1. COLLECTION OF INFORMATION

1. INFORMATION YOU PROVIDE
1. During Your Use of Platform and/or Content, We may collect and process information including, without limitation, Personal Information from You, which is detailed as follows:

1. We may collect personal information from You while You Use the Platform and/or Content, including but not limited to, contact information such as name, email address, mailing/residential address with pin code, phone number, gender, cookies, internet protocol addresses, city, region, country of residence, Device IDs and user agents (collectively, Personal Information).

   Further, if You choose to disclose information about Yourself in Our online chat rooms or equivalent, comments section, or by creating a profile on Platform (if available), any information, including Personal Information that You disclose in these areas is public information, and maybe accessible to anyone who uses Platform and/or Content. We are not responsible for the actions of any third-parties with whom You share personally-identifiable information through Platform and/or Content.

2. We may also collect additional Personal Information about You when You use Platform and/or Content through Third-Party Platforms, in accordance with the privacy policy of such Third-Party Platforms. Such information received from the Third-Party Platforms at the time of accessing Platform and/or Content may include, and may not be limited to, the username, User ID, pictures, phone number, e-mail addresses associated with the Third-Party Platform, any information that has been made public in connection with that Third-Party Platform by You and/or any information or content such Third-Party Platform shares with Us. By using Platform and/or Content through a Third-Party Platform, You authorize Us to collect, store, use and retain such information collected from the Third-Party Platform, including Personal Information and content in accordance with this Policy.

   Note that since Platform and/or Content maybe Used through Third-Party Platforms, where some of these Third-Party Platforms may be social media platforms, it is Your responsibility to read and understand the terms and privacy policies of such Third-Party Platforms and decide whether You want to use such Third-Party Platforms, before Using the Platform and/or Content through such Third-Party Platforms.

   Further, if You use Your accounts on third-party products (including but not limited to Google, Facebook, LinkedIn and Truecaller) to sign-in to the Platform or sync your profile on such third-party products to Your account on Platform, We will collect information in accordance with the terms of these third-party products.

   Content and/or Platform, may contain advertisements, which could be targeted and interest-based. We may display advertisements to You based on Your Personal Information and/or based on Your engagement with Platform and/or Content and/or based on the policies of Third-Party Services. Towards this, certain third-party tools that We have integrated on Platform and/or Content, such as Advertising Partners (as defined below) (for instance, Google AdSense), Ad Server (for instance, Google Ad Manager), Web Analytics Tool (for instance, Google

   You may refuse to provide the aforementioned Personal Information to Us. However, such refusal may prevent You from receiving all or certain offerings in Platform and/or the Content.

3. If You use Your phone number to access Content and/or Platform, We may access Your contacts list on Your device, including any data, such as phone number, name and profile photo available in such contact lists, including, to determine if someone in Your contacts is using Platform and/or Content.

4. (iv) Personally Identifiable Information, if any, that you post during chats, posting comments on Our forums, sending feedback, entering contests, etc. will also be collected by Us.

   *We do not make any warranty whatsoever, whether express or implied, relating To fitness or accuracy, reliability, completeness, timeliness, performance, Safety, merchantability, quality, suitability, fitness for a particular Purpose, or authenticity towards your personal information that we collect, Access, use, store, disclose and / or otherwise process, at any particular Time or location.

   *You should not use platform and / or content, by means of any mechanism or Technology which conceals your actual geo-location or provides incorrect Details of your location (for example, by using a virtual private network). We will not be responsible or liable for any collection, storage, or Processing of your personal information or any other data if you use any Mechanism or technology which conceals your actual geo-location.

2. We also collect and track the following information based on Your engagement on Content and / or Platform. Please note that the below mentioned is an indicative list of information pertaining to Your engagement with the Content and / or Platform that we may collect, use, access, track, disclose, store, and / or otherwise process:
   1. From Your activity: IP address (static or dynamic), browser type, browser language, pages viewed on Platform and the order of those pages, the amount of time spent on particular pages and Content, the date and time of Use, etc.
   2. From Your device: Type of device, define manufacturer, advertising identifier, device identifiers (such as IMEI), operating system and version, carrier, language settings, geo-location, network type (2G, 3G, 4G, Wi-Fi), screen resolution, etc.
   3. From Third-Party Services: Reports on activity, engagement metrics on Platform and Content, usage trends, demographic data, etc.
3. When You Use Content and / or Platform, We may place cookies in Your web browser. We use cookies for numerous purposes, including but not limited to: enabling certain functions of Platform and / or Content, capturing Users analytics, storing Users preferences, and enabling advertisement delivery (including behavioral advertising).
   
