Privacy & Cookie Policy

1. APPLICABILITY OF THIS POLICY

This Privacy & Cookie Policy (“Policy”) applies to the users (and their legal heirs and representatives) (“User”, “Users”, “You”, “Your”, “Yourself”) of the domains and sub-domains of the products listed in the table below, as well as the progressive web applications and / or mobile applications associated with any such domain or sub-domain (collectively, “Platform”) or the Content (as defined below):

On the Platform, Users can access a diverse array of digital content, including but not limited to: interactive games, quizzes, trivia, challenges, astrology-related features (such as horoscopes, tarot readings, zodiac insights, astrological forecasts, and numerology), live and recorded updates on sports events (including scores, commentary, analysis, social media posts, and statistics), reports and updates on trending topics and global events, including but not limited to, sports, entertainment, lifestyle, technology, and culture (collectively, “Content”), which are aggregated, licensed, purchased, and / or developed by Advergame Technologies Private Limited, a private limited company incorporated under the Companies Act, 2013, with its registered office at Awfis, L-29, First Floor, Connaught Place, New Delhi – 110 001 and corporate office at Awfis, 6th Floor, Suncity Success Tower, Golf Course Extension Road, Sector 65, Gurugram 122 005, Haryana, India (“We”, “Us”, “Our”, “Ours”). We own, manage, and operate the Platform.

This Policy is to make You aware of the procedures adopted by Us with respect to collection, use, storage, processing, disclosure, and protection of any information provided by You and / or collected by Us, while You use the Platform or the Content.

This Policy will be applicable to You in entirety when You use the Platform and / or the Content from within Company Platforms (as defined below) or Third-Party Platforms (as defined below). As the case may be, all the terms and policies of the Company Platforms or Third-Party Platforms shall also be applicable to You.

2. ACCEPTANCE OF THE TERMS OF THIS POLICY

This Policy should be read in conjunction and together with the Terms of Use.

By using the Platform, You agree to Our terms of processing Your Personal Data (as defined below) which You provide to Us in accordance with this Policy. In some cases, particularly if You reside in a country which is governed by a data protection regulation like General Data Protection Regulation (“GDPR”), We may ask You to provide explicit consent for You to access some of Our services.

The Platform and / or the Content may be made available to You within applications and websites owned by Us (“Company Platforms”) or third-party platforms, including but not limited to, third-party sites, mobile applications, and other internet products (“Third-Party Platforms”). Any Personal Data collected directly from You by Third-Party Platform is subject to privacy practices of those Third-Party Platform. Privacy choices You may have made on Third-Party Platforms will not apply to Us or Our use of the Personal Data collected from such Third-Party Platforms, or Personal Data collected directly through the Platform.

Please also note that the Platform may contain links to other sites e.g. sites of advertisers running promotions on Platform or Content, Third-Party Platforms that make Platform or Content available to their users, and other Third-Party Services (as defined below) not owned or controlled by Us and We are not responsible for the privacy practices of those sites. We encourage You to be aware of the privacy practices of other sites that may collect Your Personal Data.

3. ACCESS TO PLATFORM SERVICES

The access to the services on the Platform is only available to Users who are above the age of 18 (Eighteen). You must be 18 (Eighteen) years of age or older to use the Content and / or the Platform in any manner. By using the Content and / or the Platform, You hereby represent and warrant to Us that You are 18 (Eighteen) years of age or older, and that You have the right, authority, and capacity to use the Content and / or the Platform.

WE DO NOT INTEND TO COLLECT OR PROCESS ANY DATA FROM INDIVIDUALS BELOW THE AGE OF 18 (EIGHTEEN). THEREFORE, IF YOU ARE BELOW THE AGE OF 18 (EIGHTEEN) YOU MUST REFRAIN FROM USING THE PLATFORM AND THE CONTENT, BOTH VIA COMPANY PLATFORMS AND THIRD-PARTY PLATFORMS.

If at any stage in the future We plan on collecting Personal Data from individuals below the age of 18 (Eighteen), or create or target profiles personalized to them, We shall seek explicit parental consent prior to collecting and processing their Personal Data.

