PRIVACY POLICY Wolf Win Game
PRIVACY
POLICY
1. GENERAL
1.1. We,
Dwija LLC, an entity registered under the laws of New Jersey, United
States, with registered office located at 241 Forest Ave, Paramus, NJ 07652,
United States (hereinafter referred to as the “Company”, “We”, “Us”
or “Our”) grant importance to the confidentiality and security of the
information We collect from Our Users (as defined hereinafter) and are
committed to protecting Your privacy.
1.2. This
privacy policy (“Privacy Policy”) read with the applicable terms and
conditions and other policies published and available at Our mobile application
under the name and style of “WolfWin: Skill Game Online” available at Google
Play Store and Apple AppStore (hereinafter referred to as the “Platform”) and further read with any other applicable agreements or
contracts between You (as defined herein below) and the Company and its
technical processors shall apply to all information as may be collected by Us
through Our Platform from persons who are using or accessing the
Platform and/or availing the Services (as defined hereinbelow) in any manner (hereinafter
referred to as “User”, “You” or “Your”,). ‘
1.3. This
Privacy Policy is an electronic record, in the form of an electronic contract,
under the Indian Information Technology Act, 2000 and the rules made thereunder
and the amended provisions pertaining to electronic documents/records in
various statutes as amended by the Information Technology Act, 2000. This
Privacy Policy does not require any physical, electronic, or digital signature
and is a legally binding document between the User and Us. This document is
published in accordance with the relevant provisions of the Information
Technology Act, 2000 and the Information Technology (Intermediary Guidelines
and Digital Media Ethics Code) Rules, 2021 and the Information Technology
(Reasonable Security Practices & Procedures & Sensitive Personal Data
or Information) Rules, 2011 (“SPDI Rules”) issued thereunder, which
mandate an intermediary, such as the Company, to publish a privacy policy for
collection, use, storage, transfer/ disclosure of Personal Information
including Sensitive Personal Information (as defined herein below) among other
rules and regulations and agreements for Users. We reserve the right to change,
modify, add, or delete portions of the terms of this Privacy Policy, at Our
sole discretion, at any time, in the manner provided herein.
1.4. This
Privacy Policy governs and sets forth
the understanding in relation to the collection, usage, processing, storage, and disclosure of the information
that We may collect, and You may provide to Us in connection with Your use or
access of any the services, functionalities, features, content, or
facilities available on the Platform (collectively “Services”). You
acknowledge that this Privacy Policy as well as other applicable terms and
conditions of use and such other policies as may be framed by Us from time to
time and published on the Platform mentioned above, together with any other
applicable agreements or contracts between the You and Us will comprise Our
collective agreement (“Agreement”) with You in relation to any
Information Collected (as defined hereinbelow) by Us.
1.5. The
purpose of this Privacy Policy is to inform You about Our collection, usage,
processing, storage, security, and disclosure of the Information Collected,
which may consist of Personal Information (as defined herein below) of the nature
detailed herein, from Users. It is reiterated that this Privacy Policy will
apply to all Personal Information, including Sensitive Personal Information that
is collected and processed by Us from You for the purpose of, in the course of,
or as a result of Your use or access of the Services and the Platform.
1.6. The
use of the term “Personal Information” in this Privacy Policy refers to “personal
information” as statutorily defined under the SPDI Rules read with the
Information Technology Act, 2000 and includes any information through which You
are capable of being identified, whether directly or indirectly in combination
with other information of Yours as may be available or likely to be available
with Us (“Personal Information”). Any reference to Personal Information,
for the purpose of this Privacy Policy, does not include any anonymized
information that has been appropriately processed or anonymized in a way so as
to make it non-identifiable, in order to irreversibly prevent its
identification.
1.7. For
the purpose of this Privacy Policy, reference to “User” will mean any
person(s) who uses, accesses, or avails the Platform and the Services in any
manner (including representatives, legal heirs, executors, administrators,
permitted assigns and successors in interest of the relevant User as may be
applicable) and will include any other person(s) jointly participating in such
use. Further, for the purpose of this Privacy Policy, We refer to any
individual, group of individuals defined under law with whom We have a
contractual relationship, including merchants, advertisers, deal partners,
brands, businesses etc. as “Business Partners”; to any individual, group
of individuals defined under law whose services are used by Us in order to
provide certain Services to You through Our Platform (such as third party
payment processing provider and other vendors and service providers) as “Service
Providers” and to Our associate, subsidiary, affiliate and/or group
companies as “Entities”.
