Privacy Policy

1. Introduction

1.1. This Privacy Policy (“Policy”) governs the collection, storage, use, disclosure and protection of your (hereinafter, the “User”) Personal Data (as described in Clause 3) in the course of the User’s access of, use of, playing of and participation in (hereinafter collectively, the “Use”) the Game(s) (as described in the Terms and Conditions (“T&C”)) offered by Indibid Private Limited (hereinafter, the “Provider”) through and/or on its website www.indibid.in and mobile application INDIBID (hereinafter, collectively, the “Platform”).
1.2. The Privacy Policy should be read together with the T&C. Any terms used herein but not defined shall have the meaning ascribed to them in the T&C.

2. Legal Effect

The Use of the Games and the Platform by the User implies the User’s consent for collection, storage, use, disclosure and protection of their Personal Data by the Provider in accordance with the T&C and this Privacy Policy. The Use of the Games and the Platform constitutes acceptance of this Privacy Policy by the User. This Privacy Policy constitutes a legal binding contract between the User and the Provider. This document is an electronic record in terms of the Information Technology Act, 2000 and rules there under as applicable and various other statutes. This electronic record is generated by a computer system and does not require any physical or digital signatures.

3. Collection Of Personal Data And Purpose

3.1. The User data collected under Clause 3.2 and 3.3 of this Policy is collectively referred to as “Personal Data”.
3.2. The Provider collects the following data relating to the User during the Use of the Game(s) and the Platform:

(a) Name
(b) Mobile number and mobile carrier
(c) User ID
(d) Gender (if provided by the User)
(e) Full address and State of residence (when provided by the User)
(f) Email address (when provided by the User)
(g) Date of birth (when provided by the User)
(h) Profile picture (when provided by the User)
(i) Statistics of the User’s Use of the Game(s), including details of winnings/rewards, scores and gameplay history
(j) User Account activity, including Indibid Credits transacted and rewards won
(k) Any content posted, hosted, displayed, uploaded, published, transmitted, stored, shared by the User on the Platform, including any communications of the User with the Provider
(l) IP address, domain servers, browser type, the referring web page, pages visited, search terms, and cookie information
(m) Device information, operating system, messages, device storage, device identifiers and application history
(n) Location and time data
(o) All such data/information that may be generated as a result of the User’s Use of the Game(s) and the Platform or provided by the User to the Provider
(p) Any proof regarding any information provided by the User to the Provider

3.3. The Provider collects the following sensitive personal data related to the User during the Use of the Game(s) and the Platform

(a) Payment information (such as UPI ID, bank account, e-wallet and credit/debit card information) (when provided by the User)
(b) Aadhar Number and Card (when provided by the User)
(c) Permanent Account Number and Card (when provided by the User)
(d) The details of financial transactions carried out on the Platform, including deposits.
(e) Prize(s) won/redeemed/collected/forfeited
(f) Any other documents or information required for the purpose of KYC

3.4. The Personal Data is collected for the purposes of enabling the Use of the Game(s) and the Platform, ensuring fair play, ensuring compliance with applicable laws and the T&C, processing User’s payments, prizes and rewards, survey and research the User and their Use of the Game(s) and the Platform, analysis of User activity and traffic, maintenance and improvement of the Game(s) and the Platform, promotional and marketing activities and insurance.
3.5. The Provider utilises the services of several third party partners for the purposes set out in Clause 3.4 above. These third party partners may collect the User’s Personal Data and other data in the course of providing services to the Provider. The User hereby consents to the collection, storage and use their Personal Data and other data by such third party providers.
3.6. The User shall have the option to not provide the Personal Data or withdraw consent for provision of the Personal Data any time by making a request in writing. However, in case the User does not provide the Personal Data or withdraws consent for provision of Personal Data, then the Provider shall not permit the User to Use the Game(s) and the Platform or stop the User’s Use of the Game(s) and the Platform (as the case maybe).