Further, you should not use the Platform and / or the Content, by means of any mechanism or technology (e.g. virtual private networks) which conceals your actual geo-location or provides incorrect details of Your location. We will not be responsible or liable for any collection, storage, or processing of Your Personal Data or any other data if You use any mechanism or technology which conceals your actual geo-location.

4. COLLECTION AND USE OF PERSONAL DATA

“Personal Data” means any information relating to an identified or identifiable natural person. This encompasses, but is not limited to, the following: name, an identification number location data, an online identifier (e.g. username or IP address), email address, phone number, biometric data, or any factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. When anonymised information is directly or indirectly associated with Personal Data, the resulting information is also treated as Personal Data.

Your use or access of the Platform and / or Content will result in Your Personal Data being processed and used by Us. We may collect anonymized data from Users based on activity performed on the Platform. Such data, in its anonymized state, is not associated with any Personal Data and is not subject to this Policy. However, if anonymized data is later linked, directly or indirectly, to Personal Data, it will be treated as Personal Data in accordance with this Policy.

5. TYPES OF PERSONAL DATA COLLECTED

a) Personal Data provided by You voluntarily

If You send Us any personal correspondences, such as emails or letters, or if other users or Third-Party Platforms send Us correspondences about Your activities on the Platform, We may collect and process such information. We may collect additional information at other times, including but not limited to, when You provide feedback, or change email preferences, or contact Us. This information includes the information You explicitly share with Us during such correspondence like Your name, email address, phone number, address, etc.

b) Information automatically collected while You browse / use the Platform / Content

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:

i. 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.

ii. From Your device: Type of device, device manufacturer, advertising identifier, device identifiers (such as IMEI), operating system and version, carrier, language settings, geo-location, network type (2G, 3G, 4G, Wi-Fi, etc.), screen resolution, etc.

iii. From Third-Party Services: Reports on activity, engagement metrics on Platform and Content, usage trends, etc.

c) Personal Data collected while using the Platform / Content through Third-Party Platforms

We may also collect additional Personal Data 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 not be limited to, the username, pictures, phone number, e-mail address 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, retain and process such information collected from the Third-Party Platform, including Personal Data and content in accordance with this Policy.

Note that since Platform and / or Content may be 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.

d) Personal Data collected by Third-Party Services

Content and / or Platform, may contain advertisements, which could be targeted and interest-based. We may display advertisements to You based on Your Personal Data, and / or based on Your engagement with Platform and / or Content, and / or based on the policies of Third-Party Services. Towards this, if You use Your accounts on third-party products (including but not limited Google, Facebook, WhatsApp, 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; further, there are certain third-party tools that We have integrated on Platform and / or Content, including but not limited to: Advertising Partners (as defined below) (for instance, Google AdSense), ad server (for instance, Google Ad Manager), analytics tools (for instance, Google Analytics), cloud services providers (for instance, Amazon Web Services), etc. (collectively, “Third-Party Services”) that may directly or indirectly collect and process Your Personal Data . We may also share Your Personal Data with such Third-Party Services. If mandated by the applicable laws, Your Personal Data may be shared with or collected by certain technology providers declared through the consent management platform. The collection, use, and processing of Your Personal Data by such Third-Party Services will be governed by their respective privacy policies, where they act as independent data controllers. In cases where such Third-Party Services act as data processors on Our behalf, their processing of Your Personal Data is governed by contractual obligations and carried out in accordance with applicable data protection laws.

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

e) Financial Information

We currently do not charge any fees from the Users to access the Platform.

Please note that We never ask for banking or financial details, passwords, or any Personal Data of financial nature. Therefore, please refrain from sharing such information with the Platform or other Users.

f) Cookies

Cookies are tiny pieces of information that websites store on Your device (like Your computer or phone) when You browse them. These files help the website, and sometimes other companies, remember things like Your login information, preferences, and past browsing choices. This makes Your next visit to the website smoother and allows the website to offer a more personalized experience, tailored to Your interests.

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 targeted and interest-based advertising).

6. Cookie Framework

a) Why do we need cookies?

We use cookies in order to offer You a more tailored experience by understanding and remembering your browsing preferences. Cookies serve various purposes, such as:

(i) Delivering Our services smoothly and efficiently.

(ii) Understanding how You use the Platform and gaining analytical insights so We can constantly improve it.

