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This privacy policy (Privacy Policy) adopted by YS TECH ANYTIME Private
Limited (hereinafter referred to as “YS TECH”, “We”, “Us” or “Our”) governs
the collection, use and transfer of information capable of identifying a
person (Personal Information) accessed or shared with Us by virtue of use or
access of our mobile applications or websites (Platform). By agreeing to
this Privacy Policy, or by accessing, or by using the Services (defined
below) through the Platform, you consent to the collection, transfer,
adaptation, alteration, storage, disclosure, and other uses of your Personal
Information as described in this Privacy Policy. If you have any concerns
about providing data, or having it used in any manner permitted in this
Privacy Policy, you should not use the YS TECH Services. Unless specified
otherwise, this Privacy Policy applies only to the Platform and services,
features, software, and functionalities offered by Us, via the Platform.
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For the purposes of this Privacy Policy, “Sensitive Personal Data or
Information” or “Sensitive Information” means Personal Information, that
consists of the (i) password, (ii) financial information, such as bank
account, debit or credit card details, (iii) physical, psychological and
mental health condition, (iv) sexual orientation, (v) medical records and
history, (vi) biometric information, (vii) any detail relating to the above
as provided to the body corporate for providing a service, and (viii) any of
the information received under each of the aforesaid heads by the body
corporate for processing, or to be stored or processed under a lawful
contract or otherwise.This Privacy Policy incorporates the requirements
under the Information Technology (Reasonable Security Practices and
Procedures and Sensitive Personal Data or Information) Rules, 2011.
i. Our Business & Policy Applicability
- YS TECH develops and operates software & technology products/ platforms and
associated services for enabling, conducting, and offering online cash-based
skill games i.e. games where there is a preponderance of skill over chance,
whether through the deployment of physical or mental skill (Services). By
accessing our Platform, users and players (hereinafter referred to as
“Users/”You”/”Your“) can access our Services, which include the provision of
access to various games available on the Platform. As set out in the terms
and conditions relating to the Services (the “Terms“), you must be at least
at a legal age (minimum age of 18 years) to access and/or use the Services.
The Services are not directed to persons under the legal age of majority or
any such persons residing outside India. We do not knowingly collect any
Personal Information from children under legal age. If We become aware that
a child under legal age has provided Personal Information, steps will be
taken to remove such information and terminate such an account. If you
become aware that any Personal Information of a child/minor is provided,
please contact our Grievance Officer (defined below). For the purposes of
this Privacy Policy, unless defined hereunder, all capitalized terms shall
have the meaning ascribed to them under the Terms. THIS PRIVACY POLICY DOES
NOT APPLY TO MOBILE APPLICATIONS OR WEBSITES WHICH ARE NOT OWNED OR
CONTROLLED BY YS TECH , INCLUDING THIRD PARTY LINKS AND APPLICATIONS WITH
WHICH YOU MAY INTERACT WHILE USING THE PLATFORM. WE WILL NOT ASSUME ANY
LIABILITY FOR ANY HARM CAUSED TO YOU BY ACCESSING ANY THIRD PARTY WEBSITES
OR LINKS ADVERTISED ON THE PLATFORM. YOUR ACCESS AND USAGE OF ANY
THIRD-PARTY WEBSITES OR APPS IS ENTIRELY AT YOUR OWN RISK. THE COMPANY SHALL
NOT BE A PARTY TO ANY TRANSACTION BETWEEN YOU AND A THIRD-PARTY SERVICE.
ii. Collection & Use of Information
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A. Personal Information We obtain and you hereby consent to provide your
Personal Information at the time of registration or from third-party service
providers you interact with or engaged by us. Such Personal Information
includes :
Registration – phone number/Google email ID, name, location
Customer support correspondence: When you ask for assistance from Our
customer support, the contact information you provide will be collected, as
well as information about your gameplay or activity on the Service, your
user ID number, and the correspondence. If available through the Services,
you may provide Us with certain profile information which you consent to
make public, such as a short biography, location, website, cell phone, a
picture, information to customize your account, etc. Such contact
information may be used to send you information about the Services or
related information.
