Spy Eye Intelligence Network LLP (“SPIN”, “we”, “us” or “our”) respects the privacy of individuals who visit our website, contact us, request assistance or use services made available through SPIN.
This Privacy Policy explains how SPIN may collect, use, store, disclose, protect and otherwise process personal data in connection with:
This Privacy Policy should be read together with SPIN's Terms of Service and other applicable policies or engagement-specific documentation.
Spy Eye Intelligence Network LLP (SPIN) is a cyber-intelligence and forensic-services platform that connects individuals and organisations seeking cyber-investigation or forensic assistance with suitable independent cyber investigators and forensic specialists.
SPIN also provides an organisational framework around engagements, including case onboarding, expertise-based allocation, case monitoring, coordination, quality assurance and escalation.
Because of the nature of cyber-investigation and digital-forensic services, information handled by SPIN may sometimes be highly confidential, case-sensitive or evidentiary in nature.
This Privacy Policy applies to personal data processed by SPIN in connection with its website and services.
It may apply to information relating to:
Engagement-specific privacy, confidentiality or evidence-handling requirements may apply in addition to this Policy.
The information collected will depend on how you interact with SPIN and the nature of the matter.
This may include:
When you contact SPIN about a cyber, forensic or digital matter, we may collect information such as:
Where relevant to an accepted matter, SPIN or an assigned specialist may receive or examine digital information such as:
The categories actually processed will depend upon the agreed scope of the service.
Some SPIN engagements may involve information of a particularly private or sensitive nature, for example:
Where appropriate, SPIN may apply additional controls such as:
A cyber investigation or forensic engagement may necessarily involve information relating to persons other than the customer.
For example, case information may contain:
Where you provide personal data relating to another person, you should have an appropriate lawful basis, authority or legitimate reason for providing that information to SPIN.
SPIN may request evidence of authority where appropriate.
SPIN may obtain personal data:
SPIN does not obtain personal data through unauthorised access to accounts, devices or systems.
SPIN may process personal data for purposes including:
SPIN processes personal data only where there is an appropriate basis for doing so under applicable law.
Depending on the circumstances, processing may occur:
Where consent is specifically required, SPIN will seek consent in an appropriate manner.
SPIN seeks to process personal data that is reasonably necessary for the relevant purpose.
Because investigations can contain large amounts of digital information, SPIN will, where reasonably practicable:
Customers are also requested not to submit passwords, OTPs, private keys, seed phrases or unnecessary sensitive evidence through general website forms.
Where particular evidence is required, SPIN may identify an appropriate method of providing it.
SPIN operates through a network of independent cyber investigators and forensic specialists.
Where a specialist is assigned to a matter, SPIN may provide that specialist with personal data and case information reasonably necessary to perform the agreed work.
Access is intended to be based upon:
Assigned specialists are expected to comply with applicable confidentiality, professional, evidence- handling and data-protection requirements.
SPIN does not make all customer or case information available to its entire investigator network.
Depending on the circumstances, personal data may be disclosed to:
SPIN seeks to limit disclosure to information reasonably necessary for the relevant purpose.
Information may be disclosed where SPIN is required to do so under:
Where legally permissible and appropriate, SPIN may also support a customer's authorised engagement with law-enforcement agencies, courts, tribunals, platforms or other institutions by providing relevant technical information or evidence.
SPIN services are not intended to enable children to independently commission investigative or forensic engagements where parental, guardian or other lawful authority is required.
Where a matter involves a child, SPIN may process information concerning the child where necessary and lawfully appropriate.
Such matters may be subject to additional:
Where applicable safeguarding or statutory reporting obligations arise, those requirements may take precedence over ordinary investigation procedures.
Where a customer uses an ongoing monitoring service, SPIN may process agreed identifiers such as:
Such identifiers may be compared against or monitored across lawfully accessible sources relevant to the service.
Monitoring will be limited by the agreed scope, available sources and lawful technical capabilities.
SPIN does not require customers to provide active account passwords merely for ordinary monitoring purposes.
Certain SPIN services involve reviewing publicly available information, open-source intelligence, breach-intelligence sources or appropriately accessible deep-web or dark-web intelligence sources.
SPIN intends to use only lawful access methods and appropriately authorised or accessible sources.
Monitoring or investigation of such information does not mean that SPIN participates in unlawful forums, transactions or unauthorised access.
Where information forms part of digital evidence, ordinary deletion or modification practices may not always be appropriate during an active investigation.