(iii) Showing You relevant ads and recommending content You might like based on Your interests.

(iv) Distinguishing You from other users to provide a tailored experience and prevent unauthorized access.

(v) Protecting You and Our Platform from fraudulent activity.

(vi) Processing any requests You make to Us with speed and accuracy.

b) How long do cookies stay on Your device?

A number of cookies We use last only for the duration of Your session on the Platform and / or Content and expire when You close Your browser or exit the Third-Party Platform. Others are used to remember You when You return to the Platform and may persist on Your device depending on their function, such as saving preferences or enabling analytics. These cookies can last anywhere from a few seconds to several months, and in some cases, up to one year. We use cookies for a variety of purposes, and the table below outlines the main categories and their typical uses.

c) Types of cookies

The table below showcases the different types of cookies that are used while accessing the Platform and /or the Content:

• Lotame Panorama ID Lotame Panorama ID connects online and offline data into a unified ID for targeting and analytics.

Lotame Panorama ID's privacy policy is available on their website.

To opt-out of being tracked by Lotame Panorama ID, visit their opt-out page.

• Audigent Hadron ID Audigent Hadron ID is a first-party identity framework that leverages premium publisher data to deliver addressable and privacy-safe audience targeting.

Audigent Hadron ID's privacy policy is available on their website.

To opt-out of being tracked by Audigent Hadron ID, visit their opt-out page.

• Prebid SharedID Prebid SharedID is an open-source, user- consented identifier developed by Prebid to support identity resolution and audience targeting without relying on third-party cookies.

Prebid's privacy policy is available on their website.

To opt-out of being tracked, please write to privacy@prebid.org for more information on how to do so.

| Advertising Cookies* | These cookies may be set by Advertising Partners or other technology providers through Platform and / or Content. These cookies are used by such Third-Party Services to build a profile of Your interest and show You targeted and / or relevant advertisements. They may also be used to know whether You have earlier seen an advertisement or a type of advertisement, how long it is since You have seen it, and the effectiveness of an advertising campaign. | We are an advertising-supported service. We partner with Third-Party Services to provide advertisements on Platform and / or the Content ("Advertising Partners"). These Advertising Partners collect certain information from the Users and use them to serve Users with advertisements on Platform and / or Content, and analyse Users' response to particular advertisements. Advertising Partners that place advertising cookies on the Platform and / or Content include, but are not limited to, those listed below:
• Google (AdSense, Ad Exchange, and Ad Manager, etc.): You can view and edit the interests associated with Your browser as well as opt out of personalized advertising on their website. See Google's privacy policy and cookie policy on their website.
• PubMatic: You can opt-out from collection of information via cookies for purposes of interest-based advertising on their website. See PubMatic's privacy policy and cookie policy on their website.
• Amazon Publisher Services (APS): You can opt-out of interest-based advertising on their website. See APS's privacy policy and cookie policy on their website. APS is a suite of cloud services built by Amazon through which various Advertising Partners can bid to show ads on websites (such as Platform and / or Content) using a technology called header bidding. Advertising Partners participating through APS (list can be seen on the APS website) may have their own data practices. We encourage You to review their privacy policies for further details on how they handle Your information.
• Index Exchange: You can opt-out of interest-based advertising by visiting their opt-out page and selecting Index Exchange. See Index Exchange's privacy policy and cookie policy on their website.
• Taboola: You can view and edit the interests associated with Your browser as well as opt out of personalized advertising on their website. See Taboola's privacy policy and cookie policy on their website.
• OpenX: You can opt-out of interest-based advertising on their website. See OpenX's privacy policy and cookie policy on their website.
• TripleLift: You can know how to opt-out of interest-based advertising on their website. See TripleLift's privacy policy and cookie policy on their website.
• Magnite: You can opt-out of interest-based advertising on their website. See Magnite's privacy policy and cookie policy on their website.
• Missena: See Missena's privacy policy and cookie settings on their website.
• Xandr: You can opt-out of interest-based advertising on their website. See Xandr's privacy policy and cookie policy on their website.
• Kargo: You can opt-out of interest-based advertising on their website. See Kargo's privacy policy on their website.
• MGID: See MGID's privacy policy and cookie notice on their website. You can opt-out of interest-based advertising by navigating to section 4 of MGID's privacy policy under the heading "your rights".
• Kueez: You can opt-out of interest-based advertising by navigating to the relevant section in the privacy policy of Kueez on their website. See Kueez's privacy policy on their website.
• Equativ: See Equativ's privacy policy and cookie policy on their website. You can opt-out of interest-based advertising by navigating to the relevant section in the privacy policy of Equativ on their website.
• Aditude: See Aditude, Inc's privacy policy on their website. You can opt-out of interest-based advertising by going through their Privacy Policy and navigating to the section titled "9. Your Choices About the Information We Collect," then following the instructions provided there.
• InMobi: See InMobi's privacy policy on their website. You can opt-out of interest-based advertising by going through their privacy policy and navigating to the section titled "What are my privacy rights," then following the details provided there. |

