- Section 43A of the Information Technology Act, 2000 (“IT Act”);
- Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”); and
- Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
Consent for Providing Information of Third Parties
We collect the following types of information about You when You use Our Platforms: Behavioural Information, Account Information and Payment Information (collectively, “Information”).
We may collect information about how You use the Platforms and information about Your mobile device and software including usage statistics, traffic data, Your IP address, browser and operating system type, type of network connectivity, domain names, access times and locations, log and usage data (such as clicks and navigation) and browsing history (collectively, “Behavioural Information”).
We may collect information about Your name, email address, date of birth, phone number, Facebook account ID and sign-in information, Facebook profile photo, Facebook account ID of Facebook friends, Google account ID, PAN Number, selfie picture, picture of any of the government issued photo identity and address proof such as driving license, voter ID, Aadhaar card, passport and other associated details required for Your KYC forms, PAN card, contact details from your mobile address book, and details of your WhatsApp profile (collectively, “Account Information”).
We may also collect Your bank account number (for receiving credit of your winnings), UPI handle, transaction information, payment history, and amount of monies debited and credited to your account (collectively, “Payment Information”).
The IT Act and the SPDI Rules regulate the collection, usage, retention and disclosure of personal information. As per the SPDI Rules, personal information refers to any information that can directly or indirectly be used to identifying a person (“Personal Information”).
Further, “Sensitive Personal Data or Information” (“SPDI”) of a person includes Personal Information about that person relating to:
- financial information such as details of their bank accounts, credit and debit card or other payment instrument;
- physical, physiological and mental health condition;
- sexual orientation;
- medical records and history; and
- biometric information.
You may choose to not provide Us with any or all Information especially SPDI, but in the event that You do so, We will be unable to provide You with Our Services.
Use of the Personal Information
Personal Information shall be collected, stored, processed and used only for the following purposes:
- To identify You as a legitimate, bona fide, human user of the Platforms;
- To provide You with improved services and features on the Platforms;
- To notify You of various aspects of the offerings on the Platforms;
- To notify You of offers on products and services, offered by the Company;
- To improve Platform experience and Our business as a whole;
- To create a community of Users;
- Personalize the Services, content and features that match User profiles or interests;
- Provide customer service;
- To respond to any queries that You may have, and to communicate information to You, including notifications of any promotions or alerts, any updates to the Platforms, or the introduction of any future fees or charges that We may collect at the time for the provision of Our Services to You;
- To contact You from time to time to record Your valuable feedback on Our Services, as they currently stand, and/or any potential Services that may be offered in the future;
- Help protect the safety of the Company and our users, which includes blocking suspected spammers, addressing abuse, and enforcing the Company user agreement and Our other policies;
- To provide You with the Services;
- To facilitate the opening of an account for the undertaking of any transactions chosen by You;
- To enable transfer of winnings to Your designated bank account;
- To comply with applicable law;
- For any other purposes permitted by applicable law; and
Additionally, Your SPDI is collected and used for the following purposes:
The Company will not sell, rent, or license Your Personal Information to any third party.
Disclosure of Information
We may disclose Your Information including Personal Information, as the case may be to third parties in the manner specified below:
Disclosing Your Account Information, Behavioural Information and Payment Information to companies and individuals who are authorised by Us to perform functions in relation to the Services, such as payment gateway providers and security consultants;
We may share Your Information with Our partners, affiliates, investors, stakeholders or potential associates in an anonymized and aggregate manner, so that they too may understand how Users use Our Platforms, and enable Us to create a better overall experience for You or for the purposes of generating analytics to improve the App and offer better Services to You;
We may disclose and transfer Your Information to a third party who acquires, or may potentially acquire, Our business, whether such acquisition is by way of a merger, consolidation or purchase of all or a substantial portion of Our assets; and
We will disclose Your Information if legally required to do so, pursuant to an order from a governmental entity or in good faith. We will disclose the information to:
- Conform to legal requirements or comply with legal process;
- Protect Our rights or property or Our affiliated companies;
- Prevent a crime or protect national security; or
Protect the personal safety of Users or the public.
The Company shall always make best efforts to apply and maintain industry standards for the protection of similar information as the Personal Information.
We endeavour to maintain physical, technical and procedural safeguards that are appropriate to protect Your Personal Information including SPDI against loss, misuse, copying, damage or modification and unauthorized access or disclosure.