   Cookies are small blocks of data created by a web server when an internet user is browsing a website and are placed on such users computer or any other device by such users web browser. A cookie file is stored in an internet users web browser and allows the service or a third-party to recognize such user and make such users next visit easier and the related service more useful.
   
   We use the following cookies on Platform and/or on Content, for the purposes explained below:

It is usually possible to stop Your browser from accepting cookies from a website. Please note, however, that if You delete cookies or refuse to accept them, You might not be able to Use all the features the Platform and / or the Content offer. You may not be able to store Your preferences, and some of Our pages might not display properly

All modern browsers allow You to change Your cookie preferences through their settings. These settings will typically be found in the options or preferences menu. In order to understand these settings, the following links may be helpful:

• Google Chrome:https://support.google.com/chrome/answer/95647
• Safari:https://support.apple.com/en-gb/guide/safari/sfri11471/mac
• Firefox:https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
• Internet Explorer:https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

To find information relating to other browsers, please visit the browser developers website.

If You are primarily concerned about cookies being generated by Advertising Partners, You may be able to turn these off by going to the Your Online Choices site or any other application that provides a similar service. However, in the event a third-party, including a Third-Party Service, uses statistical identification or other non-cookie technologies (such as eTags and web or browser cache) on Platform or Content, then browser settings that block cookies may have no effect on such technologies.

2. REASONS FOR COLLECTING INFORMATION

We use Your Personal Information and other information to maintain the general and personalized content and functionality of Platform and / or Content. In addition, We use personal details to make it possible to accommodate Your requests. We will use and retain Your information for such periods as necessary to comply with Our legal obligations, resolve disputes, and enforce Our agreements, including the Agreement.

More specifically, it may be used for one or more of the indicative reasons provided below:

1. To improve Content and Platform, and to help You efficiently access Platform and / or Content;
2. To personalize Your experience and make bespoke recommendations;
3. To help You efficiently access Your information and the progress each time You use Platform and / or Content;
4. For running advertising and promotions;
5. To resolve Your disputes with Us and to resolve Your grievances;
6. To carry out Our obligations and to process transactions arising from any contracts entered into between You and Us;
7. Conduct research and analysis to detect, prevent, mitigate, and investigate fraudulent or illegal activities;
8. Monitor aggregate metrics such as total number of viewers, visitors, traffic, and demographic patterns and to analyse how the Content and / or Platform is used, diagnose service or technical problems, maintain security, etc.;
9. To notify You about changes on Platform and / or Content and any breach of the security of Your information and take appropriate action to the best of Our ability to remedy such a breach;
10. To enable Us to comply with legal and regulatory obligations;
11. To administer a contest, promotion, survey, etc. or to maintain record of Our dealings with You;
12. To help You to connect with Your friends from social media network or devices contacts;
13. To send periodic emails for sharing information and updates pertaining to the Content or Platform, occasional news about Us, updates, related product or service information, etc.;
14. To enforce or protect Our rights, or any or any of Our affiliates, associates, employees, directors, or officers, or when We have reason to believe that disclosing Personal Information of Users is necessary to identify, contact, or bring legal action against someone who may be causing interference with Our rights, Platform, and / or Content, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

3. SHARING YOUR INFORMATION

1. WITH EMPLOYEES, CONTRACTORS, AND AFFILIATED ORGANIZATIONS: Strictly on a need-to-know basis in order to process it on Platforms behalf or to facilitate smooth functioning of Our business, such as providing Platform, Content, IT support, and customer service. Platform shall share such information, including Personal Information, within its group companies and officers and employees of such group companies for the purpose of processing Personal Information on its behalf. We also ensure that these recipients of such information, including Personal Information, agree to process such information based on Our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
2. WITH THIRD-PARTIES: We may share Your information, including Personal Information, with Third-Party Services, Third-Party Platforms, and other third-parties for purposes including but not limited to the conduct of Our business, to provide Platform and Content to You, mitigating fraud and risk, Our compliance with applicable laws, etc.

