Safeguarding Your privacy is of utmost importance to Us and We are committed to protect Your privacy in all manner of ways in compliance with applicable laws on data privacy protection and data security. This Policy provides for the practices for the collection, possession, storage, handling and dealing of personal identifiable information/ data and sensitive personal data (hereinafter collectively referred to as “Personal Information”) of the User. This Policy 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 Policy applies to personal information and other information that is processed by Us in the course of You playing games available on the Platform, or accessing the blogs and other online offerings (together with any and all future online offerings) operated by or on behalf of Vir Bhumi (the “Services”). We also use third parties for various activities related to Our Services, including customer support, technical support, payment facilitators, data hosting and email fulfilment. Your use of the Platform and Services is also subject to the [Terms of Service available at [https://www.virbhumi.com/terms]] ("ToS”).

Vir Bhumi urges the User to read and understand this Policy and the ToS carefully for details on the way, We will protect the User’s privacy rights. By accessing Our Platform for availing Our Services by participating in the games on Our Platform, You consent to the collection, process, use, disclosure, store and transfer of Your Personal Information in accordance with this Policy and for the purposes stipulated herein.

1. OVERVIEW

   • Last updated on: 9th October, 2024
   • The User may contact Us through the Grievance Officer, details of whom is provided under Paragraph 16 below, in case of any questions, opinions or suggestions about the Policy or Personal Information protection, and We shall endeavor to revert to the User within 30 days, under normal circumstances.

2. TYPE OF PERSONAL INFORMATION COLLECTED

   In the course of the usage of the Platform, We shall collect Personal Information in the following manner:
   • While Registration on the Platform for creating an account for availing Services: Personal Information which the User provides while subscribing to or registering on the Platform for availing the Services, including but not limited to:
     • Personal Information about the User’s personal identity: The Username for creating your account with Us.
     • The User’s contact details: the User’s email address for communication and for registering on our portal for Services.
     • The User’s location to identify that You are located within India to use our Services.
     • The User’s bank account details and Permanent Account Number (PAN) or any other information or documents required to comply with Know Your Customer requirements as required in relation to the Services or under Applicable Laws.
     • The Users’ game preferences and activities and profile Information to improve the Services and provide You with relevant suggestions.
     • The Users’ account administration information (e.g. user name, password, or security questions).
     • Any other information collected through Cookies.
   • Automated Logging of Session Data
     We also gather and store following data of Users:
     • When Users log in to the Platform We gather data on (i) the type of mobile device that User use, (ii) User’s mobile device’s Unique ID, (iii) IP address of User’s mobile device, (iv) User’s mobile operating system , (v) the type of mobile internet browser User use, and (vi) unique device identifiers and other diagnostic data.
     Each time You use the Platform or play through other devices, We may automatically collect information about Your use of that device and app. If You sign into an account, We may combine it with other information We have for that account.
   • Collection of Data from Our Partners

     If You link a third-party tool with Our Service. (For example Facebook, Google etc), We may receive data/information provided by You to a third party tool, and We may collect personal data that is already associated with Your third-party social media service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account. You consent to such collection of such Personal Information by Virbhumi the same shall be used by Virbhumi in a manner consistent with this Privacy Policy.

     Please make sure that any personal details which You provide are accurate and current. We will send any important information relating to Your account to You, using the contact information You provide (including account security and privacy notices).

