We, at Guru game Digital Pvt Ltd (hereinafter referred to as the Company for the sake of brevity), and its affiliates value the privacy and security of information (“information” or “user information”) about its clients and potential users (“users” or “clients”). The Company may collect and retain certain information in order to provide and/or suggest a variety of Products and Services to our users. In this privacy policy (hereinafter referred to as "Policy" for the sake of brevity), we describe how the Company collects, uses, and discloses information collected by it and its affiliates, including on websites and/or mobile Apps (“sites”) operated by the Company.

Please read this Policy carefully. By providing information to the Company and its affiliates or visiting or using our Sites, you acknowledge the practices described in this Policy. Your use of our Products and Services, including our Sites, and any dispute over privacy, is subject to this Policy.

The information that we collect is controlled by our company, which is headquartered at 253-254 2nd FLOOR TOWER B-2 SPAZE IT PARK SOHNA ROAD GURUGRAM HARYANA 122018 INDIA.

Information collection

The Company collects and processes both Personal Data and Other Data associated to the user. For purposes of this Policy, "Personal Data" is any information that alone or together with other information in the possession of the Company relates to an identified or identifiable natural, juisctic person (a body recognized by the law as being entitled to rights and duties in the same way as a natural or human person), such as including user data as mentioned in preceding paragraphs but not limited to name, phone number, GPS location, gender, date of birth, occupations, likes/dislikes, email address, financial account information, and online identifiers and account information such as user name and password.

"Other Data" is any additional information that is not Personal Data. In this section, we describe our information-collection practices, including the types of Personal and Other Data that we collect. In subsequent sections of this Policy, we describe how we use and disclose Personal and Other Data.  

We may combine the Personal and Other Data we collect directly from you with information collected from or about you in other contexts, such as on the Sites. This may include information collected online, such as through our email exchanges with you; from documents in public domain, such as information that we collect when you establish your account with us. We will treat such combined information in accordance with this Policy. If you do not wish to provide information to the Company, we may not be able to provide certain Products or Services to you.

a) What Personal Data do we collect?

The Company may collect the following Personal Data from or about you:

Personal Data we collect directly from you, such as when you request information from us, invest with us, or register to use the Sites:  The Company collects and maintains Personal Data about you, and about any person or entity on whose behalf you are acting, that you provide to us, such as when you obtain a product or service from the Company, request information or materials from us, register to use the Sites, or otherwise interact with us or our Sites.

Personal Data for your account: Depending on the type of account, and to the extent permitted by law, we may collect the following Personal Data from you when you open an account, :

  • Full name, date of birth, gender, and contact details, including mailing address, email address, and telephone and fax numbers if any;
  • Permanent Account Number [PAN] and bank account and payment method details, if such information is needed for the purpose of administering your accounts;
  • Other information that you provide to us in connection with your account.

Device Information includes:

As foregoing mentioned, in order to provide you better service, it is also necessary for us to collect data that help us update, optimize, personalize and improve our services to you.

1. Device information Such as the type and model, operation system of your mobile phone or personal computer, hardware versions, carrier name, IP address, mobile browser (e.g. Chrome, or any other browser), applications using the services and the version of such applications battery level, signal strength, available storage space, browser type, app and file names, and other resembling types. Other device data such as the name of your mobile operator or ISP, language, time zone, mobile phone number, and connection speed.

2. Geo-location of your device. Such as GPS or other geo-location data when location services have been enabled when you use company products and services . Also we can take info from your device whenever we need to give you better user experience.

3. Device identifiers. Device identifiers are those ascribed to it as IMEI, IDFA, Android Advertising DA, serial number of mobile phone, telecommunication operator, or data resembling etc.

Information about third parties: We may collect information from you regarding other individuals related to your account. Where you disclose information about authorized signatories, dependents, relatives, potential beneficiaries, employees, agents, or other representatives as mentioned above, you warrant that you will only do so in accordance with the applicable data protection laws such as Information Technology Act 2000 and Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 with all its latest amendments; that you will ensure that before doing so, the individuals in question are provided with a copy of this Policy and made aware of the fact that the Company will hold information relating to them and may use it for any of the purposes set out in this Policy. The Company may, where required under applicable law, notify those individuals that they have been provided with their Personal Data and provide a copy of this Policy to them.also we are not liable to save your data more than 30 Days and we can delete all of your data in 30 days, If you have any dispute or query you should report in 15 days maximum after the event occurs.

Information from telephone, email, online chat, or text message communications with the Company:- 

If you communicate with the Company or its affiliates by telephone, email, or text message, the Company may keep a record of that communication. In accordance with applicable law, the Company also may record and monitor telephone calls for training, quality assurance, security, and customer service purposes.

b) What Other Data do we collect automatically?