   We may store information in locations outside the direct control of Platform (for instance, on servers or databases located with Cloud Service Providers).

   These third-parties may provide You with additional services or information about the products and services they offer. Their handling of Your information, including Personal Information, shall be as per their respective privacy policies and Platform shall not be responsible for the same.

   We will not be responsible for any breach of security or for any actions of any third-parties including, without limitation, Third-Party Platforms and Third-Party Services, that receive Your Personal Information. We shall not be liable for any loss or injury caused to You as a result of, You and / or Us providing Your Personal Information to third-parties even if links to such third-party websites are provided on Platform and / or the Content.

   We assume no liability for any disclosure of information due to errors in transmission, unauthorized third-party access or other acts of third-parties, including, without limitation, those of Third-Party Platforms and Third-Party Services, or acts or omissions beyond Our reasonable control and You agree that You will not hold Us responsible for any breach of security whatsoever.

3. WITH PARENT COMPANY, AFFILIATE, SUBSIDIARY, INVESTOR, OR ACQUIRER:In the event of corporate sale, merger, reorganization, sale of assets, dissolution, or bankruptcy, Your information, including Personal Information, may be part of the transferred assets.

   In the unlikely event that We go out of business or enter bankruptcy, Personal Information would be one of the assets that is transferred or acquired by a third-party.

   You acknowledge that such transfers as contemplated above may occur, and that any acquirer of Platform may continue to use Your personal information as set forth in this Policy.

4. WITH REGULATORY AUTHORITIES: When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including but not limited to cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing this Policy or for complying with the applicable laws and regulations.

4. PROTECTING YOUR INFORMATION

Your information is important to Us. We use reasonable safeguards as per industry standards to preserve the integrity and security of Your information against loss, theft, unauthorised access, disclosure, reproduction, use, or amendment. To achieve the same, We use reasonable security practices and procedures for the protection of Your information. However, no commercial method of information transfer over the internet or electronic data storage is known to be 100% secure. As a result, We cannot guarantee the absolute security of that information, including Personal Information during its transmission or its storage in Our systems. Be advised that if You send messages or post material containing Personal Information, that information may be collected and used by others.

We store and process Your Personal Information on cloud servers provided by Amazon Web Services (AWS) and Microsoft Azure (Azure), and We may partner with other cloud service providers in future. AWS, Azure, and other cloud service providers that We may partner with in future are collectively referred to as “Cloud Service Providers”. Currently, all Your information, including Your Personal Information are stored by AWS in servers located in Mumbai, India and Azure servers in Pune, India. However, in future, all Your information, including Your Personal Information, may be maintained by Cloud Service Providers on servers or databases located outside India or to a jurisdiction where the privacy laws may not be the same as those in Your location, region, or country. By using Our offerings through Platform and / or Content, You consent to the transfer of such information to the Cloud Service Providers and to maintenance and storage of Your Personal Information in jurisdictions other than Your jurisdiction. All information, including Personal Information You provide to Us may be stored in locations outside India.

Notwithstanding anything contained in this Policy or elsewhere, the Company shall not be held responsible for any loss, damage, or misuse of Your Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event (as defined below). For the purposes of this Policy, a Force Majeure Event shall mean any event that is beyond Our reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, pandemics, computer hacking, unauthorised access to computer, computer system or computer network, computer crashes, breach of security and encryption (provided beyond Our reasonable control), power or electricity failure, or unavailability of adequate power or electricity.

You agree and acknowledge that We may retain a copy of all information provided by You as per Our security, recovery, and back-up policies effective at such points in time, even if You stop using Platform and / or Content.

5. GENERA

1. YOUR RIGHT TO REQUEST

   You have a right, subject to the statutory provisions, to have Your Personal Information corrected, updated, amended, blocked, and deleted. We may, however, decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required as reasonably and solely determined by Us at such point in time. You may send an email to Our Grievance Officer and Data Protection Officer (details provided below), with a request to update, correct, block, delete, and amend any Personal Information.