1.8. We
collect and process the Information Collected from You in the manner provided
herein, in written or electronic form, directly and indirectly, in accordance with
this Privacy Policy in the course of or as a result of Your use of the Platform
and the Services, including: when You sign-up on the Platform for the Services,
through electronic communication with You (such as via e-mail), and when You
browse, use, or access the Platform and/or avail any Services offered through
the Platform. You acknowledge and accept that certain Personal Information about
You may be automatically tracked during Your navigation on the Platform.
1.9. You
acknowledge and accept that We may advertise certain products and services on
the Platform which may be facilitated or offered by third-party vendors and hosted
or made available on third-party websites or applications. Our Platform may
contain links to such third-party websites or applications. The User agrees and
understands that such third-party website(s) and application(s) are not under
Our control and are subject to independent terms and policies of third parties.
Once the User leaves Our servers, use of any information provided by the User
will be governed by the terms of use and privacy policy of the operator of
these website(s) and application(s). Hence, if You access these links or
advertisements and submit Your information in connection with and/or for the
purpose of these third-party products and services, You understand, acknowledge
and accept that Your information may be collected by third party vendors and
service providers (offering such products or services) and the information
submitted by You or collected from You may be processed be subject to the relevant
terms and conditions and policies as may be maintained by relevant third-party
vendors or service providers on applicable third-party platforms. We do not
operate or control any activities on third-party websites or applications, or the
products or services offered by any third parties, and We request that You
review the privacy policy and terms of use on any such third-party websites, and
of any third parties, before accessing and/or submitting Your information on
such third-party websites, or to such third parties, in any way.
1.10. We
collect and process Your Personal Information for and in connection with the
purposes described herein subject to Your consent accordance with the Privacy
Policy and the applicable laws in the United States.
Any Information Collected is used only for and in connection with Your use of
the Platform and any Services and strictly in line with Our business purposes,
including for providing You with useful features and functionalities on the
Platform, enhancement of the operation of the Platform and allowing use of all
the listed features, and for responding to Your requests/queries in an
efficient manner in the manner detailed herein.
1.11. By
registering on or otherwise visiting, browsing, accessing, availing or using
Our Platform and/or Services in any manner and/or providing Us with the
Information Collected, You acknowledge and accept the practices and policies
outlined in this Privacy Policy, and hereby consent to Our collection, use and
disclosure of Your Information Collected in accordance with this Privacy
Policy. If You are not agreeable to this, You may not provide Us with the
Information Collected and refrain from using this Platform and/or Services provided
by Us. By using the Platform and/or Services provided
by Us, consenting to provide Us with and providing Us with any of the
Information Collected as We may request in connection with the purposes
mentioned herein, You acknowledge that You accept the practices and policies
outlined in this Privacy Policy and that these are
applicable and binding to You as a User of the Platform.
1.12. You
acknowledge and accept that You are lawfully authorized to provide Your
information to Us and have the legal capacity to do so and to give Your legal
consent for the collection and processing of such information by Us in the
manner provided in this Privacy Policy. You hereby consent to Our collection
and processing of Your Information Collected (including Your Personal
Information and Sensitive Personal Information) in the manner described in this
Privacy Policy. If You are an US resident who has not attained the age of eighteen
years (under applicable laws in the jurisdiction You reside in and/or are
accessing the Platform from), You may only use the Platform and/or the Services
subject to the grant of consent from Your parent or legal guardian. We do not
knowingly seek any Personal Information (including Sensitive Personal
Information) from a person who has not attained the age of legal majority
(under applicable laws in US and any other jurisdiction the person resides in
and/or is accessing the Platform from). If You are a parent or guardian and You
are aware that a minor in Your care has provided us with such information
without Your knowledge and consent, please contact Our Grievance Officer in the
manner provided in this Privacy Policy. If We become aware that We may have
collected Personal Information (including Sensitive Personal Information) from any
minors, We will take all reasonable and commercially appropriate steps to
remove that information from Our servers and/or to deactivate the relevant User
account associated with such persons as soon as reasonably practicable.