B. Non-Personal / Aggregated Data: Additionally, Cashgrail may use data
management services to access device information; metadata of incoming and
outgoing calls and messages; device storage, device identifiers, call
related information and records, application history, etc. These permissions
are collected to better understand how users access and use our Services,
both on an aggregated and individualized basis, in order to improve our
Platform, analyse player traffic and activity, respond to user desires and
preferences, and for other research and analytical purposes. This includes:
Location Services: We and/or third parties may use and store information
about your location to provide special features, to deliver ads that relate
to your interests and/or to improve and customize the Services and to ensure
that you are not accessing the Platform from restricted states in India or
outside the territorial limits of the Republic of India.
Log Data Services: Our backend servers automatically record information
created by your use of the Services. This data may include information such
as your IP address, browser type, operating system, the referring web page,
pages visited, location, your mobile carrier, device and application IDs,
search terms, and cookie information. Log data is received when you interact
with the Services. This data is used to provide the Services and to measure,
customize, and improve them.
Third-party services: We use a variety of third-party services to help the
provision of the Services, such as hosting and other services. These
third-party service providers may collect information sent by your browser
as part of a web page request, such as cookies or your IP address, location
and devices’ unique identifiers. Also, third-party ad partners may share
information to measure ad quality and tailor ads, for example, to display
ads about things you may have already shown interest in.
C. Sensitive Personal Data or Information Collected: Please note that We
shall always take your express consent before collecting any Sensitive
Personal Data or Information.
We are committed to keeping all such Sensitive Personal Data or Information
safe at all times and ensure that such data/information is only transacted
provided the highest possible degree of care available under the technology
presently in use. We will not use Your Sensitive Personal Data or
Information for any purpose other than for such specific purposes as you
have expressly consented to its use.
If you opt for the paid functions on the Platform, YS TECH may collect the
billing and financial information necessary to process the charges,
including bank account details; and/or do so on behalf of the relevant
payment service providers. Purchases of third-party services are subject to
the policies applicable to such providers. Any payment data may need to be
retained only within India to comply with directives of the Reserve Bank of
India that apply to the payment service providers we engage to provide the
services.
Where we permit any third parties to collect and use your Sensitive Personal
Information, we, to the best of our knowledge, (i) ensure that such third
parties maintain the same security standards that are adhered to by us and
prescribed under applicable data protection laws for the protection of your
Sensitive Personal Information and (ii) take reasonable measures to ensure
that the third parties do not disclose the Sensitive Personal Information
unless such disclosure has been expressly consented to by you.
When You deposit money to Your wallet on the Platform by using a Virtual
Payment Address (VPA) of the Unified Payments Interface (UPI) payment
method, We may store such VPA to facilitate seamless and swift deposit
transactions for You in the future and for enhancing Your payment
experience. You understand, agree and consent to such storing of the VPA by
the Platform.
The Platform may also, from time to time, through the Payment System
Providers, fetch other VPAs associated with Your mobile number registered
with the Platform. These VPAs will be used to facilitate seamless and swift
deposit transactions for You and for enhancing Your overall payment
experience. You understand, agree and consent to the Platform obtaining such
VPAs from relevant Payment System Providers and storing and displaying such
VPAs to You on the Platform.
