THIS DOCUMENT IS AN ELECTRONIC RECORD IN TERMS OF INFORMATION TECHNOLOGY ACT, 2000 AND RULES THEREUNDER, AS APPLICABLE AND THE AMENDED PROVISIONS PERTAINING TO ELECTRONIC RECORDS IN VARIOUS STATUTES AS AMENDED BY THE INFORMATION TECHNOLOGY ACT, 2000. THIS ELECTRONIC RECORD IS GENERATED BY A COMPUTER SYSTEM AND DOES NOT REQUIRE ANY PHYSICAL OR DIGITAL SIGNATURES.
THIS DOCUMENT IS PUBLISHED BY MIND SPORTS LEAGUE PRIVATE LIMITED (HEREINAFTER REFERRED TO AS “THE COMPANY”, “WE” OR “US”) IN ACCORDANCE WITH THE PROVISIONS OF RULE 3 (1) OF THE INFORMATION TECHNOLOGY (INTERMEDIARIES GUIDELINES AND DIGITAL MEDIA ETHICS CODE) RULES, 2021 THAT REQUIRE PUBLISHING THE RULES AND REGULATIONS, TERMS OF SERVICES, PRIVACY POLICY AND USER AGREEMENT FOR ACCESS AND USE OF THE MOBILE APPLICATION “HASHTAG POKER” (HEREINAFTER REFERRED TO AS THE “APP”).
YOUR USE OF THIS APP OR PROVISION OF ANY INFORMATION ON THE APP CONSTITUTES YOUR AGREEMENT TO THIS PRIVACY POLICY AS MAY BE AMENDED FROM TIME TO TIME; DO NOT USE THE APP OR PROVIDE INFORMATION IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY AS SPECIFIED HEREIN.
THIS PRIVACY POLICY IS A LEGALLY BINDING DOCUMENT BETWEEN YOU AND COMPANY AND GOVERNS YOUR RELATIONSHIP WITH THE COMPANY. THE TERMS OF THIS PRIVACY POLICY WILL BE EFFECTIVE UPON YOUR ACCESS AND USE OF THE APP. IF YOU DO NOT AGREE WITH ALL OF THE TERMS OR HAVE ANY OBJECTION TO GRANTING YOUR CONSENT AS STATED HEREINABOVE, KINDLY DO NOT DOWNLOAD, INSTALL OR USE THE APP.
Privacy Notice
This privacy policy is aimed and intended to provide the users of the App and registered members with information in relation to the online practices pursued by the Company especially with respect to the personal information provided by the users/registered members on the App.
Hashtag Poker App
This App is a unique platform which is aimed at providing its users with the content to explore the game of skill based poker gaming under its unique and proprietary “Learn Watch and Play” TM model. This App enables its users to access content on poker games, information on news and events related to poker gaming activities and tournaments including “Poker Sports League”, a league which is owned and operated by the Company, provide training and access to content to enable users interested in learning skill based poker gaming as well as provide users with the gaming experience.
Please note that all games supported and hosted by the App are free and for entertainment and learning purposes only. This App does not provide any real money gaming services i.e. the App does not enable users to play with real money or undertake gambling or betting activities with the use of real money.
Information that we collect about you
General
We may collect personal and non-personal information about the user on the App. Such information and data may be collected on the basis of the information that you provide to the App or is collected using cookies and similar technologies as more particularly set out in this Privacy Policy. By accepting these Terms, you confirm that you have the capacity to enter into a legally binding contract under applicable law, including, in particular, the Indian Contract Act, 1872.
Personal Information
“Personal Information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Information but may not be considered as Personal Information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature on the App. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.
You have the right to request us to discontinue the collection or use of your Personal Information. However, please note that in case of such a request, we may be unable to provide certain services on the App.
Collection of Personal Information
When you provide the Personal Information
- At the time of signing up to access the App and registration, the Company shall require you to provide your name/surname, contact email-id, location, gender and Mobile number and other relevant details to enable you to register on the App and create an account and provide transaction updates. While creating your account, you will provide a username and password to enable you to access the App.
- The Company also and records videos at the time when you are accessing and using the video poker feature available on the App.
