. Any such provider is contractually required to maintain security measures consistent with this Policy and Applicable Law.

17. Third-Party Processing — Limitation of Liability

We are not responsible for, and disclaim liability in connection with, the security practices, content or privacy policies of a Third-Party Site or a third-party service provider engaged by You independently of SGPL, including where that third party has independently obtained Your Personal Data.

18. Children and Persons Requiring Guardian Consent

The Platform and Our Services are, as a general rule, intended for individuals who are at least 18 years of age. Where SGPL permits participation by a minor in a specific event or category (including junior or family categories), or where a person with a disability requires a lawful guardian to exercise legal rights, We will collect the personal data of such minor or dependant, including any Health Information disclosed in a waiver form, only upon receipt of the signed consent of the parent or lawful guardian, executed by countersigning the applicable waiver form and uploading the same to the Platform. The parent or guardian signing on the minor’s or dependant’s behalf represents and warrants that they are the lawful parent or guardian of the minor or dependant. Such parent or guardian exercises all rights under this Policy on the minor’s or dependant’s behalf and is responsible for the accuracy of the information provided.

We do not knowingly use a minor’s Personal Data for behavioural monitoring, tracking or targeted advertising, except where such processing is undertaken with the parent or guardian’s consent obtained as described above, for the minor’s health, safety or well-being in connection with an event. Where We become aware that a minor’s Personal Data has been provided to Us without the requisite parent or guardian consent described above, We will take reasonable steps to promptly obtain such consent or, failing that, to delete the relevant Personal Data and suspend the corresponding account.

19. Changes to this Policy

We may update this Policy from time to time as described above. We encourage You to review this Policy periodically. Your continued use of the Platform following notice of a change constitutes Your acceptance of the updated Policy.

20. Severability

If any provision of this Policy is held to be invalid, illegal or unenforceable under Applicable Law, that provision will be severed from this Policy, and the remaining provisions will continue in full force and effect and will be interpreted so as to reasonably achieve the intent of the severed provision to the extent permitted by Applicable Law.

Spectacom Global Pvt Ltd © 2026. All rights reserved.