Privacy Policy - Gamesys11

We Gamesys Fantasy Private Limited (“Gamesys11”) recognise that your privacy is very important to us and we take it seriously. This Privacy Policy (“Privacy Policy”) sets out how we collect, process, use, share and protect information when you use Gamesys11 (“Mobile Application”). This privacy policy together with the Terms and Conditions governs your use of the Mobile Application and describes our policies and procedures on the collection, use, disclosure, processing, transfer, and storage of the information provided to us by you. By using, browsing, or accessing the Mobile Application you agree to be bound by the terms of this Privacy Policy and consent to the collection, storage, possession, dealing, handling, sharing, disclosure or transfer of your information in accordance with the terms of the Privacy Policy. We shall not use the User’s information in any manner except as provided under this Privacy Policy. Capitalised terms used herein if not defined shall have the same meaning as ascribed to them under the Terms. References to “we”, “our” or “us” or the “Company” shall mean the mobile application and/or Gamesys11. Any references to “you”, “your” or “user” shall mean any person using our mobile application. We will not use or share your information with anyone except as described in this Privacy Policy.

You are advised to carefully read the Privacy Notice before using the mobile application. If you do not agree with any provisions of the Terms or this Privacy Policy, we advise you to not use or access the mobile application. By clicking on ‘Continue’ during the sign-up process, by using the mobile application, or by using the Services, You confirm that You have read, understood, and agree with the privacy practices described in this Privacy Policy, and the Terms and Conditions (the “User Terms”) and the collection, storage and processing of Your information in accordance with them.

Please note that our mobile application and other digital platforms may contain links to third party websites / digital platforms which are provided for your convenience. We are only responsible for the privacy practices and security of our mobile application. We recommend that you check the privacy and security policies and procedures of every other website / digital platform that you visit.

1. INFORMATION WE COLLECT

We are committed to ensuring the protection of your personal data and collecting only the necessary information to provide you with the best possible experience on our platform. Below is a detailed breakdown of the types of information we collect when you use our online fantasy sports gaming services:

a) Personal Information

This includes data that identifies you as an individual or relates to an identifiable person. We collect this information when you create an account or interact with our platform, including but not limited to:

• Full Name: For identity verification and personalization of your account.
• City, State and Pin Code: For legal and regulatory compliance purposes we also collect the details about user city, state and pincode.
• Date of Birth: To verify your eligibility (age) to participate in fantasy sports gaming, as required by law.
• Contact Information: Such as your email address and phone number, for account creation, communication, and notifications.
• Profile Picture: If voluntarily uploaded, used for personalization within your account.

b) Financial Information

To process payments and withdrawals, we collect financial information when you engage in monetary transactions on our platform:

• Bank Account Details: Used for processing withdrawals and deposits.
• UPI ID: For facilitating fast and secure payments.
• Credit/Debit Card Information: For processing payments for participation in paid leagues, contests, and subscriptions.
• Transaction History: Records of all financial transactions conducted on the platform, including deposits, withdrawals, and winnings.

C) Device and Log Information

When you access our platform via a mobile device or computer, we automatically collect certain information to enhance your gaming experience:

• IP Address: Collected to identify your location and ensure compliance with local laws (e.g., geolocation-based access restrictions) and to prevent fraud.
• Device Information: type of device to provide enhanced user experience.
• Login Activity: Dates and times of logins and actions taken within the platform, which helps us detect unauthorized access and maintain platform security.

d) Usage Information

We collect data about how you interact with our platform to improve your experience and optimize services. This includes:

• Game Participation Data: Data on leagues, matches, and contests you participate in, including the teams you select, the outcomes, and performance scores.
• Browsing and Click Data: Pages you visit, the amount of time spent on each page, and the features you use on the platform.
• Search Queries: Information on what you search for within the platform to improve search results and recommendations.
• Referral Source: Data on how you discovered our platform, including referral links or marketing campaigns.

e) Location Information

We may collect and process information regarding your precise geographic location based on your device’s GPS or IP address. This helps us:

• Ensure that our services are being accessed from permissible jurisdictions, as per the applicable laws and regulations governing fantasy sports.
• Provide location-based services, such as region-specific contests or promotions.

f) Communications Data

When you communicate with us via email, in-app messaging, or other channels, we collect the content of your communication along with metadata such as:

• Email and Chat Correspondence: Any inquiries, support requests, or feedback you provide.
• Push Notifications: Data on when you receive and engage with push notifications and promotional messages sent by us.

g) Social Media Information & Login Credentials

If you choose to link your social media accounts (e.g., Facebook, Google) with our platform for login purposes, we may collect your email address details to map the user with a particular email. To ensure login through any of the social media, the user is required to login to that specific social media on the device and after due verification and validation the user shall be allowed using the social media login credentials.

h) Sensitive Personal Data

As per the Digital Personal Data Protection Act, of 2023, we may collect Sensitive Personal Data such as Aadhar Card or PAN Card Details: If required for regulatory compliance, taxation, or to confirm your identity for high-value withdrawals.