1.13. You
acknowledge and accept that the collection and processing of Your Information
Collected in accordance with this Privacy Policy shall not cause any loss or
wrongful gain to You or to any other person. You acknowledge that anything
done, caused to be done, whether expressly or impliedly in contravention of
this Privacy Policy may render You liable for legal action. We shall not be held liable in any manner whatsoever if
there is any error or deficiency by Us in Our business transaction with You due
to any information You provide Us which is false or incorrect or provided in a
manner contrary to this Privacy Policy or due to any withdrawal of Your
consent. You acknowledge and agree to indemnify and hold Us (and Our employees,
consultants, directors, representatives, and affiliates) harmless from any
complaints, legal proceedings or claims filed or initiated by any third party
against Us due to any breach by You of the terms of this Privacy Policy through
any act or omission attributable to You.
2.
PROCESSING OF INFORMATION
2.1.
You
acknowledge and accept that any Information Collected (including Personal
Information and Sensitive Personal Information as mentioned herein) shall be
primarily processed in the United States by the Company subject to data
protection regulations and applicable laws in the United Staes. However, We may
store, collect, process and use Your data in countries other than the United
States in compliance with applicable laws of such jurisdictions and We may
enter into agreements with third parties, including Our Entities (in or outside
of the United States), to store or process Your information or data for this
purpose. You further acknowledge and accept that such third parties may have
their own security standards to safeguard Your information or data. We will on
commercial reasonable basis require from such third parties to adopt reasonable
security standards to safeguard Your information/data in accordance with this
Privacy Policy equivalent to the security standards maintained by Us. Your
Personal Information (including Sensitive Personal Information) shall not be
shared with or disclosed to any third parties by the Company except in the
manner provided in this Privacy Policy. By agreeing to this Privacy Policy, You
acknowledge and accept that You are providing the Company with Your explicit
consent to collect and process Your Information Collected in the manner and for
the purpose(s) defined in this Privacy Policy.
2.2.
We collect and process
Your Personal Information in the manner provided in this Privacy Policy in
accordance with applicable laws where this: (i) is necessary for and in
connection with the purposes mentioned in this Privacy Policy (ii) is necessary
for the performance of a contract for which Company and User are parties, (iii)
is information which You have given Us consent to collect and process, or (iv)
is necessary for compliance with a legal obligation to which We are subject.
2.3.
In
case You have any concerns in the processing of Your Personal Information,
please reach out to Our Grievance Officer in the manner provided in this
Privacy Policy.
3.
INFORMATION COLLECTED
3.1.
You acknowledge and
accept that the Company may collect Your information (including Your Personal
Information and Sensitive Personal Information as listed below) of the nature
mentioned herein from You for and in connection with the purposes mentioned
herein in the course of, or as a result of, providing Services to You through
the Platform and through Your use of the Platform (collectively “Information
Collected”). Subject to clause 1.8 herein above, We may collect the
Information Collected in the following ways: as information submitted or
supplied to Us by Users on the Platform; as information automatically tracked
by Us during Users navigation on the Platform; and/or as communicated to Us via
e-mail or other electronic mode in the manner provided in this Privacy Policy.
Further, We may combine and process the Information Collected along with any other
information about You, which is available to Us in the public domain or which
You have otherwise provided to Us.
3.2.
We may collect Personal Information
such as Your name, username, e-mail address and other details associated with
Your User profile when You sign-up on the Platform for the Services. We may
collect certain Personal Information linked to the e-mail account used by You
to sign-up for Services on Our Platform, principally, the username and profile
details provided by You at the time of sign-up.
3.3.
We may collect Personal
Information and non-personal information about You including details of Your IP
address, mobile device and any other statistical and technical and other
information that may be required or be related to rendering the Services in an
efficient and timely manner or to verify Your account with Us. Certain information
and technical data about Your hardware devices and geographic location may be
automatically collected when You access or register on the Platform. We may
also collect information about Your activity on the Platform, such as
information about Your account usage, as well as information about how You interact
with the Platform and Your preferences.