*Note: The other Advertising Partners, ad agencies, and vendors with which We work may be members of the Network Advertising Initiative, the Digital Advertising Alliance Self-Regulatory Program for Online Behavioural Advertising, and / or the European Digital Advertising Alliance. To opt-out of interest-based advertising from the other Advertising Partners, ad agencies, and vendors, please visit AboutAds.info or the European Digital Advertising Alliance for laptops and NAI Mobile Choices or AppChoices for mobile devices. Note that opting out through these channels does not mean You will no longer see ads. You may still see ads that may not be interest-based.

Disclaimer: Please note that some of the links provided in this Policy—such as those included in the "Types of Cookies" table above—may direct You to third-party websites. While We strive to ensure that these links are accurate and up to date, We do not guarantee their availability or functionality at all times. Users are encouraged to visit these websites directly to verify the information and obtain any additional details they may require. We disclaim any liability for the content, accuracy, or availability of any third-party sites linked herein. Use of such third-party links is at your own discretion and risk.

d) Your choice: Accepting / Disabling Cookies

You have a choice on how We use cookies with respect to Your use of the Platform and / or the Content. Please note that if You limit Our ability to use cookies, You may not be able to access all or parts of the Platform and / or the Content.

The saving of a cookie on a device is governed by user-defined settings of the browser or device. If You have accepted the option to allow the collecting and saving of cookies through Your browser or device, they will be integrated into the pages and content You have viewed and may be temporarily stored in a dedicated location on Your browser or device. Such cookies will be readable only by their issuer.

You have the choice, at any time, to delete or disable all or part of these cookies using Your browser or device, except for the essential cookies which are necessary for the Platform to function.

Wherever required We will seek consent prior to collecting the cookie. At any point if You want to withdraw consent of the cookies then You can delete the cookies from Your browser.

e) Disabling cookies or withdrawing consent to use of cookies

The effect of disabling cookies depends on which cookies You disable but, in general, the Platform may not operate properly if all cookies are switched off. If You disable all cookies, You may deteriorate Your overall user experience of the Platform, since it may no longer be personalized to You. It may also prohibit You from saving customized settings.

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

(i) Google Chrome

(ii) Safari on Mac and Safari on iPhone and iPad

(iii) Firefox

(iv) Microsoft Edge

(v) Samsung Internet

(vi) Brave

(vii) Opera

To find information relating to other browsers, please visit the browser developer's website. Please be advised that Users should refer to the official website of their respective browsers to confirm that the links provided above are current and functional. The inclusion of these links in this Policy is based on their status as of the last update date of the Policy.

If You want to remove previously stored cookies, You can manually delete the cookies at any time. However, this will not prevent the websites from placing further cookies on Your device until You adjust Your internet browser setting as described above.

f) Non-cookie-based tracking

If You have concerns about cookies generated by Advertising Partners, You can disable them by visiting the 'Your Online Choices' website or using a similar application. It's essential to understand that while these tools are effective for managing traditional cookies, they may not offer comprehensive control over non-cookie tracking methods that specific third parties may employ on our Platform and / or Content.

It's crucial to note that even with cookies blocked, third parties, including Third-Party Services, may utilize alternative technologies such as statistical identification, eTags, and web or browser cache on Our Platform or Content. Despite Your cookie settings, these third parties may still collect information, often for purposes such as optimizing website performance or enhancing Your personalized experience by remembering Your preferences.