2. USE OF PERSONAL INFORMATION

We collect and process your personal data for specific purposes with the primary goal is to providing you with a seamless and enjoyable experience on our platform, ensuring compliance with legal requirements, and protecting both you and our platform. Below is a detailed explanation of why we collect your data:

a) Account Creation and Management

• To enable you to register, create, and manage your account on our platform.
• To authenticate your identity during the sign-up and login processes.
• To facilitate account recovery in case you forget your login credentials.
• To ensure compliance with age restrictions and prevent unauthorized access to the platform.

b) Facilitating Participation in Games and Competitions

• To allow you to join and participate in fantasy sports leagues, contests, and other competitions available on the platform.
• To manage and display real-time game results, performance statistics, and leader boards.
• To track your selections, scores, and other gaming-related data for accurate gameplay results.
• To customize your gaming experience, offering personalized game recommendations and tailored contests.

c) Processing Payments and Transactions

• To process financial transactions such as deposits, withdrawals, and payments for entry into paid contests.
• To verify and validate payment methods and facilitate secure monetary transactions.
• To comply with legal obligations related to financial transactions, including taxation, auditing, and financial reporting.

d) Communication and Customer Support

• To communicate with you regarding important account-related matters, such as password resets, transaction confirmations, and security alerts.
• To respond to your inquiries, complaints, or feedback through customer support channels, ensuring you receive timely assistance.
• To send notifications related to new features, promotional offers, and upcoming events via email, SMS, push notifications, or other communication channels.

e) Improving and Enhancing the Platform

• To analyse user interactions and preferences to improve the overall functionality and performance of the platform.
• To monitor and assess user activity patterns, allowing us to optimize user interfaces and enhance gaming features.
• To conduct research and development for the introduction of new features, games, or services based on user feedback and behavioural analytics.

f) Fraud Detection and Prevention

• To protect the integrity of our platform by monitoring and analysing activity patterns for fraudulent, suspicious, or malicious behaviour.
• To detect and prevent account takeovers, payment fraud, collusion, or any other prohibited activities that may harm the platform or its users.
• To ensure compliance with the rules of fair play and enforce necessary measures when fraudulent or suspicious behaviour is identified.

g) Compliance with Legal and Regulatory Obligations

• To comply with legal obligations, including anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and other applicable financial or gaming laws.
• To retain and provide data to regulatory authorities, law enforcement, or governmental bodies when required by law, court orders, or other legal processes.
• To ensure compliance with the platform’s terms of service, policies, and applicable gaming regulations to maintain a safe and legal environment for all users.

h) Marketing and Promotions

• To send you marketing communications regarding new offers, games, contests, and platform updates, provided you have opted in to receive such communications.
• To inform you about exclusive contests, bonus features, or promotional campaigns relevant to your gaming interests and preferences.
• To carry out surveys, polls, and feedback collection initiatives to improve the quality of our services and understand user satisfaction levels.

i) Research, Analytics, and Reporting

• To gather and analyse aggregated data for internal reporting purposes, helping us assess platform performance and user engagement.
• To carry out statistical analysis on user behaviour, preferences, and trends to refine our gaming offerings and improve user satisfaction.
• To generate insights into market trends, user demographics, and contest preferences, which help us stay competitive and enhance our offerings.

j) Ensuring Platform Security

• To maintain the security of our platform by using personal and device data to identify potential security risks and vulnerabilities.
• To implement access controls, firewalls, and security measures that prevent unauthorized access, data breaches, and cyber-attacks.
• To detect and mitigate any violations of the platform’s security policies, including the use of unauthorized tools or cheating mechanisms.

k) Legal Disputes and Enforcement

• To investigate, manage, and resolve any legal disputes or issues that arise in connection with your use of the platform.
• To enforce our terms of service and policies, including managing disputes related to contest outcomes or financial discrepancies.
• To defend and protect the rights, property, and safety of our platform, employees, users, and third-party partners.

l) Improving User Safety

• To collect and process data that helps us enhance the safety and integrity of the gaming environment, including monitoring interactions for harmful or abusive behaviour.
• To provide tools for reporting and addressing abusive or inappropriate conduct by other users, ensuring a safe community for all participants.