3.4.
We collect communications
between You and the Company, and any related information. If You
communicate with Us through electronic means in the manner described in this
Privacy Policy, (such as via e-mail), You accept that any information,
including Personal Information, provided in such communication, such as Your
contact details, may be collected by Us.
3.5.
The
Personal Information We collect from You may include (as may be applicable)
“sensitive personal data or information” as defined under the SPDI Rules,
principally, the details of Your password for Your account with Us and other
details as the User may communicate or submit to Us. As defined under SPDI
Rules, and for the purpose of this Privacy Policy, reference to “sensitive
personal data or information” (“Sensitive Personal Information”) herein
shall mean Personal Information relating to: passwords; financial information
such as bank accounts, credit and debit card details or other payment
instrument details; physical, physiological and mental health condition; sexual
orientation; medical records and history; biometric information; information
received by Us under lawful contract or otherwise. It is clarified that if any such
information about You is freely available in the public domain, it shall not
comprise Sensitive Personal Information for the purpose of this Privacy Policy.
3.6.
We
collect the Personal Information (including Sensitive Personal Information)
that You choose to share with Us in the course of or for and in connection with
the purposes mentioned herein including any other details about Yourself which
You provide to the Company. By choosing to provide such information You consent
to Our processing of that information in the manner mentioned in this Privacy
Policy. We may also collect certain Personal Information from observing Your
performance, Your actions and/or Your feedback in relation to the Platform
and/or the Services.
3.7.
All
the above Information Collected is stored or used by Us only for the purposes
mentioned herein. We use the Information Collected for the Platform and
Services in the manner mentioned in the Privacy Policy. Except for the lawful
disclosures mentioned to be made by Us in the Privacy Policy, We do not
disclose or share Your Personal Information including Sensitive
Personal Information with any third-parties.
3.8.
Other
than as provided in this Privacy Policy, We do not collect or process any Personal
Information including Sensitive Personal Information of Users, including any of
Your financial or payment related details. All payments made or received by You
in connection with the Services offered on the Platform are processed and
facilitated by the relevant third-party payment processor(s), the names of
which We mention on the Platform, which We have engaged as Our Service Provider(s)
for this purpose (“Payment Service Provider(s)”). Users
to note that the relevant Payment Service Provider engaged by Us may collect Your Personal Information including
any Sensitive Personal Information User may submit in connection with payment
purposes as and when the User opts to makes or collect any payment in
connection with the Services subject to the independent terms of use and
privacy policy maintained by the Payment Service Provider.
4.
TRANSFER AND DISCLOSURE
OF INFORMATION
You acknowledge and accept the following:
4.1.
The
Company only collects, uses, and processes Your Personal Information
(including Sensitive Personal Information) for the purposes mentioned
herein or otherwise as part of Our Agreement with You. The Company does not
disclose or transfer Your Personal Information to other third parties without
Your consent. The Company may disclose or transfer Your Personal Information
(including Sensitive Personal Information) to third parties only in the manner
and for the purposes mentioned hereinbelow.
4.2.
Other
than is specifically stated in this Privacy Policy, We will only disclose or
transfer Your Personal Information (including Sensitive Personal Information) in
the event required to do so under applicable laws, rules and regulations or
under directions from a law enforcement agency, governmental official, legal
authority or pursuant to similar requirements applicable to Us. The Company may
disclose or transfer Your Personal Information (including Sensitive Personal
Information) in its sole discretion in accordance with this Privacy Policy when
We deem this necessary in order to protect Our rights or the rights of other
persons and Users, to prevent harm to such persons or User or property, to
fight fraud and credit risk, or to enforce or apply the Privacy Policy and
Agreement, as and when deemed necessary in line with applicable laws.
4.3.
We
may disclose and transfer Your Personal Information (including Sensitive
Personal Information) in the manner mentioned above only if required to do so
by law or in the good faith belief that such disclosure is reasonably necessary
to respond to court orders or for other legal processes under applicable laws.