The sites of the Company and its affiliates use a variety of technologies, such as cookies, web beacons, and/or similar mechanisms, as described further below, to collect Other Data that helps us to understand how our Sites are used. Specifically, when you visit the Sites, we or our third-party service providers may automatically collect a variety of technical and navigational information about you via these technologies, including as applicable:-

your computer or device type; operating system version; browser type and version; user agent string; internet connection type; mobile network provider; date and time of your visit; time since your last visit; web pages you view; links you click; searches conducted on the Sites; the internet protocol (IP) address used to access our Sites; your general geographic location (e.g. your city, postal code, or metropolitan region). We also may use similar tracking technologies in emails that we or third parties send to you, as further described below. When you visit our Sites, you have the ability to accept or decline these cookies and other tracking mechanisms, except those that are strictly necessary for you in order to enter and legitimately browse around the Sites and use essential Site features, and you can change your preference at any time.

  • Cookies: A cookie is a small file of letters and numbers that is stored on your computer, tablet, mobile phone, or other device when you visit a website. Cookies contain information that is transferred to or read on your device and allow websites to recognize devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our Sites. This helps us to provide you with a useful experience when you browse our Sites and also allows us to improve our Sites. We and our third-party service providers use cookies, which link your actions during a particular browser session and expire at the end of that session, as well as persistent cookies, which remain on your device and allow us to remember your actions or preferences across multiple browser sessions. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Sites may not operate correctly.

  • Web beacons: The Sites or the emails that you receive from the Company use an application known as a "web beacon" (also known as a "pixel tag" or "clear gif"). A web beacon is an electronic file that usually consists of a single-pixel image. We and our service providers may use web beacons and cookies to determine whether and when you receive and open our emails; these beacons and cookies may also capture information such as the type of device, operating system, email program, and web browser used to view the email, the IP address from which you opened the email, and whether you click on any links in the email.

We may combine Other Data with additional information that we have collected about you, including, where applicable, your name and other Personal Data. When we combine Other Data with Personal Data, we treat all of the combined information as Personal Data. If you have registered for secure access on our Sites, we are able to combine the information we collect about your usage of our Sites during a secure (logged-on) session with other information we know about you, such as any searches you conduct or information you request during your web session. We can also identify your computer or device on each visit to our Sites, even if you do not log on, and link information about that visit, as well as about the Company notifications that you may have viewed on other websites, to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our Sites and the effectiveness of our online advertising, as well as to identify the Products and Services of the Company that may be of interest to you.

Use, legal basis, and disclosure

How do we use Personal and Other Data?

We use the Personal and Other Data that we collect for the purposes described in this Policy, for the purposes for which it was provided to us, as required by law, and for our business purposes, including:

  • To establish and administer accounts and your relationship with us, to fulfil the terms of any agreement you have with us, and to otherwise provide the Company's Products and Services to you;
  • To communicate with you, notify you about important updates or changes to the Company's Products and Services, and address relevant inquiries or complaints;
  • To comply with our legal obligations and protect our legal rights, including, without limitation, to comply with record-keeping, reporting, and tax obligations under applicable law and anti-money laundering laws);
  • For marketing and promotional purposes, in accordance with applicable law. For example, as permitted by applicable law, we will use your Personal Data, such as your email address, to send you news and newsletters, or to otherwise contact you about the Company Products or information we think may be of interest to you. Although we hope you will find our promotional communications of interest, you may opt out of receiving them by following the "unsubscribe" instructions at the bottom of each communication;
  • To create new products and services or improve our existing products and services;
  • To count and recognize visitors to the Sites and various Site features and better understand how users access and use our Sites and the Company Products and Services;
  • To support Site performance, perform Site analytics, enhance Site navigation, and improve our web design and functionality; and
  • For other research and analytical purposes.

Legal bases for using Personal Data

We will only collect, use, and share your Personal Data where we are satisfied that we have an appropriate legal basis to do this. This may be because:

  • Our use of your Personal Data is necessary to perform a contract or take steps to enter into a contract with you (for example where we use your contact, demographic, and banking information required to establish and fund your account in the performance of our services);
  • Our use of your Personal Data is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to undertake vetting to comply with anti-money laundering legislation or where we are required to disclose Personal Data to a court or any law enforcement authority);
  • You have provided your consent to us using the Personal Data (for example in relation to our use of cookies on the Sites); and/or
  • Our use of your Personal Data is in our legitimate interest as a commercial organisation (for example in order to make improvements to our products and services and to provide you with information you request); in these cases we will process your Personal Data at all times in a way that is proportionate and respects your privacy rights, and you have a right to object to this processing as explained in the section below titled Your legal rights.

If you would like to find out more about the legal bases on which we process Personal Data, please contact us using the details below.

To whom do we disclose Personal and Other Data?