[Our security management standards are in compliance with ISO 27001. ISO 27001(Information Technology – Security Techniques – Information Security Management System - Requirements) is a widely recognized international security management standard that specifies security management best practices and comprehensive security controls following the ISO 27002 best practice guidance. Our compliance with ISO 27001 demonstrates our commitment to information security at every level.]
You are responsible for the security of Your account including the login credentials. If You suspect any unauthorized use of Your account, You must immediately notify Us by sending an email to firstname.lastname@example.org. You shall be liable to indemnify Us due to any loss suffered by Us due to such unauthorized use of Your account.
Further, We shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond Our reasonable control including but not limited to acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User, etc.
Retention of Information
We will also put in place measures such that Your SPDI, which is in Our possession or under Our control, is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the Purpose for which that SPDI collected is no longer being served by the retention of such SPDI; (ii) We no longer require the retention of Your SPDI for enforcing Our rights or discharging Our obligations; and (iii) retention is no longer necessary for any other reason such as compliance with applicable law.
You shall have the right to review your Personal Information submitted by You on the Platforms and to modify or delete any Personal Information, provided by You directly on the Platform and not through third party applications. You hereby understand that any such modification or deletion may affect Your ability to use the Platforms. Further, it may affect Our ability to provide Our Services to You.
We reserve the right to verify and authenticate Your identity and Your Account Information and/or Payment Information in order to ensure accurate delivery of Services. Access to or correction, updating or deletion of Your Personal Information may be denied or limited by Us if it would violate another person’s rights and/or is not otherwise permitted by applicable law.
If You wish to cancel Your account, or request that We no longer use Your Personal Information to provide You Services, contact Us at email@example.com.
If You wish to (a) opt out of Our Services; (b) opt out of receiving communications such as promotional and marketing-related information regarding the Services; or (c) withdraw consent regarding sharing Your Personal Information or SPDI, please email Our designated grievance officer at firstname.lastname@example.org.
Please note that Your withdrawal of consent or cancellation of account may result in Us not being able to provide You with Our Services, or terminate any existing relationship that We may have with You. Please also note that uninstalling the Platforms will not result in termination of Your use of the Platforms or Services.
Third Party Links
The Platforms may include hyperlinks to various external websites, and may also include advertisements, and hyperlinks to applications, content or resources (“Third Party Links”). We have no control over such Third Party Links present on the Platforms, which are provided by persons or companies other than Us. You acknowledge and agree that We are not responsible for any collection or disclosure of Your information by any external sites, applications, companies or persons thereof. The presence of any Third Party Links on our Platforms, cannot be construed as a recommendation, endorsement or solicitation for the same, or any other material on or available via such Third Party Links.
You further acknowledge and agree that We are not liable for any loss or damage which may be incurred by You as a result of the collection and/or disclosure of Your information via Third Party Links, as a result of any reliance placed by You on the completeness, accuracy or existence of any advertising, products services, or other materials on, or available via such Third Party Links. This will include all transactions, and information transmitted therein, between You and any such third party sites or applications or resources, such transactions are strictly bi-partite. We shall not be liable for any disputes arising from or in connection with such transactions between You and the aforementioned third parties.
Cookies and other tracking technologies
We utilize “cookies” and other tracking technologies. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Platforms. Some cookies and other technologies may serve to recall information previously indicated by a User. Most browsers/mobile settings allow You to control cookies, including whether or not to accept them and how to remove them. You may set most browsers/mobile application to notify You if You receive a cookie, or You may choose to block cookies with Your browser/mobile applications.
At all times, You may refuse all cookies on your mobile application by changing Your mobile settings to the extent permissible on Your device. However, by doing so, You may not be able to use certain features on the App or take full advantage of all the App offerings. You can remove cookies by following directions provided in Your mobile’s “help” file.
You agree and undertake to indemnify Us in any suit or dispute by any third party arising out of disclosure of information by You to third parties either through Our Platforms or otherwise and Your use and access of websites, applications and resources of third parties. We assume no liability for any actions of third parties with regard to Your information which You may have disclosed to such third parties.
Complaints and Grievance Officer
In accordance with the IT Act and rules made thereunder, the name and contact details of the Grievance Officer are provided below:
Name: Rajesh Menon