Here are some additional steps You can take to avoid non-cookie-based tracking:

(i) Explore browser settings: Many browsers offer controls for managing tracking technologies, in addition to cookies.

(ii) Explore other options: Resources like the Digital Advertising Alliance website provide information and tools to manage Your online preferences.

g) Device Information

Any device, browser, or platform on which You access and use the Platform and / or Content generally comes pre-loaded with certain permissions, such as network and storage access, without which We cannot provide You with Our services. Other optional permissions, such as installing a progressive web application, are sought when accessing specific features.

Each platform (e.g. Android / ChromeOS, iOS / macOS, Windows, Tizen, KaiOS, HarmonyOS, Linux, Blackberry OS) has its own permission system for procuring Your consent for optional permissions. Depending on the platform You use, Your device or browser will either: (a) notify You of such additional permissions, if any, You provide prior to using the Platform for the first time, or (b) will require Your consent to proceed.

You maintain control over permissions. Through platform settings, You can grant or deny access to the permissions.

7. PURPOSE OF COLLECTION AND LAWFUL BASIS OF PROCESSING

We only collect and process Your Personal Data on lawful bases, prioritizing utmost transparency and compliance with data protection laws. These lawful bases include:

a) Your explicit consent: For specific purposes, We obtain Your clear and informed consent;

b) Legal obligations: We may process Your Personal Data to fulfil Our mandatory obligations under applicable laws and regulations;

c) Contractual necessities: We may process Your Personal Data to fulfil Our contractual obligations to You; and

d) Legitimate interests: Where strictly necessary for Our legitimate interests, such as optimizing Our Platform, enhancing Your experience, and providing effective customer support, We may process Your Personal Data. We always diligently assess and balance these interests with Your fundamental privacy rights.

We may use the Personal Data collected for the following purposes:

(i) Account Management:

• Facilitate Your registration and secure access to the Platform.

• Verify Your identity and maintain accurate accounts for Users.

(ii) Content Delivery and Personalization:

• Determine Your geographic location to provide relevant Content.

• Improve Content and Platform based on usage data and User feedback.

• Personalize Your experience and offer tailored recommendations based on Your interests and preferences.

• Assist You in efficiently accessing Your information and tracking progress within the Platform.

(iii) Marketing and Communications:

• Run advertising and promotional offers relevant to Your interests.

• Send occasional emails with Platform updates, news, and related product or service information.

(iv) Customer Support and Dispute Resolution:

• Resolve disputes and address any grievances You may have.

• Provide effective customer support and technical assistance.

(v) Security and Compliance:

• Monitor aggregate metrics, analyse usage patterns, and maintain Platform security.

• Notify You about important Platform and security updates, including changes to Terms of Use and this Policy, where feasible.

• Inform You of any potential or actual security breaches and take appropriate action to protect Your data.

• Comply with legal and regulatory obligations imposed on Us.

(vi) Platform Operations:

• Maintain records of Our interactions with You for administrative purposes.

• Conduct research and analysis to improve Platform performance and User experience.

(vii) Social Connectivity:

• Assist You in connecting with friends from social media networks or Your device’s contacts list.

(viii) Rights Protection:

• Enforce Our rights or protect Our affiliates, associates, employees, directors, or officers.

• Disclose Personal Data when necessary to identify, contact, or bring legal action against someone causing harm to Our rights or the Platform.

The Personal Data obtained from You will be processed by Us solely for the above-mentioned purposes and none other. Your Personal Data might also be shared with Our employees and associated partners. However, We ensure that these parties are also bound by contractual obligations to process Your Personal Data only for the specified purpose(s) and they implement technical measures to safeguard Your Personal Data. In the event We wish to process Your Personal Data for purposes other than those mentioned herein, We shall seek specific consent from You prior to processing Your Personal Data for such additional purposes unless the same falls within legitimate business interest for processing.

8. DISCLOSURE OF PERSONAL DATA

a) Service providers and third parties providing services We may engage Third-Party Services, located within or outside the European Union (“EU”), to perform certain functions on Our behalf, such as hosting or operating the Platform, storing Personal Data, sending OTPs, mitigating fraud, and providing data analysis. These parties may act either as data processors or independent controllers. Where they act as processors, their processing is governed by contractual agreements and applicable data protection laws, and We remain responsible for ensuring compliance. Where they act as independent controllers, their processing is governed by their own privacy policies. We recommend that You review these policies accordingly.