4. Use, Sharing And Disclosure Of Personal Data

4.1. The Provider may share/disclose the User’s Personal Data with third parties as follows:

(a) The User’s name, mobile number, full address, state of residence and email address may be shared and disclosed to the Provider’s business partner(s) from whom the prize is procured and the business partner(s) responsible for delivering the prize.
(b) The User’s IP Address, Location information etc may be shared with IP Reverse Geolocation Providers in order to ascertain if the User is Using the Game(s) and the Platform from a jurisdiction prohibited as per Clause 3.1 of the T&C.
(c) The User’ sensitive personal information as set out in Clause 3.3 of this Policy may be shared with and disclosed to the Provider’s business partner(s) who are providing payment and banking services for the Game(s) and the Platform.
(d) The Provider may share anonymised and aggregated data of the Users with advertisers.
(e) The Provider may share such Personal Data of the User as necessary for the purpose of insurance claims.

4.2. The Provider may share/disclose the User’s Personal Data: pursuant to an order of the government and/or a judicial authority, pursuant to any requirement under applicable law, for the purpose of protecting the rights, property or safety of the Provider or any other person, to enforce this Policy and T&C, and respond to claims that any content/action of the User violates the rights of other persons.
4.3. The Provider may share the User’s Personal Data with its affiliates, group entities and successor’s in interest. The Provider may also share/transfer the User’s Personal Data with/to any other entity as part of sale of its business assets.
4.4. The Provider may share/disclose the User’s Personal Data with/to its employees and representatives (including lawyers and accountants) on a strictly need to know basis.
4.5. The Provider may copy, reproduce, distribute, broadcast, modify, adapt, translate, publish, transmit, publicly display and otherwise use: the User’s name, likeness, profile photo and user ID; the statistics of the User’s Use of the Game(s), including details of winnings/rewards, scores and gameplay history; any content posted, hosted, displayed, uploaded, published, transmitted, stored, shared by the User on the Platform and other data/information that may be generated as a result of the User’s Use of the Game(s) and the Platform; in any manner and in any form, without any time limitations and for any purpose, including for commercial or promotional use, and without payment of any compensation to the User or any further permission from the User.
4.6. Any content (including messages) posted by a User on any discussion, chat or publicly accessible forum may be available for viewing by other Users or any person with internet access.
4.7. The User’s Personal Data may be transferred out of India during the course of being shared with any person pursuant to this Clause 4.
4.8. Where the User’s Personal Data is shared with any person pursuant to this Clause 4, the Provider shall, on a best efforts basis, procure from such person that they shall keep the User’s Personal Data confidential and maintain similar standards in maintaining the security of the Personal Data as applicable to the Provider.

5. Updation Of Personal Data

The User may correct/change/modify/update its Personal Data from within the Platform or contact customer support for assistance in this regard.

6. Storage And Deletion Of Personal Data

6.1. The User’s Personal Data shall be continued to be collected, stored, used and disclosed in accordance with this Policy and the T&C till such time the User has a User Account.
6.2. On termination or closure of the User Account, the User’s Personal Data shall be deleted except that:

(a) Details of transactions carried out in the User Account, including KYC verification details, withdrawal beneficiary details and prize details, may be retained.
(b) The User’s Personal Data may be retained to the extent and for such period as required under applicable law or pursuant to any direction of any governmental or judicial authority.
(c) The User’s Personal Data may be retained for the purpose of establishment, exercise or defense of any legal claim.

7. Use Of Cookies

To improve the effectiveness and usability of the Platform for the Users, the Provider uses “cookies”, or such similar electronic tools to collect information to assign each visitor a unique random number as a user identification to understand the User’s individual interests using the identified device. Unless the User voluntarily identifies themself (e.g., through registration), the Provider has no way of knowing who the User is, even if it assigns a cookie to the User’s device. The only information a cookie can contain is information supplied by the User. A cookie cannot read data off the User’s device hard drive. The Provider’s advertisers may also assign their own cookies to the User's device (if the User clicks on their ad banners), a process that the Provider does not control.