- In addition, if you are making in-app purchases on the App which requires you to make any payments on the App, we may, in addition, collect details of your payment, credit card, debit card, net banking details and other digital modes of payment which are available on the App. However, please note that this information is usually collected by the payment gateway operators and as such this information may not be provided by such operators to the Company and is maintained by such operators in a safe and secure manner.
- Please note that for accessing certain services such as access to “PSL Qualifiers”, the App may require you to provide additional information and may also collect information (location) through automated means to determine if you are eligible to access and use such services.
Collection of data through Automated Technologies
While the App does not generally collect information through automated means, however, please note that the (a) Transaction and historical usage data which refers to refers to your activity on the App, services which are accessed, pages visited etc. (b) Technical data such as internet protocol (IP) address, login data, browser type and version, location, time zone setting etc. and (c) marketing data including preferences on receiving direct communication etc. may be collected automatically when you visit or access certain services on the App.
Collection of data by third party advertisers
In addition, the App may provide or support certain third party advertisers who are permitted to promote and advertise their products and services on the App. Such third party advertisers may provide external links which when selected will direct you to a page outside the App. Please note that such third party advertisers may collect your personal information when you access such external links. The collection of such information by external links is governed by the privacy policy and terms of use of such third party advertisers and you are advised to read the same prior to accessing such links.
Use and disclosure of data collected on the App
Personal Information
- We will only use and disclose your Personal Information for activities which are permitted on the App and as per the terms of this Privacy Policy. Such activities shall include:
- Use of information for provision of transactional and other Services on the App and to improve the user experience while accessing services on the App.
- Use of information for communications, newsletters, and sharing of other value added data with the users. Such communication may include information about any products or services offered on the App, products or services offered by our partners and affiliates, usage related communication, information on service requests etc.
- We will further utilize the information for conducting data analytics, creating a database of information about the users, building and improving on models, assessing and analyzing information to improve the search and to understand usage patterns and customer preferences.
- We may further use the data for improvement of our product and offerings so that we may improve the product for our users.
- Generally, we do not disclose any Personal Information or sell, rent, lease, license the use of any Personal Information which is collected on the App. However, we may disclose information to
- Agents or sub-contractors who provide services to the Company. These may include (A) Data analytics services (B) Customer support services (C) Marketing and advertising services which may be outsourced to third parties. These agents and contractors are only allowed to use the information shared with them for the specific tasks we have requested them to do and consistent with this Privacy Policy, and for no other purposes. The Company takes steps to ensure that all service providers with access to Personal Information are capable of protecting the information we share with them.
- Legal Disclosures: We may disclose your Personal Data as required or permitted by law and/or to comply with a judicial proceeding, court order, or legal process. We take suitable actions to limit the extent of such disclosure to only comply with any specific legal requirements.
- Business Transfers: In the event of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, we may disclose or otherwise transfer information about our users, including Personal Data, to an acquirer, successor, or assignee.
- We may partner with other companies or organisations to provide you with additional services. When you purchase or otherwise express interest in a service offered by a third party through the Company or sponsored on the App, you consent to our sharing your information with those parties. Participation in rewards programs, discount offers, contests, or other programs that involve third parties, authorizes the Company to share your personal information with those parties. A third party’s use of your information is bound by contracts and agreements between the Company and the third party. We only share information reasonably needed to provide additional services, and such shared information may be bound by other privacy agreements. By sharing this information, you agree that the Company is not liable or responsible for the actions or inactions of third parties.
- Available log records and all data stored on our servers may be accessed by our system administrators.
Non-Personal Information or Aggregated Information
- As stated above, Non-Personal Information and Aggregated Information is collected and prepared after removing any personal identifiers which may directly or indirectly associate with the user.
- Such Non-Personal Information or Aggregated Information may be utilized for assessing and analyzing the efficacy of the services offered on the App, creation of new content, products or services, whether or not connected with the services offered on the App and for general business or marketing purposes.
- We may share aggregated, automatically-collected or otherwise non-personal information with third parties. We may utilize, share and disclose such Non-Personal Information / Aggregated Data for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users’ interests, habits and usage patterns for certain programs, content, services, advertisements, promotions and/or functionality available through the App.
- However, we ensure that while disclosing such Non-Personal Information, any personal identifiers are removed or encrypted using appropriate technical practices and technology to prevent an identification of the person whose information is being used.