While We prioritize partners committed to data security and privacy, We cannot fully guarantee their independent practices. While We take reasonable steps to partner with third parties who uphold data protection standards, We are not responsible for the data handling practices of such third parties acting as independent data controllers. Their use of Your Personal Data will be governed by their respective privacy policies. In cases where We engage third parties as processors, We ensure they process data strictly under contractual obligations and applicable laws.

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 Data. We shall not be liable for any loss or injury caused to You as a result of, You and / or Us providing Your Personal Data 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, unauthorised 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.

To know the third parties with whom Your Personal Data is shared, kindly write to Us on privacy@gamezop.com.

b) Affiliate Sharing and Business Transfers

In the event of corporate sale, merger, reorganization, sale of assets, dissolution, or bankruptcy, Your information, including Personal Data, may be part of the transferred assets. In the unlikely event that We go out of business or enter bankruptcy, Personal Data may 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 Data as set forth in this Policy.

c) Legal Protections and Other Disclosures

We may disclose Your Personal Data if and when required by law, applicable legal process, a court order, or a competent governmental authority. This includes necessary disclosures for verifying Your identity or other personal information You provide; preventing, detecting, investigating, or prosecuting criminal offenses or fraud (including cyber incidents); enforcing this Policy or other applicable terms and conditions (including intellectual property rights); and protecting the rights, safety, or property of ourselves, Users, or third parties.

Such disclosures will be made in good faith and to the extent reasonably necessary for the relevant purpose(s).

9. YOUR CONTROLS AND CHOICES

a) Accessing & rectifying Your Personal Data

When You use the Platform, We make good faith efforts to provide You with the right to access Your Personal Data and to uphold its accuracy.

You can send Us an email for accessing and rectifying Your information by contacting Us at: privacy@gamezop.com.

b) Data Portability

You may also be entitled to request copies, in a structured, commonly used, and machine-readable format, of Personal Data that You have provided to Us, wherever feasible. Alternatively, You may request for Your Personal Data to be transmitted to another service provider directly by Us (where technically feasible).

c) Data Retention and Erasure

We retain Your Personal Data for legitimate business interests as long as necessary for the purposes for which it was collected. We may also need to retain Your Personal Data for Us to comply with Our legal obligations. If You wish to erase Your Personal Data or no longer want Us to process Your information, You can request deletion by contacting Us at: privacy@gamezop.com.

Please note that due to technical considerations related to data backup and contingency support, complete removal of all Personal Data may not be immediately feasible. We are committed to ensuring that Your Personal Data is retained only for as long as necessary and in compliance with applicable data protection laws.

d) Objection and Restriction of Processing

Where Your Personal Data is processed for customer support, capturing location, etc., or where Our lawful basis of processing Your information is legitimate interest, You may, at any time ask Us to restrict or object processing of Your data for these purposes by contacting us on privacy@gamezop.com.

In the event You wish to temporarily restrict or object to processing of Your Personal Data at any time, You may choose to do so by contacting Us at privacy@gamezop.com.

Please be aware that if You do not allow Us to collect Personal Data from You, We may not be able to deliver certain experiences, and services to You, and some of Our services may not be able to take account of Your interests and preferences. If collection of Personal Data is mandatory, We shall inform the same to You at the point of collection so that You can make an informed decision whether You wish to allow the processing of such Personal Data.

To send Us a request for any of the above-mentioned purposes, You will have to first extract your cookie ID, for which You can refer to Our user guide and share it with Us along with Your request:

• on an e-mail at privacy@gamezop.com, or

• by raising request through Our official form.

We may take up to 30 (Thirty) days from the date of receipt of request to fulfil it. However, if the nature of Your request requires significant effort or is time consuming in terms of locating the date or in terms of volume of data involved, We may ask for an extension of a further 60 (Sixty) days by giving You a prior notice and the reason for the extension.

We advise the Users to identify themselves and the information requested to be accessed or corrected before submitting such requests. We may decline to process requests that are unreasonably repetitive or systematic, requiring disproportionate technical effort, jeopardizing the privacy of others, or would be extremely impractical or for which access is not otherwise required.