We may disclose Personal and Other Data to third parties for the following purposes, as permitted by law for the time being in force in India.  You have certain rights to object to the processing of your Personal Data as described below:

Affiliates: We disclose Personal and Other Data to the Company and its affiliates for the purposes described in this Policy.

Service providers: We may disclose Personal and Other Data to our service providers, who use it to perform tasks on the Company’s behalf. Among other things, these service providers help us provide the Company’s Products and Services, send disclosures and statements to you, administer your accounts, and manage and improve the Sites. Our service providers may collect, process, and retain information about you, in accordance with the laws of our country, directly on behalf of the Company. The Company's service providers include:

  • Any organization involved in providing, managing, or administering the Sites, related systems, such as administrators, email senders and providers, technology service providers, and third parties that provide analytics and advertising services; and
  • The Company's auditors, consultants, legal advisers, Income Tax Department and other professional advisers.

Customer agents: We may disclose Personal Data to your agents or representatives, including:

  • Your legal or other professional adviser(s);
  • Other financial institutions that hold an account in your name or on which you are authorized to act, for example, where amounts have been transferred to or from that account.

Legal purposes: We may use and disclose information about you as we believe reasonably necessary to protect the rights and property of the Company and its affiliates, including to establish legal claims or defenses, to obtain legal advice, to defend our legal rights, to protect our rights or property and those of the Company’s affiliates, to protect against fraud and abuse, to protect other users of our services and our Sites, and to protect the life, body, or property of others (individuals or entities). We also may disclose information about you in order to comply with the law, judicial proceeding, court order, or other legal process, such as in response to a court order or investigating agencies, law enforcement mechanism who could potentially investigate) alleged fraudulent or suspicious transactions in relation to your account or any other account on which you are authorized to act.

Sale or other transfer of the company: We reserve the right to disclose information to facilitate the licensing, assignment, acquisition, securitization, bankruptcy, or other transfer of our technology or business, or a portion thereof, to third parties, in accordance with applicable law in India.

Market research: We provide information to market research companies or the Company’s affiliates for the purpose of assessing information about our business or client base. We may provide our clients' or prospective clients' contact details to market research companies to undertake research on behalf of the Company, in accordance with applicable law. For example, we may run client satisfaction surveys or run focus groups on proposed products.

We use commercially reasonable physical, electronic, and procedural safeguards to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with applicable laws in India. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time. If you have online account access, we recommend that you take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your user name and password private.

The Company retains Personal Data for as long as necessary to provide our services to you, to fulfill the purposes described in this Policy and/or our business purposes, or as required by law, regulation, or internal policy. We are obliged to retain certain information to ensure accuracy, to help maintain quality of service, and for legal, regulatory, fraud prevention and legitimate business purposes.

Your legal rights

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your Personal Data:

1. Right to access Personal Data

You have a right to request that we provide you with a copy of your Personal Data that we hold, and you have the right to be informed of:

  • the source of your Personal Data;
  • the purposes, legal basis, and methods of processing;
  • the data controller’s identity; and
  • the entities or categories of entities to whom your Personal Data may be transferred.

2. Right to rectify or erase Personal Data

You have a right to request that we rectify inaccurate Personal Data. We may seek to verify the accuracy of the Personal Data before rectifying it.

3. You can also request that we erase your Personal Data in limited circumstances where:

  • It is no longer needed for the purposes for which it was collected; or
  • You have withdrawn your consent (where the data processing was based on consent); or
  • Following a successful right to object (see Right to object below); or
  • It has been processed unlawfully; or
  • To comply with a legal obligation to which we are subject.

4. We are not required to comply with your request to erase Personal Data if the processing of your Personal Data is necessary:

  • For compliance with a legal obligation; or
  • For the establishment, exercise, or defense of legal claims.

5. You can ask us to restrict your Personal Data, but only where:

  • Its accuracy is contested, to allow us to verify its accuracy; or
  • The processing is unlawful, but you do not want it erased; or
  • It is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend legal claims; or
  • You have exercised the right to object, and verification of overriding grounds is pending.

6. We can continue to use your Personal Data following a request for restriction:

  • Where we have your consent; or
  • To establish, exercise, or defend legal claims; or
  • To protect the rights of another natural or legal person.

7. Right to transfer your Personal Data

You can ask us to provide your Personal Data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

  • The processing is based on your consent or on the performance of a contract with you; and
  • The processing is carried out by automated means.

8. Right to object to the processing of your Personal Data

You can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to object to how we use your Personal Data for direct marketing purposes You can request that we change the manner in which we contact you for marketing purposes.

You can request that we not transfer your Personal Data to unaffiliated third parties for the purposes of direct marketing or any other purposes.

If you have any query or issues, please address the same to the Company, we ask that you please attempt to resolve any issues with us first.

If you would like to exercise any of the rights described above, please send us a request at the address or email provided in the Contact us section below. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete.

Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request.