Security
The Company has placed reasonable technical, organizational, administrative and physical controls to prevent unauthorized or unlawful access to or accidental loss of or destruction or damage to your information. Such security practices include defining roles and responsibilities of Company’s personnel who are accessing the backend of the App. We also ensure that our security practices are updated at regular intervals to maintain compliance with applicable laws.
You are responsible for maintaining the confidentiality of your account and password and for restricting access to your devices, and you agree to accept responsibility for all activities that occur under your account or password.
Further, the Company will not be responsible for any third party access to your information on the App which is provided by you if such access has been obtained inspite of Company implementing and maintaining reasonable security practices.
Disclaimers and Limitation of Liability
Without prejudice to anything stated herein and in addition to the disclaimers provided elsewhere in this policy, the users/members by accessing the App and/or registering as a user on the App specifically acknowledge and understand that whilst the Company shall make all reasonable endeavors to protect and secure the confidentiality of the information provided by the users/members, the Company shall not be liable in the following circumstances (please note that this is not an exhaustive list and the specification of any instances hereinbelow shall be in addition to other defenses which may be applicable to the Company under applicable laws):
- Credit Fraud or other criminal offences committed by any third party with the use of credit cards/debit card etc. or other bank details provided by the members/users which fraud or offence has been committed in spite of the reasonable security measures adopted by the Company as part of its App infrastructure or where such fraud or criminal offence is committed owing to negligence, acquiescence or connivance or assistance, whether voluntary or involuntary of the user/member. The Company shall operate and maintain the App in accordance with the rules set by its payment processor.
- Unauthorised Use (i.e. use, reproduction, distribution, disposition, or any other activity, including, without limitation, decompilation, reverse engineering, modification or disassembly etc. without the authorisation from the Company) or Unauthorised access (access, or to attempt to access, or to penetrate, or attempt to penetrate by any third party’s computer software or electronic communications system, including, without limitation, hacking, introduction of any virus, malware, spyware, trojans, any intrusion resulting in the corruption or loss of data etc.) of the App by a user/member or by any third party which may cause any loss or damage to the user/member or the third party where such unauthorized use or access could not be prevented despite reasonable safety precautions undertaken by the Company.
Log Files
Like most standard software application servers, we use log files. This includes IP (internet protocol) addresses, browser type, ISP (internet service provider), referring / exit pages, App type, date / time stamp and number of clicks to analyze trends, administer the App, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. The same may be used to track the behavior of the customers or identify the area of interest of the customer, which might further be useful for advertisement, promotions etc.
Cookies, Location Trackers, IP Address Trackers (and related technology)
The App uses cookies, location trackers, IP trackers and other automated technology when you download, install and access services on the App.
Posting
Posting or updating content is a public action undertaken by users who are subject to the Terms of Use as set out on the Site. For the avoidance of doubt, identification of all contributed content may include, but is not limited to, display of your name. All content may be retained for restorative, archival, or research purposes by the Site. Editing or deleting content may alter the displayed state of the content but will not permanently delete the content from the Site.
Contact Us
The “Contact Us” feature available on the App may require you to provide information pertaining to the nature of issue or query which you may raise. While usually no personal information is required to enable the Company to provide support services, the Company may require you to provide certain personal information to enable the resolution of the queries. Such personal information, if provided, shall be used solely for resolution of the issues or queries raised and not otherwise.
Data Retention
We will only keep your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This means, for instance, that we will retain your Personal Information for as long as you use the App or services. Once you decide to terminate your use of the App, we will retain your information for 6 months or such shorter period as prescribed under applicable laws. Please note that if any content which is uploaded by you which is removed by the App on account of violation of user policy, such content is maintained by the Company in its archival systems for a period of 180 (one hundred and eighty) days post deletion.
Changes in this Privacy Policy
The Company reserves the right to change this policy from time to time, at its sole discretion. We may update this privacy policy to reflect changes to our information practices. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy on the home page, and other places we deem appropriate may also elect to send users notice of any changes via e-mail.
Contact
If you wish to contact us to provide any feedback or if you have any queries, you may contact us at info@hashtagpoker.com.
Please refer to the terms of use for information on grievance redressal mechanism
Last Updated on: 15 June 2021