We may disclose and transfer and share Your Personal Information with
government or judicial or other competent legal bodies (such as law enforcement
agencies) in the good faith belief that such disclosure is reasonably necessary
to enforce Our Agreement, respond to claims or orders or notices or other
lawful requisitions or for purpose of compliance with applicable laws and
regulations. Such transfer or disclosure shall be for lawful purposes and made
subject to applicable laws in the United States.
4.4. The Company may disclose, transfer, and share Your Personal
Information (including Sensitive Personal Information) with third parties such
as the Entities in line with Our business purposes including business research,
analysis, and development in connection with the Services provided on the
Platform. We may disclose and transfer Your Personal Information (including
Sensitive Personal Information) to third parties (such as Entities and Business
Partners) to facilitate the restructuring of Our business subject to Your
consent in the manner mentioned in this Privacy Policy. Such
disclosure and transfer are undertaken by Us subject to Your consent and the
Agreement for lawful purposes in line with this Privacy Policy. In
relation, to Our business, We may share, disclose and transfer Your Personal
Information (including Sensitive Personal Information) for the purpose of obtaining
professional advisory or services such as in relation to tax, regulatory and
legal compliances, or in case of any major event such as merger, acquisition,
sale and/or transfer of assets, or in case of any force majeure event, or as part of any merger, sale of Company
assets or acquisition, or in the event of insolvency, bankruptcy, or
receivership to Our professional advisors, consultants, Entities or other third
parties. Such transfer shall be made subject to Your consent in the manner
specified to You under the Privacy Policy. The
transfer of Your Personal Information (including Sensitive Personal Information)
to other third parties in the manner mentioned will only be done once it is
ensured that the third party receiving such information has implemented the
same level of security practices as We have.
5.
USE OF INFORMATION
COLLECTED
You acknowledge and accept the following:
5.1.
We use the Personal
Information (including Sensitive Personal Information) We collect from You (as
mentioned herein above) only for and in connection with the Services and the
business transactions between You and the Company on the Platform in the manner
mentioned herein subject to the applicable laws.
5.2.
Your Personal Information
and Sensitive Personal Information (such as the password associated with Your
account with Us) is principally used by Us for creating and maintaining Your
User account on the Platform and for offering You the Services. We may combine Your
Personal Information (including Sensitive Personal
Information) and use and process it along with other information about You
that We may have collected automatically through Your access or use of Our
Platform, information about You in the public domain, as well as any other
information (such as Personal Information including Sensitive Personal
Information) You may choose to provide Us in the manner mentioned herein.
5.3.
We may also use Personal
Information (including Sensitive Personal Information) to contact You and share
additional and/or upcoming information with You regarding: any changes made by
Us in the Services or Platform; any aspects which are likely to impact the
Services or Platform; Our requirements or instructions for and in relation to
the Platform or Services and the scope thereof; to enforce the Agreement or for
other important notifications in this regard; and for any other purpose as may
be specified to You as part of Our Agreement or otherwise specified to You in the
written communication You receive from Us
from time to time.
5.4.
We may also use Your
Personal Information (including Sensitive Personal Information) to the extent
We are lawfully mandated or required to do so under applicable laws and for
lawful purposes in accordance with this Privacy Policy and the applicable laws,
such as for the purpose of responding to the judicial process, providing
information to law enforcement agencies or any government agency in connection
with a query/investigation as permitted by law, to identify security breaches
and attacks, investigate, prevent, and take action on illegal or suspected
fraud or money laundering activities and conduct forensic audits as part of
internal or external audit or investigation as required by law or government
bodies or agencies located within the United States or outside jurisdictions.
5.5.