Evidence may need to be preserved:
The handling of evidentiary material may therefore differ from ordinary business records.
Detailed requirements shall be addressed through other relevant policies of SPIN.
SPIN intends to retain personal data only for as long as reasonably necessary for the purpose for which it was processed, subject to applicable legal, evidentiary, contractual and operational requirements.
Different retention periods may apply to:
Information constituting evidence or forming part of a legal, regulatory or investigative matter may need to be retained for a longer period.
Detailed requirements governing the retention, review, deletion and secure disposal of personal data and case information are set out in relevant policies of SPIN on data retention and secure disposal.
When information is no longer required and there is no lawful, contractual, evidentiary or operational reason to retain it, SPIN may delete, destroy, anonymise or otherwise securely dispose of the information, as appropriate.
Methods of disposal may vary depending on:
SPIN seeks to implement reasonable technical and organisational measures appropriate to the nature of the information being processed.
Depending on the circumstances, these may include:
SPIN will seek to implement reasonable security safeguards and appropriate technical and organisational measures in accordance with applicable data-protection requirements, including the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025, as and when the relevant provisions become legally applicable.
However, transmission, storage and processing of data through electronic networks and systems inherently involve security risks. No technical or organisational security measure can provide absolute protection against every possible security incident.
Accordingly, even where SPIN has implemented applicable reasonable security safeguards, SPIN cannot guarantee absolute immunity from events including zero-day vulnerabilities or exploits, advanced persistent threats (APTs), state-sponsored or highly sophisticated cyber intrusions, distributed denial-of-service (DDoS) attacks, malicious software outbreaks, hardware or infrastructure failures, or other adversarial attacks capable of circumventing or defeating reasonable security safeguards.
The existence of such inherent technical risks does not reduce SPIN's obligation to implement security safeguards required under applicable law.
Where SPIN becomes aware of a personal-data breach affecting information under its control, it will take appropriate measures in accordance with applicable law, which may include assessing the breach, undertaking containment and forensic or technical investigation, mitigating potential harm, preserving relevant information or logs, undertaking appropriate remedial measures and taking reasonable steps intended to prevent recurrence.
Where applicable law requires notification, SPIN will notify affected Data Principals, the Data Protection Board of India or another competent authority in the form, manner and timeframe prescribed under the applicable legal requirements.
Such notifications may include information regarding the nature and extent of the breach, its possible consequences, measures taken or proposed in response to the breach, recommendations or protective measures for affected Data Principals and applicable contact information, to the extent required by law.
SPIN's obligations in relation to a personal-data breach will be determined by the applicable provisions of the Digital Personal Data Protection Act, 2023, the Digital Personal Data Protection Rules, 2025 and any other applicable law, rule, direction or legally binding requirement.
Compliance by SPIN with applicable breach-containment, mitigation, remediation and notification obligations does not limit any statutory right or remedy that cannot lawfully be excluded or restricted.
To the extent permitted by applicable law, SPIN, its Designated Partners, employees and empanelled investigators or forensic specialists will not be liable for unauthorised access, alteration, loss, unavailability or compromise of information to the extent directly caused by events beyond their reasonable operational control and notwithstanding the implementation of applicable reasonable security safeguards.
Such events may include regional or widespread telecommunications or internet disruptions, failures of critical third-party infrastructure, cyber warfare, state-sponsored sabotage or intrusion, unusually severe or widespread malware outbreaks, natural disasters, acts of God, or other comparable events that could not reasonably have been prevented or mitigated through the security safeguards required under applicable law.
Nothing in this section excludes or limits any responsibility or liability that cannot lawfully be excluded or limited.
By transmitting files, digital evidence, personal data or other information to SPIN, or by commissioning or using SPIN's services, you acknowledge that electronic transmission, storage and processing involve inherent technical and cybersecurity risks that cannot be completely eliminated.
Where SPIN has implemented the reasonable security safeguards required under applicable law, then, to the extent permitted by applicable law, SPIN will not be liable for indirect, incidental, consequential, special or punitive loss or damage arising solely from a third-party cyberattack or other external malicious act that circumvents such safeguards and is beyond SPIN's reasonable operational control.
This acknowledgement of inherent risk does not waive, restrict or exclude any statutory right, obligation or liability that cannot lawfully be waived, restricted or excluded.
SPIN may serve customers or work with specialists, service providers or institutions located in different jurisdictions.
Accordingly, personal data may, where necessary and legally permitted, be accessed or processed outside the location in which it was originally collected.