We shall not charge You for fulfilling any of the above requests. However, if the fulfilment of any such request leads to certain costs being incurred by Us, then We will notify the same to You prior to processing such request.

10. CHILDREN’S PRIVACY

We do not intend to collect or knowingly collect information from individuals below the age of 18 (Eighteen). We do not intend to collect or process any data from individuals below the age of 18 (Eighteen). Therefore, if You are below the age of 18 (Eighteen) You must refrain from using the Platform and the Content, both via Company Platforms and Third-Party Platforms.

If at any stage in the future We plan on collecting Personal Data from individuals below the age of 18 (Eighteen), or create or target profiles personalized to them, We shall seek explicit parental consent prior to collecting and processing their Personal Data.

11. DATA TRANSFER, STORAGE & PROCESSING GLOBALLY

We operate globally and may transfer Your Personal Data to Our affiliated companies or third parties in locations around the world for the purposes described in this Policy. Wherever Your Personal Data is transferred, stored or processed by Us, We will take reasonable steps to safeguard the privacy of Your Personal Data. Additionally, when disclosing Personal Data to any third party outside the European Union, We ensure our legal agreements with such third parties include standard contractual clauses approved by the European Commission. We also adopt other means under European Union law for ensuring adequate safeguards and protection of Personal Data transferred outside the European Union.

12. OUR COMMITMENT TO PRIVACY AND CHOICES

We respect Your privacy and are committed to protecting the Personal Data that You provide, in connection with Your use of Platform. We take reasonable and appropriate precautions to protect Your Personal Data from unauthorized disclosure and to prevent possible security breaches.

We incorporate commercially reasonable safeguards to help protect and secure Your Personal Data. However, because electronic data can be intercepted, corrupted, lost or destroyed, please note that We cannot ensure or warrant the security of any data, and Your use of the Platform is at Your own risk. We are continuously implementing and updating administrative, technical, and physical security measures to help protect Your information against unauthorized access, loss, destruction or alteration. If You know or have reason to believe that Your account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of Your account, please contact Us using the contact information provided below.

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. 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. We shall not be held liable for any loss, damage, or misuse of your Personal Data if such loss, damage, or misuse is attributable to phishing attacks.

Notwithstanding anything contained in this Policy or elsewhere, We shall not be held responsible for any loss, damage, or misuse of Your Personal Data, 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 it is beyond Our reasonable control), power or electricity failure, or unavailability of adequate power or electricity.

13. NOTIFICATION OF CHANGES AND YOUR ACCEPTANCE OF THE PRIVACY & COOKIE POLICY

We will update this Policy from time to time in response to changing legal, regulatory, or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the Platform after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If You do not wish to acknowledge or accept any updates to this Policy, You may stop using the Platform and / or the Content.

14. CONTACT INFORMATION

a) 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:

Aadesh Anish

Grievance Officer and Data Protection Officer

Email: privacy@gamezop.com

Address: 1st Floor, L-29, Connaught Place, New Delhi 110 001, India

b) European Union Data Representative: This appointment is made as a precautionary measure for instances where Our processing activities may fall under the jurisdiction of the GDPR.

For GDPR-related matters, You may contact:

Prof. Peter Kabel

European Union Data Representative

Email: pkabel@kabel.de

Address: Bernadottestraße 26, 22763 Hamburg, Germany

ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This supplemental Privacy & Cookie Notice is an addendum to the information provided in Our Policy above and applies solely to California residents.

Please note that this section does not apply to any third-party website or application that You may access via the Platform. These Third-Party Services are governed by the privacy and cookie policies that appear on their sites and applications. As used in this section of the Policy, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or household.