3. DATA SECURITY

We are committed to ensuring the security and protection of your personal data. We implement a variety of industry-standard security measures and protocols to safeguard your personal information from unauthorized access, misuse, alteration, disclosure, or destruction. Below is a detailed overview of the steps we take to ensure the security of your data:

a) Encryption

• • All sensitive personal information, such as financial data, is protected using encryption protocols (e.g., SSL/TLS) both in transit and at rest. This ensures that any data you provide, including payment information, is securely transmitted and stored.
  • Personal data stored in our servers, databases, and backups are encrypted to prevent unauthorized access, even in the event of a data breach.

b) Secure Access Controls

• We implement role-based access control (RBAC), which ensures that only authorized personnel with the necessary permissions can access specific types of personal data.
• All employees, contractors, and third-party service providers who require access to your data are subject to strict confidentiality agreements and are granted access only to the data necessary for their role.
• Multi-factor authentication (MFA) is used for administrative access to sensitive parts of our platform, further securing access points.

c) Data Anonymization and Minimization

• We adopt data minimization practices, ensuring that we only collect and retain personal data that is necessary for the purposes outlined in this Privacy Policy.
• Where possible, we anonymize or pseudonymize personal data to reduce the risk of identification in case of a data breach.
• For analytical purposes, personal data is aggregated and anonymized to prevent individual identification.

d) Regular Security Audits and Vulnerability Assessments

• We conduct regular security audits and vulnerability assessments to identify potential security risks and address them proactively. These audits help us ensure that our security measures remain up-to-date and effective against evolving threats.
• Independent third-party audits may also be conducted periodically to verify the security and integrity of our data protection systems.
• Penetration testing is carried out regularly to identify and address potential vulnerabilities in our systems and applications.
• We use default encryption techniques as per framework such as SHA, AES, MD5 and security salt etc. for sensitive data such as passwords.

e) Firewalls and Intrusion Detection Systems

• We utilize firewalls, intrusion detection, and prevention systems (IDS/IPS) to monitor and filter incoming and outgoing traffic on our servers. This helps us detect and prevent unauthorized access to our platform.
• Our firewall policies are continuously updated to block suspicious activities, such as brute-force attacks, data scraping, and other forms of cyberattacks.

f) Data Integrity and Monitoring

• To ensure the integrity and accuracy of personal data, we implement data validation measures to prevent unauthorized changes, corruption, or loss of information.
• Automated monitoring tools continuously track user activities on our platform to identify unusual behaviour, unauthorized access, or potential security threats.
• Any suspicious activity is logged, flagged, and investigated by our security team to mitigate any potential threats in real-time.

g) Secure Payment and Financial Transactions

• All financial transactions on our platform are processed using third-party payment gateway services having necessary PCI DSS (Payment Card Industry Data Security Standard) compliant systems to protect your credit/debit card, UPI, and banking information.
• Payment data is never stored on our platform and it is processed through secure third-party payment gateways that employ their rigorous security measures.

h) Data Backup and Recovery

• Regular backups of personal and platform data are performed to ensure that in the event of accidental data loss or a cyber incident, your information remains recoverable.
• All backups are securely encrypted and stored in geographically dispersed data centres to mitigate the risks associated with physical disasters or localized breaches.

i) User Responsibilities

• • While we take every possible step to secure your personal data, you also play a key role in maintaining your account’s security:
    • Always use a strong password and avoid sharing your login credentials with others.
    • Be cautious of phishing attempts or suspicious communications requesting your account or personal information.
    • Enable two-factor authentication (2FA) when available for added security.

4. USER CONSENT

By accessing and using our platform, you explicitly consent to the collection, use, and processing of your personal data by this Privacy Policy. You acknowledge that you have read, understood, and agreed to the terms outlined here, including the specific purposes for which your data will be used, such as account creation, service delivery, and personalized marketing.

You have the right to withdraw your consent at any time by contacting us via the details provided in this Privacy Policy. Please note that withdrawing consent may affect your ability to access certain features or services on the platform. Additionally, we will inform you of any significant changes to this policy, and continued use of our platform after such changes constitutes your acceptance of the revised terms.

5. DISCLOSURE OF INFORMATION TO THIRD PARTY

We do not sell, share, rent or trade the information we have collected about you, other than as disclosed within this Privacy Policy or at the time you provide your information. Following are the situations when information may be shared:

a) ADMINISTRATIVE AND LEGAL REASONS

We cooperate with Government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your information (including Protected Information, IP address, Device Information or geo-location data), to Government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, subpoenas, Governmental requests or legal process; (ii) to protect and/or defend the Terms and Conditions for online and mobile Services or other policies applicable to any online and mobile Services, including investigation of potential violations thereof; (iii) to protect our safety, rights, property or security, our Services or any third party; (iv) to protect the safety of the public for any reason; (v) to detect, prevent or otherwise address fraud, security or technical issues; and /or (vi) to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity.

b) BUSINESS TRANSFER

We may share your information, including your Protected Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.

c) WHEN YOU AGREE TO SHARE INFORMATION WITH THIRD PARTY

We may share your personal information/data with third parties after obtaining express consent from you for sharing that information. In such circumstances, the user shall be solely responsible for information that the user consents us to share with the third party and further, we shall not way be responsible if any misuse of personal information/ data takes place from the end of that third party.