Disbursal Information Services: If you make a purchase in the Services, We
may collect and store the billing, payments, and financial information
necessary to process the charges/payments; and/or do so on behalf of the
relevant payment service providers. Purchases of third-party services are
subject to the policies applicable to such providers.
iii. Use of Information
- Some of the Personal Information, for example, your name and/or username,
may be listed publicly on the Services, including on your profile page and
in search results. You agree that We may use and store the Personal
Information for the purposes of contacting you as part of customer support;
to send you updates or information about the Services; managing your account
and relationship with the Service, improving the in-app experience,
facilitating seamless transaction, improving the Services, research,
surveying, and engaging with you, for example by sending you communications
for these purposes; marketing and promotion of the Services or other
products; to personalize and optimize the Services, promotional content
and/or advertising; to create reports, analysis or similar services for the
purposes of research or business intelligence. In certain circumstances,
such as improving Your user experience or enabling seamless payment
transactions for You on any online platform that We operate, we may use Your
financial information (including your UPI handle or Virtual Payment Address)
to display it on the relevant payment processing or checkout page of such
platform.
iv. Information sharing and disclosure
- We may disclose your Personal Information in the circumstances set out below
and you hereby consent to the same to be shared with:
Provision of Services: any third-party service provider to whom
disclosure
is necessary to enable Us to provide You with the services which You wish to
access on or through the Platform, for example, to process a disbursal
instruction your Information has to be provided to the payment processors.
Such companies shall be granted access to the Personal Information needed to
perform their functions and include:
Third-Party Data Recipient Entity Name |
Service/Function |
Payment gateways and payment aggregators |
For making transactions and depositing and withdrawing
money with us |
Juspay Technologies Private Limited (or any other agency
notified to you, who would be aiding our card-on-file
tokenization efforts) |
Disclosure of card details for obtaining tokenization
and technology services as per applicable RBI guidelines
|
SMS OTP providers |
For the generation of OTP |
IP Reverse Geolocation Providers |
To ascertain and act against Users from restricted
jurisdictions |
Analytical and data management service providers |
To obtain services for smooth functioning of the
Platform and customizing the Platform for
the needs of the Users, sharing such data with data
analytics services and tools which are
run on |
Law Enforcement: (i) any person/entity to whom disclosure is
necessary in
accordance with applicable law; (ii) any government or statutory authority
or court of law or judicial forum to whom disclosure is necessary in
accordance with applicable law; (iii) in circumstances We believe necessary
or appropriate to respond to valid claims and legal process, to protect the
property and rights of YS TECH, to protect the safety of the public or any
person or User, or to prevent or stop any illegal, unethical or legally
actionable activity; and (iv) any person/entity to whom disclosure is
necessary to enable Us to enforce Our rights;
Affiliates: to Our associate companies, business partners, agents or
third
parties for the purposes of the services or any other marketing and
promotional activity is undertaken by or on behalf of the Company;
Change in Control: any entity that legally acquires the Company or
its Platform. In the event that Cashgrail is involved in a bankruptcy,
merger, acquisition,
reorganization or sale of assets, your Personal Information may be sold or
transferred as part of that transaction. The undertakings in this Privacy
Policy shall
apply to the Personal Information as transferred to the new entity.
v. Your Rights
- We do not keep Your data for longer than is necessary unless we are required
to do so under applicable law. We will use Your Personal Information only
for so long as is necessary:
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i. to achieve the purposes that have been specifically
identified in
this
Privacy Policy or such purposes as having been identified in any
agreement
entered into with you;
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ii. as required by applicable laws and regulations, or as may be
required for
evidentiary purposes;
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iii. as deemed necessary for tax, fraud control, or mitigation,
and to
conduct a
defence in relation to any disputes or claims whether potential
or
actual
(taking into account statute of limitations under applicable
laws).
Your right to withdraw consent relates to any further collection or
processing, of your Sensitive Personal Information, however such withdrawal
of consent shall not: (i) be retrospective or require the deletion of
records required for statutory purposes; or (ii) operate where required for
the discharge of ongoing contractual obligations unless the contract under
which the Sensitive Personal Information is required to be collected is also
terminated with the request for withdrawal of consent to collect such
Sensitive Data.
Your data will be erased/deleted when it has served the purpose for which it
was being collected and is no longer necessary, where consent has been
withdrawn, or where retention of such data is contrary to or prohibited by
applicable law.
You have the right to data portability, i.e., you have the right to receive
a copy of your Personal Information in a commonly used and structured,
machine-readable format and have it transferred to another service provider
or third party after paying us a fee which shall be communicated upon your
request.