Where cross-border processing occurs, SPIN will seek to comply with applicable requirements governing such transfers or access.
Where applicable law restricts the transfer of particular personal data to specified jurisdictions, SPIN will apply those restrictions.
Depending upon applicable law and the circumstances, you may have rights relating to your personal data.
These may include rights to:
These rights may be subject to lawful limitations.
For example, SPIN may not be able to delete information immediately where retention is necessary for:
Where personal data is processed on the basis of consent, you may request withdrawal of that consent in accordance with applicable law.
Withdrawal will not ordinarily affect processing already lawfully undertaken before the withdrawal.
Depending on the service, withdrawal may also mean that SPIN cannot continue providing some or all of the requested assistance.
Where information must continue to be retained or processed for another lawful reason, withdrawal of consent will not require SPIN to act contrary to that lawful requirement.
You should provide information that is accurate and complete to the best of your knowledge.
Where information materially changes during an engagement, you should inform SPIN where the change is relevant to the service.
SPIN may request clarification or additional documentation where reasonably necessary to verify information or authority.
When you use the SPIN website, certain technical information may be processed automatically, such as:
Such information may be used for:
Use of cookies and similar technologies, where applicable, will be addressed separately through relevant policies of SPIN.
SPIN does not sell personal data as a business activity.
Personal data may be shared only where reasonably necessary for SPIN's services, operations, legal obligations or other purposes described in this Privacy Policy.
SPIN's website or services may contain links to or involve interaction with third-party websites, platforms, banks, exchanges or other service providers.
Their privacy practices are governed by their own policies.
SPIN is not responsible for the privacy practices of independent third-party platforms merely because a link, reporting process or recovery procedure involves those platforms.
Privacy and confidentiality are related but distinct.
This Privacy Policy primarily explains how SPIN processes personal data.
Additional obligations regarding:
may be addressed through Terms of Service of SPIN and engagement-specific documentation.
If you have a concern about how SPIN has processed your personal data, you may raise it with SPIN through its designated grievance mechanism.
Grievance Officer: Mr. Gaurav Banerjee
Grievance Officer Designation: Director – Operations and Compliance
Grievance Officer Email: contact@spyeye.org
Please provide sufficient information to enable SPIN to understand and appropriately examine the grievance.
SPIN's broader complaint-handling process will be described in its Grievance Redressal Mechanism.
Where applicable law provides a further statutory remedy or right to approach the Data Protection Board of India or another competent authority, those rights remain unaffected.
Requests relating to access, correction, updating, erasure, withdrawal of consent or other applicable privacy rights may be submitted to:
Data Protection Officer: Mr. Gaurav Banerjee
Data Protection Officer Designation: Director – Operations and Compliance
Data Protection Officer Email: contact@spyeye.org
SPIN may need to verify your identity before acting on a request.
Where the request concerns information relating to another person, SPIN may also require proof of authority.
SPIN may update this Privacy Policy from time to time to reflect:
The updated Privacy Policy will be published on the SPIN website together with the revised Last Updated date.
Where required by applicable law, additional notice or consent may be sought for material changes.
SPIN intends to process personal data in accordance with applicable data-protection and privacy requirements.
This includes, where and to the extent applicable, requirements under the Digital Personal Data Protection Act, 2023, the Digital Personal Data Protection Rules, 2025, and other applicable laws, rules, directions and legal obligations.
Where provisions of applicable data-protection law come into force on different dates, SPIN will apply the requirements relevant to the processing activity from the date on which they become legally applicable.
For questions about this Privacy Policy or SPIN's handling of personal data:
Spy Eye Intelligence Network LLP (SPIN)
Registered Office: Rajahmundry, Andhra Pradesh, India.
Email: contact@spyeye.org
Phone: +91 877 762 8651
Privacy Contact:
Data Protection Officer: Mr. Gaurav Banerjee
Data Protection Officer Designation: Director – Operations and Compliance
Data Protection Officer Email: contact@spyeye.org
Grievance Contact:
Grievance Officer: Mr. Gaurav Banerjee
Grievance Officer Designation: Director – Operations and Compliance
Grievance Officer Email: contact@spyeye.org
This Privacy Policy explains SPIN's general approach to personal-data processing.
Depending upon the nature of an engagement, additional privacy, confidentiality, evidence-handling, data-retention or security requirements may be specified through:
Where a case requires heightened privacy or safeguarding, additional controls may be applied according to the nature and sensitivity of the matter.