8. Security Procedures

All information gathered on the Platform is securely stored within a controlled database. The database is stored on servers secured behind a firewall; access to such servers being password-protected and strictly limited based on need-to-know basis. However, please note that as effective as the Provider’s security measures are, no security system is impenetrable. Thus, the Provider cannot guarantee the security of its database, nor can it guarantee that User’s Personal Data will not be intercepted while being transmitted between the User and the Provider over the internet or any other network.

9. Limitation Of Liability

The Provider, its officers, employees, directors, representatives, affiliates and partners, shall not be liable for any direct, indirect, incidental, consequential, special, exemplary, punitive, monetary or any other damages, fees, fines, penalties or liabilities whatsoever arising out of or relating to the collection, storage, use, disclosure and protection of the Users’ Personal Data. In no event shall the Provider be liable for any damages in excess of INR 500 (five hundred).

10. Amendment

10.1. This Policy supersedes any prior agreement between the User and the Provider.
10.2. The Provider may amend/revise this Policy at any time without giving prior notice. To continue Using the Game(s) and the Platform, the User shall be required to accept the amended Policy.

11. Customer Support

11.1. For support in any aspect relating to their Personal Data and this Policy, the User may write to support@indibid.in or use the in-Platform customer support feature.
11.2. While raising an issue for customer support, the User should include a detailed description of the issue along with necessary information to identify and contact the User.
11.3. The Provider shall respond to any request for customer support within a period of 48 (forty-eight) hours and endeavour to resolve the issue within 15 (fifteen) working days.

12. Grievance Redressal

12.1. The User may also contact the Grievance Officer of the Provider to address any concerns regarding their Personal Data and breach of this Policy. The User may contact the Grievance Officer at the following coordinates:

Name: Romil Mehta

Address: 15^Th Floor, Villa Orbit, Bomanji Darabsha Road, August Kranti Marg Mumbai-400036

Office Hours: 10 am to 6 pm Monday to Friday

Email: support@indibid.in
12.2. The Grievance Officer identified above is pursuant to the provisions of applicable laws, including but not limited to the Information Technology Act, 2000 and the Consumer Protection Act, 2019, and the rules enacted under those laws.
12.3. The Grievance Officer shall respond to any complaints received within a period of 48 (forty-eight) hours and resolve the complaint within 15 (fifteen) working days.

13. Governing Law and Jurisdiction

13.1. This Policy shall be governed by the Laws of India.
13.2. The Courts at Mumbai shall have exclusive jurisdiction to adjudicate any dispute arising out of or in connection with this Policy.

14. Miscellaneous

14.1. If any provision of this Policy is found to be legally unlawful, void or for any reason unenforceable, then that provision shall be deemed severable from this Policy and shall not affect the validity and enforceability of any remaining provisions.
14.2. These Policy governs the Provider’s relationship with the User (and vice versa). It does not create any rights for anyone else unless explicitly stated otherwise in this Policy.
14.3. The Game(s) and the Platforms may contain third-party advertisements and links to websites/services owned and operated by the Provider’s affiliates and/ or third parties (“Third-Party Content”). Please note that the Provider does not endorse the Third-Party Content. The Provider does not guarantee the accuracy, reliability or quality of such Third-Party Content. The User’s reliance on Third Party Content is at their own risk. Any claims that a User may have regarding Third-Party Content should be directed to the third party in question. On accessing Third Party Content, the User will be governed by the terms of use, privacy policy and other policies of the concerned third-party. The information provided by the User is governed by the privacy policy of the provider of the Third-Party Content. That policy may differ from this Policy. The Provider is not responsible for the privacy practices in relation to Third-Party Content or the content itself.
14.4. The User hereby consents to receiving news, updates, offers/campaign related messages, including through SMS, email and social media websites.
14.5. The Provider reserves the right to monitor all activities from the User’s Account on the Platform. If any User Uses the Game(s) and/or the Platform in violation of any central and/or state law(s) in India, the Provider reserves the right to cooperate with law enforcement agencies of the relevant state and report such participation or/and suspicious activity along with all relevant details of the concerned User.