2. UNSUBSCRIBING FROM EMAIL COMMUNICATIONS

   If You are receiving Our emails and no longer wish to receive them, You may opt out at the time You receive the message by following the unsubscription instructions in that email. Please allow Us reasonable time for Your request to be processed. However, You may not opt out of service-related communications (e.g., account verification, changes / updates to features of the Platform or Content, technical and security notices, etc.).

3. LIMITING SCOPE OF SHARING INFORMATION

   In event of disagreement with terms of this Policy, You may either not Use the Platform or Content, or You may limit Your level of interaction with the Platform or Content, which could include not providing Us with Personal Information.

4. DELETION OF YOUR PERSONAL INFORMATION

   If You had previously agreed to this Policy, but no longer agree with this Policy or seek to withdraw Your consent with respect to Your data, please write to the Grievance Officer and Data Protection Officer. Upon withdrawal of Your consent, We will take actions and attempt to delete all Your Personal Information available with Us. We, however, will retain information, including Personal Information about You that is on Our system following Your termination and / or deletion request as per Our security, recovery, and back-up policies effective at such points in time. You understand and acknowledge that, even after removal, copies of personal data or content may remain viewable in cached and archived pages, or if other Users have copied or stored Your personal data or content.

5. GOVERNING LAW

   This Agreement and the relationship between Platform and You hereto shall be governed by, and interpreted in accordance with, the laws of India without having regard to the conflict of law provisions thereunder. The courts of New Delhi, India, shall have exclusive jurisdiction over all matters arising pursuant to this Policy. All rights and obligations available to You and Us under Our Terms of Use, including, without limitation, dispute resolution, indemnity, and limitation of liability shall be applicable and deemed extended to this Policy.

6. AGGREGATED STATISTICS

   Platform may collect statistics about the behavior of Users. When in the aggregate form and not pointing to a particular individual, We may display this information publicly or provide it to others.

7. PHISHING

   Phishing can occur if Users are induced by an individual / entity into divulging personal and / or sensitive personal data by using fraudulent media, including without limitation, websites, phone numbers, and / or e-mail addresses. In the event You provide information to a website or respond to an e-mail which does not belong to Us or is not connected with Us in any manner, You may become a victim to Phishing. We do not send e-mails requesting Users to provide payment information, username, or passwords. However, We may verify the payment information (if applicable), username, password etc. provided by You from time to time.

   If You receive a suspicious email on Our behalf, We suggest You do not: (i) reply to it, (ii) open any attachments, (iii) click on links contained in the e-mail, (iv) or provide any information in response to it. You can report suspected fraud involving Us by sending an e-mail to the Grievance Officer and Data Protection Officer respectively. Please include the word phishing in the subject line of Your e-mail and provide as much information as possible about the suspected fraudulent activity or message.

8. If You have any questions, feedback, or concerns in relation to this Policy or Your information with Us, including if You identify any discrepancies and have any grievances with respect to collection or processing of personal data, please contact:

6. GDPR Policy

Many types of data we process qualify for multiple legal bases for processing under the General Data Protection Regulation (GDPR). Below is the primary legal basis for each type of data that we process:

1. We have a legitimate interest in conducting analytics, measurement of usage and conversions, and game telemetric to improve our services. We and our processors have multiple measures in place to minimize the privacy impact.
2. We have a legitimate interest in storing users’ purchase history for the purpose of providing users help in fixing purchase and payment issues.
3. We have a legitimate interest in enabling third party ads and data collection on our sites and apps to help provide a more customized ad experience for our users and site visitors. Our reputable partners provide opt outs and numerous other privacy measures to minimize the privacy impact of online ads.
4. We have a legitimate interest in periodic email and direct marketing, to inform registered users of updates and offers. We make clear disclosures when users sign up and offer opt outs for anyone not interested.

It is contractually necessary to process your username, email, password, cookie data, IP address, game network IDs, game information and similar information to fulfil our obligations in the terms of service to provide you with high quality games and a social game network from ourselves and our partners.

Name: Abhay Techno Services Private Limited.
Address: 1214, Tower-A, SPAZE ITECH PARK, Block S, Sector 49, Gurugram, Haryana 122018.