3. PURPOSE OF COLLECTION AND USAGE OF PERSONAL INFORMATION

   We use the Personal Information for the following purposes:
   • Providing Our Service: The collection Personal Information is important to facilitate the User to create account to allow User to play the games and use Services vide the Platform. The Personal Information is also used for other customer service purposes in relation to User accounts.
   • Verification: We use Personal Information for the verification of the User’s identity, eligibility, registration and to provide customized Services.
   • Verification and Confirmation of Payments: For facilitating the payments by the User on the Platform.
   • Disbursement of cash prizes: For crediting the prize money for cash prizes that Users win while playing the games on the App.
   • To keep Services safe: Access to chats and profile images helps to monitor the usage of Services by Users effectively and take action against the Users engaging in misconduct or fraud in order to ensure safety of all the Users.
   • Marketing and advertising: We use Personal Information to provide Users with special offers, and promotions, including via email; and for other marketing, advertising, and promotional purposes, including general updates about Us and Our Services and new offerings. These communications will be sent in accordance with the User’s communications preferences.
   • Lead Generation: For generating business enquires and trade leads.
   • Improving the Services: To analyze User’s choices, browsing pattern including the frequency of visits and duration for which a User is logged on, to diagnose problems with the Our servers, for improving Our systems and Platform and Services.
   • Quality Control: Correspondence between Users and the representatives of the Platform (including the additional information, if any) in relation to the Services is collected and stored for quality control or training purposes.
   • Advertising: Provide the User with advertisement based on the User’s activity and interests, both on Our own Platform and applications and on third-party sites and applications.
   • New services: We shall approach the User for the User’s consent for any other specific purpose not listed in this Policy.
   • Comply with legal obligations: To meet Our legal obligations under the applicable laws.
   • Legitimate Interests: To fulfil Our legitimate interests, or those of a third party in conducting and managing Our business and Our relationship with You as described in this Policy.
   • Security: In order to help protect You and other Users from fraudulent activities and transactions and to protect Your game account from unauthorized access ( for example an unauthorized attempt to log in from a different location)
   Please get in touch with the Grievance Officer (as provided under Paragraph 1 above) in case the User would like to object to any purpose of processing the User’s Personal Information. However, please note that if the User object or withdraw consent to process data as above, We may, either partly or fully, discontinue providing the User with Services through the Platform.

4. USE OF COOKIES AND SIMILAR TECHNOLOGIES

   • We use Cookies to personalize the User’s experience on the Platform and the advertisements that may be displayed.
   • Cookies are small pieces of information that are stored by the User’s browser on the User’s device’s hard drive. Cookies allow Us to serve the User better and more efficiently (“Cookies”).
   • Type of Cookies We Use
     • Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
     • We use both session and persistent Cookies for the purposes set out below:

       • Necessary / Essential Cookies

         Type: Session Cookies

         Administered by: Us

         Purpose: These Cookies are essential to provide You with Services available through the Platform and to enable You to use some of its features. They help to authenticate Users and prevent fraudulent use of User accounts. Without these Cookies, the Services that You have asked for cannot be provided, and We only use these Cookies to provide You with those Services.

       • Cookies Policy / Notice Acceptance Cookies

         Type: Persistent Cookies

         Administered by: Us

         Purpose: These Cookies identify if Users have accepted the use of Cookies on the Platform.

       • Functionality Cookies

         Type: Persistent Cookies

         Administered by: Us

         Purpose: These Cookies allow us to remember choices You make when You use the Platform, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Platform.

       • Tracking and Performance Cookies

         Type: Persistent Cookies

         Administered by: Third-Parties

         Purpose: These Cookies are used to track information about traffic to the Platform and how Users use the Platform. The information gathered via these Cookies may directly or indirectly identify You as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device You use to access the Platform. We may also use these Cookies to test new advertisements, pages, features, or new functionality of the Platform to see how our Users react to them.

   • If You prefer to avoid the use of Cookies on the Platform, first You must disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this Platform. You may use this option for preventing the use of Cookies at any time.
   • The User can control how and whether Cookies will be accepted by the User’s browser, however, blocking Our Cookies may disable certain features on the Platform, and may hinder an otherwise seamless experience to purchase or use certain Services available on the Platform.

5. WHERE PERSONAL INFORMATION IS HELD

   The Personal Information that We collect in respect of the User is hosted within India.