We use Your Personal
Information only for legitimate purposes under the applicable laws for and in
connection with Our business purposes, which generally include the following:
5.5.1. to
contact You as and when necessary;
5.5.2. to
maintain any registered accounts that You may hold with Us;
5.5.3. for
verification or authentication of Your account;
5.5.4. to
customize the content of Our Platform for You;
5.5.5. to
gather broad demographic and statistical information about Your activity on Our
Platform;
5.5.6. to
request for reviews of Our Platform and/or Services, or any other improvements
thereto;
5.5.7. to
prevent any misuse or abuse of Your account and information and to detect and
protect against occurrence of error, fraud and other criminal activity on the
Platform;
5.5.8. for
responding to the judicial process and providing information to law enforcement
agencies or any government agency in connection with a query/investigation on
matters as permitted by law in the manner mentioned herein;
5.5.9. for
Our business requirements, including for record keeping, reports, data
processing, statistical or risk or other analysis, for review, for improvement
of the Platform and Services, to help diagnose problems with Our servers, to
resolve disputes or complaints pertaining to Our Platform and Services,
troubleshoot problems, to enforce this Privacy Policy and to administer Our
Platform and Services; and
5.5.10. for
any other purposes as detailed herein or as We may detail to You at the time of
collection of Your information or may communicate to You in writing.
5.6.
We may use Your Personal
Information for marketing and advertising the Platform and Our Services and certain
third-party products and services (including of Our Entities) to You (such as
by displaying advertisements and links to third party websites on the Platform
in the manner mentioned herein). Prior to any direct marketing or commercial
operation (for example for sending the newsletters or commercial offers), We
will first obtain the User’s consent, either upon creation of an account by the
User on the Platform or later by allowing the User to indicate User’s choice in
the account settings. The User may withdraw User’s consent to such marketing at
any time, directly by clicking on the unsubscribe link available on each communication
received, or by modifying Your account settings on the Platform, or by reaching
out to Us using the “Contact Us” form available on the Platform.
5.7.
We re-iterate that We do
not use or process Your Personal Information, including Your Sensitive Personal
Information (such as any of Your financial details, including but not limited
to Your bank account details, credit or debit card details and other payment
details), for the purpose of any payments made or received in connection with
the Services on the Platform. It is reiterated that such Personal Information,
if submitted by the User in connection with the Services, will be directly
collected and processed by the Payment Service Provider engaged by Us for this
purpose. Users to note that the relevant Payment Service Provider engaged by Us
shall directly collect the Personal Information including Sensitive Personal
Information that User may submit in connection with payment purposes when the
User opts to makes or collect any payment in connection with the Services
subject to the independent terms of use and privacy policy maintained by the
Payment Service Provider.
6.
REVIEW AND CORRECTION OF
INFORMATION
You acknowledge and
accept the following:
6.1.
We grant Users the
opportunity to review, correct and amend the Personal
Information (including Sensitive Personal Information) User has provided to
Us and submitted on the Platform. You may review and amend details associated
with Your account and profile with Us through accessing Your account with Us or
by contacting Us in accordance with this clause. You may intimate Us of any omissions
or errors in any other Personal Information that You may have previously
submitted to Us by filling out the “Contact Us” form available at Our Platform
and may request for correction or amendment to any Personal Information that
You consider to be incorrect or wrong. We shall process such requests from the
User in accordance with applicable laws in the United States. Upon receipt of a
verifiable request from You, We will use commercially reasonable efforts to
correct the inaccurate Personal Information taking into account the nature of
the information and the purposes of the processing and in accordance with
applicable laws and regulations.
6.2.
You acknowledge and
accept that We are not responsible for the authenticity of any Personal
Information (including Sensitive Personal Information) that You provide to Us.
You are solely and exclusively responsible for providing Us information about
You that is true, authentic, and correct in all aspects and particulars. If You
provide inaccurate or false information to Us, You shall be liable to indemnify
and hold harmless the Company (and its officers, directors, contractors or
agents and any third party relying on the information provided by You) in the
event You are in breach of this Privacy Policy. You shall have the sole
responsibility to intimate Us and request correction of inaccurate Personal
Information maintained by the Company about You.
7.
INFORMATION STORAGE AND
SECURITY
You acknowledge and
accept the following:
7.1.