A. Information We collect and disclose when You use Platform

We, Our service providers and / or associated third parties may collect the following categories of information for business or commercial purposes as defined under the California Consumer Privacy Act (CCPA) and other relevant privacy laws. Examples of these uses are identified below:

B. Business or commercial purposes for collecting and disclosing Your Personal Information through the Platform

We, Our service providers and / or associated third parties may collect the above mentioned categories of information for the following business or commercial purposes:

i. Process Your registration on the Platform;

ii. Determine Your geographic location and provide Content available in the said territory;

iii. To improve Content and Platform, and to help You efficiently access Platform and / or Content;

iv. To personalize Your experience and make bespoke recommendations;

v. To help You efficiently access Your information and the progress each time You use Platform and / or Content;

vi. For running advertising and promotions;

vii. To resolve Your disputes with Us and to resolve Your grievances;

viii. To carry out Our obligations and to process transactions arising from any contracts entered into between You and Us;

ix. Conduct research and analysis to detect, prevent, mitigate, and investigate fraudulent or illegal activities;

x. 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.;

xi. 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;

xii. To enable Us to comply with legal and regulatory obligations;

xiii. To administer a contest, promotion, survey, etc. or to maintain record of Our dealings with You;

xiv. To help You to connect with Your friends from social media network or device's contacts;

xv. 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.;

xvi. Notify You about changes in terms of service or in this Policy;

xvii. To enforce or protect Our rights, 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.

C. Information sharing

We share Your information captured through the usage of Platform with any service providers or third parties in the following circumstances:

a) Service providers and Third Parties Providing Services on Our Behalf

We may, from time to time, employ service providers to perform certain functions on Our behalf, such as hosting or operating the Platform, storing the Personal Information, sending OTP or message communications, and providing data analysis services etc. Any Personal Information shall be disclosed to such service providers only after getting into a contract with them to ensure complete protection of Your Personal Information. These service providers are prohibited from using your Personal Information for purposes other than those requested by Us or required by law.

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.

b) Affiliate Sharing and Business Transfers

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.

c) Legal Protections and Other Disclosures

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, We may disclose Your Personal Information as necessary to comply with such legal requirements. 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.

D. Do Not Sell / Share My Info

We share and disclose some of Your information like name, email id, device details, and phone number to associated third parties to provide You with service on the Platform. Under California Consumer Privacy Act, 2018 (“CCPA"), users based out of United States have the right to “Opt Out” of such sale of their information at any time.

If You are located in the United States and would like to opt-out of the sale or sharing of Your Personal Information, a pop-up may appear when You visit the Platform giving You the option to do so. If You do not see the pop-up or dismiss it, You can still opt out at any time by clicking the “Do Not Sell My Personal Information” link available in the footer of the Platform. You can also submit an opt-out request by emailing Us at privacy@gamezop.com along with Your name.

Please note that We do not knowingly sell the Personal Information of individual under the age of 18 (Eighteen) years without legally required affirmative authorization.

E. United States Residents’ Rights

Residents of U.S. are entitled to rights under certain state laws which are as follows:

a) Right to Know and Access: You can request and receive a copy of the specific pieces of the Personal Information that We have collected from You and shared with the associated third parties.

b) Right to Delete: You can request deletion of Your Personal Information that We have collected except where an exemption applies.

c) Right to Correct Inaccurate Personal Information: You can request correction of Your Personal Information that We have collected by contacting Us on privacy@gamezop.com.

d) Right to Limit the use and Disclosure of Sensitive Personal Information: You can request limiting of usage and disclosure of Your sensitive Personal Information (We only capture account log in details) that We have collected by contacting Us on privacy@gamezop.com.

We take reasonable steps to verify Your identity before responding to any of the above requests. These steps may include, at a minimum and depending on the sensitivity of the information requested and the type of request, verifying Your name, email address, or mobile number.

You are also permitted to designate an authorized agent to submit certain requests on Your behalf. In order for an authorized agent to be verified, You must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with You to verify Your identity before processing the authorized agent’s request.

If You would like to exercise any of the rights, please send Us an email at privacy@gamezop.com.

F. Non-discrimination for exercising Your rights

CCPA prohibits discrimination against California residents for exercising their rights under CCPA. We hold the practice of non-discrimination strongly and do not deny or provide a different level or quality of services or charge different rates or penalties on residents who exercise their CCPA rights.

G. Metrics

CCPA requires Us to compile metrics for the previous calendar year regarding consumer requests and responses catered. We will disclose the metrics with relevant details by July every year.

Under the metrics reporting provision, or Section 999.317(g) of the Attorney General’s CCPA regulations, we have compiled metrics related to user requests from the previous calendar year here.