6. TRANSFER AND DISCLOSURE OF PERSONAL INFORMATION

   The User’s Personal Information may be shared by Us, in the following manner:
   • To affiliated companies and entities, within India or outside India, for better efficiency, more relevancy, innovative business matchmaking and better personalised services, provided such entities provide similar or greater level of protection as We provide.
   • If required by law, legal process, litigation, and/or requests from governmental or regulatory authorities, or for the purpose of national security, law enforcement, or other issues of public importance, including cyber incidents, prosecution and punishment of offences, to disclose the User’s Personal Information.
   • We may share the User’s Personal Information with (i) all Our affiliates in relation to performance of Services, and (ii) with any other third party that We may engage to perform certain tasks on its behalf, including but not limited to conducting market research/ surveys, data hosting, data processing platforms and payment facilitation.
   • We may use Personal Information of Users in aggregate or anonymized form to: (a) build higher quality, more useful online Services by performing statistical analysis of the collective characteristics and behavior of Our customers and visitors including Users, and by measuring demographics and interests regarding specific areas of the Platform; (b) to provide anonymous statistical information based on this data to suppliers, advertisers, affiliates and other current and potential business partners; (c) to inform these third parties as to the number of people who have seen and clicked on links to their Platforms.
   • Additionally, We may disclose User's Personal Information, if required to do so, (a) for rendering Services or for attaining the purpose under Paragraph 3 above; (b) to the facilitators as required, for providing the Service; (c) for regulatory, internal compliance and audit exercise(s); (d) to secure Our systems; or (e) to enforce or protect Our rights or properties or any or all of its affiliates, associates, employees, directors or officers or when We have a reason to believe that disclosing Personal Information of User(s) is necessary to identify, contact or bring legal action against someone who may be causing interference with Our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
   • Please take note that whenever a User post Personal Information online, the same becomes accessible to the public and the Users may receive messages/ emails from visitors of the site.
   • In connection with a sale, divesture, or transfer of Virbhumi (including any shares) or any combination of its products, Services, assets, affiliates, and/or businesses. The User’s Personal Information may be among the items sold or otherwise acquired in these types of transactions. We may also sell, assign or otherwise transfer such Personal Information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings.
   • Once a User gets registered with Us, the User is no longer anonymous to Us and thus all the Personal Information provided by the User shall be stored, possessed in order to provide the User with the requested Services and as may be required for compliance with statutory requirements in India.

7. GLOBAL TRANSFER OF PERSONAL INFORMATION

   We may transfer the User’s Personal Information outside India, where it is collected, in any case it will only be transferred to a country that offers the same or greater level of protection for Personal Information than India.

8. PROTECTION OF PERSONAL INFORMATION

   • Security Safeguards and Procedure

     • We value the security of the User’s Personal Information and hence We have implemented technical and organizational security measures that are designed to help protect the User’s Personal Information from unauthorized access, disclosure, use and modification. From time-to-time, the We review Our security procedures to consider appropriate new technologies and methods.
     • Please be aware, however, that no data security measures can guarantee 100% security.
     • If We learn of a security breach, We may (a) attempt to notify the User electronically so that the User can take appropriate protective steps; or (b) post a notice on the Platform, or (c) take suo-motto steps to rectify the breach without any notice to the User. If the User have any questions about the security of the User’s Personal Information, please contact the Grievance Officer.

   • Record Retention

     • We shall retain the User’s Personal Information only for as long as is necessary, and after such reasonable time, it is destroyed appropriately and securely or anonymized in accordance with the law.
     • We shall retain the User’s Personal Information (other than in anonymized form) for: (i) as long as User’s account is active and We have a continued relationship with the User; (ii) as long as needed in order to comply Our legal and contractual obligations; (iii) as long as needed to provide Services to the User and shall be subject to periodic update or deletion of unnecessary data.

