and which may be used by the Company in future (collectively referred to as the “Platform”) of the individuals who browse, or access the Platform or provide information on or through the Platform, or whose information the Company otherwise collects, receives or processes in connection with its Services (as defined below) (hereinafter, collectively referred to as “Users”, “You”, “Your”, “Players”).
European Countries: This shall include countries in the European Union (EU) and the European Economic Area (EEA) and Switzerland;
GDPR: GDPR shall mean the General Data Protection Regulations, applicable as of May 25, 2018 in all member states of European Union (EU) to harmonize data privacy laws across Europe;
CCPA: The California Consumer Privacy Act of 2018;
COPPA: The Children’s Online Privacy Protection Act;
DOPPA: The Delaware Online Privacy and Protection Act;
IT Act: The Information Technology Act, 2000;
IT Rules: The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;
Personal Data: It refers any information about an individual which can be used to distinguish or trace an individual’s identity or any other information that is linked or linkable to an individual. Examples included but not limited to name, an identification number, an online identifier, location data, or one or more factors specific to the physical, physiological, mental, genetic, economic, cultural or social identity of that natural person and any other information that is so categorized by applicable laws. Personal Data includes the information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
When You submit Your Personal Data on Our Platform:
By undergoing the registration process, You consent to Us collecting Your Personal Data, including the Personal Data described in this Section.
Unregistered Users: If You are a passive user of the Platform and do not register for any Service (“Passive User”), You may still be subject to certain passive data collection as set out in Section 2.2 and Section 2.5 below.
The use and the collection of the Personal Data by the Company is dependent upon how the User interacts with the Platform and/or avail Our Services. For clarity, We collect the following categories of Personal Data in the following ways:
We shall use Your Personal Data in a fair and reasonable manner, and where We have a lawful reason to do so. Our use of Your Personal Data depends on the purpose for which You interact with Us. We may process Your Personal Data for the following purposes:
The legal basis on which We collect Your Personal Data:
We make clear disclosures when Users sign up on Our Platform and offer opt outs for anyone not interested (as discussed below)
We may share Your data, including Personal Data, with third parties such as other Users, Our affiliates or service providers that perform certain Services on Our behalf or that receive Services from Us. We share Your Personal Data with the following third parties:
Further, in several Octro games (For instance, Octro Teen Patti), other players regardless of whether they are Your social network friends will be able to see Your player profile, view description of Your in-game activity, communicate with You within Our Services and send You game or friend requests through Our Platform or related social media network.
We do not actively share Personal Data that directly identifies You with third-party advertisers for their direct marketing purposes unless You give Us your consent. To enable advertisers, ad networks, and offer wall providers to serve You with more relevant ads, they may collect, or We may collect and share with them via cookies or other similar technologies, certain information including performance data (like the number of clicks on an advertisement); technical information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID); a unique identifier (such as social network ID, Octro player ID) and or other contextual data about Your game play.
As a User of Our Platform, You may avail Yourself of the rights explained in this section. Please note, We may attempt to verify Your identity through the email address or telephone number associated with Your use of Our Platform prior to fulfilling any such request and reserve the right to deny a request where We are unable to satisfactorily complete this process. If You authorize someone to make a request on Your behalf, We may also deny Your request if We are unable to verify with You that the individual making the request is authorized to act on Your behalf.
In cases where We are data processors, We will forward any requests, inquiries or claims concerning these processing activities to the respective data controller for further assessment and necessary action.
If You want to stop receiving push notifications, which are messages an app sends You on Your mobile device even when the app is not on, You can turn off push notifications by visiting Your mobile device’s “settings” page. Many of Our games also offer the ability to turn off push notifications in the in-game “settings” page.
You can opt out of receiving SMS text messages by texting back STOP to the number We send the text from for that particular SMS text messaging program or by sending an email to the email id provided in “Contact Us” section below. When We receive an opt-out message from You for SMS text messages, We may send a text message confirming receipt.
Please note that if You opt out of receiving promotional communications from Us, We may still communicate with You from time to time if We need to provide You with information about the Services You are using from Us, if We need to request information from You with respect to a transaction initiated by You, or for other legitimate non-marketing reasons, for example, if We are required under applicable laws to notify You of updates to this Policy or Our terms of service.
Withdrawing consent: If We have collected and processed Your Personal data with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We conducted prior to Your withdrawal, nor will it affect processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about Our collection and Use of Your Personal Data, subject to EU GDPR. For more information, please contact Your local data protection authority. (For Users located in European Countries only)
To exercise Your rights to access or deletion, please submit a request through Our Personal Data Request Portal. If You have any problems with the Portal or would like to exercise any of Your other rights, You can send an email to the email id provided in the Contact Us section below. We respond to all data protection requests We receive in accordance with applicable data protection laws.
The Company does not knowingly collect data of children under the age of 13 (or under 16 for children located in the UK or European Countries or under 18 in the State of Delaware) (collectively, “Children” or “Child”). If You are a Child, You must ask Your parent or guardian for permission to use our Platform and/or Our Services. If any Child submits Personal Data to the Company and We learn that the Personal Data is the information of a Child, We will attempt to delete the information as soon as possible. If You believe that We might have any Personal Data of a Child, please inform Us by sending an email to the email id provided in the “Contact Us” section below.
Please note that We review and may make changes to this Policy from time to time and as required under applicable laws. We will not reduce Your rights under this Policy without Your explicit consent. When changes are made, the Policy link will include a notation “Last Updated date.” indicating that You should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. The notation will be included in this Policy link for at least seven (7) days after the update has been made. We will also use reasonable efforts to notify You of such change via email address, if such information is provided by the User. By accessing the Platform after any changes have been made, You signify Your agreement on a prospective basis to the modified Policy and any changes contained therein. In case You miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Policy.
Under the CCPA, Your Authorized Agent is responsible for implementing and maintaining reasonable security procedures and practices to protect and use Your Personal Data only for the purpose of fulfilling Your request.
If You have any questions, comments or concerns regarding our Policy, you may contact Us through our customer support page or through information provided below:
You can contact our grievance officer at: Email: mailto:firstname.lastname@example.org
The grievance officer is identified above pursuant to the provisions of applicable laws including but not limited to the IT Act, 2000 and the Consumer Protection Act, 2019, and the rules enacted under those laws.