The security of Your Personal
Information (including Sensitive Personal Information) is important to Us and
We have implemented commercially reasonable robust physical, managerial,
operational, and technical security measures to protect the loss, misuse, and
alteration and to preserve the security of Your Personal Information as may be
in Our possession. We follow leading industry standards to protect the Personal
Information submitted to Us, both during transmission and once We receive it,
in the manner provided in this Privacy Policy. The Personal Information (including
Sensitive Personal Information) We collect is stored in electronic form but may
also be converted to physical form from time to time, if deemed necessary. We take
necessary precautions to protect Your Personal Information both online and
off-line and implement reasonable security practices and measures that are
commensurate with respect to the information being collected and the nature of
Our business.
7.2.
All Personal Information (including
Sensitive Personal Information) collected through Our Platform is securely
transmitted to and stored by Us in Our primary data storage facility (along
with a backup storage option). To ensure secure storage of Your data Our database
is stored on servers secured and protected behind a firewall. Our servers are
hosted on Amazon Web Services (AWS) which employs industry-leading security
protocols for safeguarding Your Personal Information. Further, access to Your
data is limited by Us to eradicate and mitigate risks. We employ data
encryption measures to protect Your Personal Information on a per User basis
and ensure that only authorized devices within the Company’s secure network can
access Your Personal Information. The access to Your Personal Information is
limited to select executives of the Company. As an additional security measure,
We require such executives to authenticate themselves by using two-factor
authentication in order to access Your Personal Information. As an additional
defense mechanism to prevent any potential security breaches and to counter the
threat of viruses and malware, We install and maintain comprehensive virus
protection software on all Our secured devices.
Further, We conduct regular audits of the data We collect, process and
store to ensure Our compliance with established security standards and to
promptly identify and address any vulnerabilities and to protect the loss,
misuse and alteration of the Personal Information in Our possession.
7.3.
Although We make
best possible efforts to store Your Personal Information (including Sensitive
Personal Information) in a secure operating environment that is not open to the
public, You understand that there is no such thing as complete security, and We
cannot guarantee safety or security of Your information in case events beyond
Our control occur, both during transmission of Your information and once We
receive it and thus cannot guarantee that there will be no unintended
disclosures of Your information. If We become aware that Your Personal
Information (including Sensitive Personal Information) has been disclosed in a manner
not in accordance with this Privacy Policy, We will use reasonable efforts to
notify You of the nature and extent of such disclosure as soon as reasonably
possible and as permitted by law. We encourage You to follow certain security
measures on Your part during and after the transmission of Your Personal
Information (including Sensitive Personal Information) as may be reasonable and
appropriate and as may be communicated and requested to You by Us in writing in
the manner mentioned herein. In general, We
encourage the User to follow certain security measures on their part,
including: if using a computer in a public location, to always log out and
close the website browser when You complete Your online session; keep Your
account details and passwords private; frequently change Your password; avoid
using the same password for multiple online accounts.
7.4.
We retain Information
Collected for as long as is reasonably necessary for the purposes listed in
this Privacy Policy to provide You with access to Our Services and Platform. However,
You acknowledge and agree that We may retain certain Personal Information (including
Sensitive Personal Information) of User for a longer duration of time at Our
discretion for other purposes, strictly purposes which are in line with Our
business operations, such as research and development in connection with the
Platform and Services and for any regulatory, tax or accounting requirements
and other compliances We are subject to under applicable laws.
8.
USER CONSENT AND
PERMISSION
You acknowledge and accept the following:
8.1.
User may communicate any grievances
or concerns regarding User’s Personal Information (including Sensitive Personal
Information) to the Company by reaching out to Our Grievance Officer in the
manner provided in this Privacy Policy. In case the User opts to decline to
provide consent or withdraw any consent granted to Us in respect of collection
or processing of the User’s Sensitive Personal Information, the User should
clearly intimate Us of such request in writing by filling out the “Contact Us”
form available at Our Platform. In such case the User acknowledges and agrees
that the User’s actions may interfere with or render it impossible for Us to
offer any further Services to You and We may be forced to limit, suspend or
terminate Your access to the Platform and/or the Services.
8.2.
User hereby agrees and
acknowledges that We shall not be held liable in any manner whatsoever if We
are unable to perform Our Services or if there is a deficiency in the Services
provided by Us due to any Personal Information (including Sensitive Personal
Information) provided by a User which is incorrect or due to any withdrawal of User
consent. User acknowledges and agrees to indemnify and hold Us (and Our
employees, consultants, directors, representatives and/or affliates) harmless
from any complaints, legal proceedings or claims filed or initiated by any
third party against Us due to any breach by the User of the terms of this
Privacy Policy.