Vi. Protection of Information
- YS TECH maintains appropriate technical and physical safeguards to protect
Information against accidental or unlawful destruction or loss, alteration,
unauthorized disclosures or access, and any other unlawful forms of
processing of the data in its possession (Security Practices). All
information provided by You is stored and retained on a secure server . Such
Security Practices include, but are not limited to encryption, firewalls,
password protection, limitation of access to specified personnel on a need
to know basis, de-identification and encryption and other physical security
measures to guard against unauthorized access to the server and systems and
information residing on such server and systems. YS TECH Security Practices
are commensurate with the information assets being protected and with the
nature of the business. By using the Platform, you accept that the Security
Practice and procedures mentioned above, which are designed to protect the
information provided by You, are reasonable. Information including Sensitive
Personal Data or Information (other than such data that is subject to data
localization due to statutory or regulatory obligations) may be transferred
to third parties located and/or may be stored at worldwide destinations,
outside India or the location from which your information has been collected
which ensure a similar level of protection and security adhered to by us
under applicable Indian laws. However, we do not guarantee that Personal
Information cannot be accessed, disclosed, altered or destroyed by breach of
any of the abovementioned safeguards. We take all steps reasonably
necessary, including providing notice of breach to users, where required
under applicable law, to ensure that Personal Information is treated
securely and in accordance with this Privacy Policy. Irrespective of which
country you reside in or supply information from, you authorize Us to store
and/or use the Information according to this Privacy Policy in any country
where We may operate. PLEASE UNDERSTAND THAT, WHILE WE STRIVE TO PROTECT
YOUR PERSONAL INFORMATION AGAINST POTENTIAL RISKS AND EXPOSURES, THERE IS NO
ABSOLUTE SECURITY IN THE ONLINE/ INTERNET SPHERE. THEREFORE, YOU MUST NOT
DISCLOSE ANY INFORMATION ON THE PLATFORM THAT IS SENSITIVE PERSONAL DATA OR
INFORMATION WHICH IS NOT REQUIRED FOR YOU TO USE OUR SERVICES. YOU
UNDERSTAND THAT THE TRANSMISSION OF INFORMATION OVER THE INTERNET IS NOT
COMPLETELY SECURE AND THERE ARE RISKS ASSOCIATED WITH IT. ALTHOUGH WE STRIVE
TO PROTECT YOUR PERSONAL INFORMATION, WE CANNOT GUARANTEE THE SECURITY OF
THE SAME WHILE IT IS BEING TRANSMITTED TO OUR PLATFORM AND ANY TRANSMISSION
IS AT YOUR OWN RISK.
Vii. Term
- We may retain the Information for as long as is necessary to fulfil the
purposes for which it was collected or as needed to provide the Services,
even after you have discontinued or deleted any account, or after the end of
the provision of the Services, if retention of such Personal Information is
reasonably necessary to comply with legal obligations, meet regulatory
requirements, resolve disputes between users, prevent fraud, or any other
use. Subsequent to such a term, we will delete or anonymize your Personal
Information once the purpose has been fulfilled.
Viii. Grievance Redressal
- In case of any queries regarding our data processing activities or to
exercise your rights with respect to your Personal Information, please
contact us at ludorjhelp@gmail.com . for revoking your consent and
requesting deletion of your Personal Information held with us. We will
respond to your request as soon as possible, and in any event within 30 days
or in accordance with the timeframe permitted under applicable law. and
delete your Personal Information, except such information required by law to
be retained. If any court or other competent authority finds any of this
Privacy Policy to be invalid or unenforceable, the other terms of this
Privacy Policy will not be affected. This Privacy Policy is governed by and
interpreted in accordance with the laws of the Republic of India. You
consent to the jurisdiction and venue in such courts and waive any objection
as to an inconvenient forum. We reserve the right to revise or amend this
Privacy Policy from time to time.