9. THE USER’S RIGHTS

   • The User has the following rights pertaining to the User’s Personal Information
     • Right to know what Personal Information We hold about a User and, in some cases, to have the information communicated to the User;
     • Right to request that the User’s Personal Information held by Us be corrected, rectified or deleted;
     • Right to object to the processing of the User’s Personal Information or to request restriction thereof;
     • Right to opt out of targeted advertisements;
     • Right to withdraw the User’s consent to submit any or all Personal Information or decline to provide any permissions on its Platform as covered above at any time.
   • Any request from the User to update, delete or correct the Personal Information, or to withdraw consent regarding sharing and use of Personal Information should be shared with the Grievance Officer. For more details, click here
   • In case, the User chooses to object processing of the User’s Personal Information, withdraw consent in regard to the User’s Personal Information or delete the Personal Information shared, then the User’s access to the Platform may be limited, or We might not be able to provide the Services to the User.
   • We will evaluate any request for deletion of Personal Information on a case-to-case basis and take the requisite action as per applicable law. In this regard, please note that information sought to be deleted may remain with Us in archival records for the purpose of compliance of statutory enactments, or for any other lawful purpose. Therefore, Users are requested to carefully evaluate what types of information they would like to provide to Us at the time of registration.

10. OTHER PLATFORMS

    We may through the Our Platform, provide links to third-party Platforms. We do not make any representations or warranties with respect to such third-party Platforms. Further, We are not responsible for the practices employed by such Platforms, applications, or services linked to or from the Services or Platform, including the information or content contained there. Such third-party gaming Platforms and services are subject to that third party’s own rules, policies, and practices, and not this Policy.

11. AGE LIMITS

    We do not knowingly collect or process personal data of children below age of 18 years without obtaining verifiable parental consent to process the personal data.

    Accounts for children between the age of 18 years old, must be created by Your parent or legal guardian. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Information, please contact Us. If We become aware that We have collected Personal Information from anyone under the age of 18 without verification of parental consent, We will take steps to remove that information from Our servers.

12. RIGHTS TO PERSONAL INFORMATION

    • Save and except the rights provided herein in this Policy, all rights to the Personal Information shall belong to the User.
    • Any Personal Information which We collect and which We may use in an aggregated format is Our property. We may use it, in Our sole discretion and without any compensation to the User, for any legitimate purpose including without limitation the commercial sale thereof to third parties.
    • You are responsible for any content You share on forums, communities, chat and messaging features. This content will be accessible to other Users who can then share that information further. We recommend You consider carefully what You share and with whom You share such information.

13. UPDATE OF POLICY

    • This Policy is current as of the last updated date set forth above.
    • We may periodically change this Policy to keep pace with new technologies, industry practices, and regulatory requirements, among other reasons. While, We expect most such changes to be minor, We request the Users periodically to review the changes.

14. OPTING OUT FROM PROMOTIONAL EMAILS

    • We may send periodic promotional or informational emails to Users in accordance with their communications preferences. At any time, Users may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to thirty (30) business days for Us to process opt-out requests.
    • Please note that, even after the User opts out from receiving marketing messages from Us, the User may continue to receive transactional and product-related messages.

15. GOVERNING LAW

    The terms of this Policy shall be governed by and construed in accordance with the laws of India. The User and Virbhumi agrees that they are bound by the laws of India for the purposes of this Policy and the Services. The User agree that We shall not be required to follow laws of any other jurisdiction, whether or not such User belongs to a different jurisdiction other than India.

16. GRIEVANCE REDRESSAL MECHANISM

    • Any complaints with regards to use, processing or disclosure of Personal Information provided by the User or breach of the terms of this Policy may be taken up with the Grievance Officer. The details of the Grievance Officer are as follows:

      Grievance Officer: Ravi Ram Jonnalagadda

      Email: grievance@virbhumi.com

      Address: Desk No.HD-103,1st floor,, CTS No. 95, 4 B 3 & 4 590, Oberoi Commerz Two, Oberoi Garden CitY, Off W. E. Highway, Goregaon East, Mumbai, Mumbai Suburban, Maharashtra, 400063

    • The Grievance Officer shall acknowledge the complaint within twenty-four hours and dispose off such complaint within a period of fifteen days from the date of its receipt.