6. DATA RETENTION

We retain your data only for as long as necessary to fulfil the purposes for which it was collected, as outlined in this Privacy Policy, or as required by law. This includes retaining your data for legal, regulatory, accounting, or reporting purposes, as well as for resolving disputes and enforcing our agreements.

Once your data is no longer needed for these purposes, we will securely delete or anonymize it. In some cases, we may retain anonymized data for research, statistical, or analytical purposes. You may request the deletion of your data at any time, subject to applicable legal requirements. When personal data is no longer needed, it is securely deleted, anonymized, or destroyed to prevent unauthorized recovery or misuse.

7. DELETION OF DATA

Users may raise a request for deletion of any or all personal data or information stored with Gamesys11 by writing an email to grievance@gamesys11.com. Once your deletion request has been received and confirmed, Gamesys11 will delete your personal data or information from our records.

However, Gamesys11 reserves the right to discontinue the services for which the information was originally collected.

Please note that we may have to also retain such personal data or information if any required by prevailing laws in force or if applicable laws require us to maintain archives or retention of data including such personal data or information.

8. LINKS TO THIRD PARTY WEBSITE

In the facilitation and provision of services to the user, our website may contain certain links to third-party websites or applications. In the event the user uses the third-party links to any websites or applications, the user shall be governed by the Terms and Conditions and Privacy policy of that third-party website or application. This Privacy policy is only applicable to us and to the website and services provided through us. User is requested to read the Terms and Conditions and Privacy policy of third-party websites and applications while visiting those websites and applications.

9. LIMITATION OF LIABILITY

To the fullest extent permitted by applicable law, we shall not be liable for any indirect, incidental, consequential, special, or punitive damages, or any loss of profits, data, or business opportunities arising out of or in connection with your use of our platform or the handling of your personal data. This includes, but is not limited to, damages resulting from unauthorized access to or alteration of your personal data, errors or omissions in our data processing, or any disruption or unavailability of our services. We do not warrant the security of our systems or the accuracy, completeness, or reliability of any information provided through the platform. Our total liability for any claims related to this Privacy Policy or your use of our platform shall be limited to the maximum amount permissible under applicable law.

10. MODIFICATION

We reserve the right to update/ change this privacy policy without giving any prior notice. Any changes to this privacy policy shall be effective immediately upon posting of the revised privacy policy on the mobile application. Users are encouraged to periodically review this page for changes to this privacy policy. Your continued use of our application shall indicate your acceptance and acknowledgement of the changes and therefore user shall be bound by the updated policy.

11. GOVERNING LAW

This privacy policy is applicable for the users using the mobile application in the territory of India. If the user using the mobile application within a jurisdiction other than India, the user shall be governed by the local privacy laws, rules and regulations prevailing in the country of user location.  Any or all compliances related to privacy laws, rules and regulations shall be the sole responsibility of the user and the company or any of its representatives, administrators, or permitted assignees shall not be in any way held responsible in the event of any breach of the same. The terms of this Privacy Policy shall be governed and construed by the laws of India. Any dispute regarding or arising out of this Privacy Policy shall be subject to the exclusive jurisdiction of the courts in Ahmedabad, Gujarat.

12. GRIEVANCE REDRESSAL

We value your association with us and using our mobile application. To resolve your grievances or concerns in time effective and efficient manner, Gamesys hereby appoints Mr. Anand Umraniya as our Grievance officer for complaints of rules drafted under the Information Technology Act, 2000, who may be contacted through e-mail at grievance@gamesys11.com and through mail Gamesys Fantasy Private Limited, C-101A, Ganesh Meridian, Opp. Gujarat High Court, SG Highway, Sola, Ahmedabad Gujarat-380060. Users are requested to address any of their questions/grievances/ complaints/feedback/ concerns in respect of this privacy policy or usage of their personal information data to the Grievance officer appointed under this policy.

13. SEVERABILITY

Whenever possible, each section of this Privacy Policy shall be interpreted in a manner to be valid under applicable law. However, in the event that any provision is held to be prohibited or invalid, such provision shall be ineffective only to the extent of such prohibition or invalidity, without invalidating the remainder of such provision or other remaining provisions of this Privacy Policy.