8.3.
We take data privacy
seriously and are committed to ensuring the security and confidentiality of our
users' information. Our data retention and deletion policy are designed to
empower users with control over their personal data. Users have the right to
request the deletion of their data, and we have a dedicated grievance officer
available to address any such queries or fill out contact us form specifically
stating your request. We believe in transparency and accountability when it
comes to data management, and we're here to assist our users in making informed
choices about their data. Rest assured, your data is in safe hands, and we are
committed to honoring your requests for data deletion promptly and securely.
8.4.
We provide Users with the
opportunity to opt-out of receiving non-essential (promotional, marketing
related) communications from Us, once You sign-up on the Platform, by sending
an e-mail to the following email address: contactus@wolfwinplay.com. To the
extent We use Your Personal Information to market to You, We will provide You
the ability to opt-out of such uses. In case, You choose to do so then Your
access to the Platform may be limited, or We might not be able to provide the
Services to You.
9.
CHANGES TO PRIVACY POLICY
You acknowledge and accept the following:
9.1.
You acknowledge and
accept that the Company may update this Privacy Policy at any time, with or
without advance notice. In the event there are significant changes in the way
Company treats User’s Personal Information, or in the Privacy Policy itself,
Company will display a notice on the Platform and may intimate Users concerning
relevant changes in the Privacy Policy via an e-mail, so that You may review
the changed terms prior to continuing to use the Platform and Our Services.
9.2.
If You object to any of
the changes to Our Privacy Policy and You no longer wish to avail the Services,
You are entitled to deactivate Your account with Us and refrain from using or
accessing the Platform and Our Services. You may also reach out to Us by
filling out the “Contact Us” form available at Our Platform in this regard. If
You have any complaints or issues concerning changes to Our Privacy Policy,
please reach out to Our Grievance Officer in the manner provided in this
Privacy Policy.
9.3.
Unless stated otherwise
herein or otherwise informed to You in writing by the Company, the Company’s
current Privacy Policy applies to all information that the Company has about
You. If You choose to maintain Your account with Us and/or use the Platform or
the Services in any manner after any notice of changes or updates made by Us in
Privacy Policy is published on the Platform or informed to You over electronic
communication via an e-mail in the manner provided herein, then You hereby
consent to the changed terms of Our Privacy Policy.
10.
GRIEVANCE REDRESSAL
10.1. In
case You have queries or concerns pertaining to the Privacy Policy or Our use
of Your Personal Information (including Sensitive Personal Information), You
can direct any questions or complaints to Us by contacting Our designated
grievance officer (“Grievance Officer”) in writing via e-mail and/or by
post using the contact details mentioned herein below. Any communication
pertaining to any discrepancies, points of concern or grievances as regards the
Privacy Policy and any complaints, abuse, or concerns with regards to content
and/or breach of the terms herein must be immediately informed to the Grievance
Officer (using the contact information mentioned below) in writing. The
Company shall not be responsible in the event that You address any
communication to any non-designated person in this regard.
|
Name |
: |
Dhrumit Kabariya |
|
Office Address |
: |
241 Forest Ave, Paramus, NJ 07652 |
|
Email Address |
: |
You acknowledge and accept that You will provide
Our Grievance Officer with all necessary information
and/or documents to enable the Grievance Officer to resolve the issue.
10.2. The
grievances received under this paragraph shall be dealt with in adherence to
the timelines specified under the Information Technology Act, 2000 and the
applicable rules notified thereunder. We will investigate and attempt to
resolve any queries regarding the use or disclosure of Your Personal
Information (including Sensitive Personal Information as soon as possible).
While We try to respond to all legitimate requests as soon as possible from the
date of receipt of the query, occasionally it may take Us longer than the same
if Your request is particularly complex, or You have made a number of requests,
or You have not provided all necessary information/documents to enable the
Grievance Officer to resolve the issue. In this case, We will notify You and
keep You updated.
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