PRIVACY POLICY

PREAMBLE

This Privacy Policy ("Policy") constitutes a legally binding agreement between you ("User," "you," or "your") and Junglee Games India Pvt Ltd, a company incorporated under the laws of India, having its registered office at Floor 14, Building No. 5, Tower A, DLF Cyber City, Phase-III, Gurgaon, Haryana – 122002 and/or its Affiliates, subsidiaries, associates and partners ("Junglee Games," "we," "us," or "our").

This Policy describes our practices regarding the collection, use, processing, storage, retention, safeguard, disclosure, and transfer of your Personal Information when you access and/or use the Rummy.com website, mobile applications, and related services (collectively, the "Services"), the Platform offered by Junglee Games. Our commitment is to provide a secure, transparent, and compliant environment for all our Users. We handle your data with the utmost care and in strict accordance with applicable laws, ensuring that your privacy is protected at every stage of your interaction with our Services.

We are committed to protecting your privacy and handling your Personal Information in an open, transparent, and lawful manner. Your trust is the cornerstone of our business, and this Policy is designed to provide you with comprehensive details about your privacy rights and the measures we take to safeguard them.

This Policy applies to our Services available under the domain and sub-domains of the Website (https://www.rummy.com/) as well as the mobile applications (Android and iOS) and must be read in conjunction with and is to be construed in accordance with the Rummy.com Terms of Service. Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Terms of Service.

1. YOUR CONSENT AND ACKNOWLEDGEMENT

1.1 By accessing, downloading, registering for, or using our Services, or by clicking on an "I Agree" or similar button, you expressly consent to be bound by the terms of this Policy and our Terms of Service. You agree to the collection, use, storage, processing, safeguard and disclosure of your Personal Information as described herein.

1.2 If you do not agree with the terms of this Policy, you must immediately cease accessing or using our Services and uninstall the application. Continued use of the Services will be deemed as your acceptance and agreement of this Policy and any subsequent amendments made thereto.

1.3 You acknowledge that you are providing your Personal Information voluntarily and out of your own free will. You understand that the collection and processing of your Personal Information are necessary for us to provide you with our Services. You have the option not to provide the Personal Information we seek, but in such cases, we may be unable to provide you with some or all of our Services, or certain features may be unavailable.

1.4 You represent that the Personal Information you provide is and shall remain true, correct, and updated. You have a duty to inform us of any changes to your Personal Information to ensure its accuracy. We shall not be responsible for the authenticity of the Personal Information supplied by you.

1.5 By using the Services, you represent and warrant that you are at least 18 years of age and legally competent to enter into a binding agreement under applicable law.

2. DEFINITIONS

2.1 "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 us, is capable of identifying such a person. This includes, but is not limited to:

Name
Email
Date of birth
Mobile number
Postal/Contact address
PAN (as applicable)
The IP address of your computer, browser type and language.
The date and the time of your accessing the Services.
The address of the website that you may have used to link to our Services
Your photograph for the purpose of testimonials and other promotions.
Your transaction and behavioural data.
Any other information that is defined as “sensitive personal data or information” in law.

2.2 "Sensitive Personal Data or Information" (SPDI) consists of information relating to passwords and any other information identified as sensitive under the applicable laws. We handle your password or any other SPDI that we may collect, with the highest level of security and confidentiality and do not disclose the same to third parties without your express consent, unless such disclosure is required by applicable law or regulatory order.

3. INFORMATION WE COLLECT

We collect the following categories of information, which are necessary to provide our Services and to comply with our legal obligations. The collection is limited to what is necessary for the purposes outlined in this Policy.

3.1 Information You Provide to Us

1. Registration and Profile Information: When you create an account, you provide your full name, date of birth, residential address, email addresses, and mobile number. This information is fundamental to creating your unique user profile and ensuring you are eligible to use our Services.

2. Know Your Customer (KYC) Information: To comply with legal and regulatory mandates, we collect information and images from your government-issued identification documents, such as PAN Card, Aadhaar Card, Passport, or Voter ID. This is essential for mandatory identity and age verification and to prevent fraudulent activities, including but not limited to, creation of multiple accounts.

3. Financial Information: As our Services are limited to free-to-play practice games and freeroll tournaments, we do not collect or require any financial information from you, such as bank account numbers, Virtual Payment Address (VPA) IDs, or credit/debit card details. We do not process any monetary deposits or withdrawals.

4. Communications Information: We collect information from your correspondence with us, including your interactions with our customer support teams via email, chat, or recorded telephonic conversations. This helps us resolve your queries, improve our Services, and maintain records for legal and quality purposes.

3.2 Information We Collect Automatically

1. Technical Information: We automatically collect your IP address, device ID, device type, operating system, browser type and version, and other technical identifiers (device/browser fingerprinting). This data is crucial for optimizing our Services for your device and for diagnostic purposes.

2. Usage and Behavioral Information: We collect detailed records of your gameplay, login/logout activity, User-to-User communications, clicks, features you use, time spent on the app, game play history and responsible gaming habits. Analyzing this data allows us to enhance User experience, identify and fix bugs, and ensure a fair and secure gaming environment.

3. Geolocation Information: We determine your precise location via device GPS (with your explicit permission) or your coarse location based on your IP address. This is a critical compliance measure used to enforce geofencing restrictions and prevent Users from accessing our Services from states where they are legally prohibited.

3.3 Information from Cookies and Similar Technologies

We use cookies, pixel tags, web beacons, and other tracking technologies to enhance your experience. This includes using Essential, Performance & Analytics, Functional, and Targeting & Advertising Cookies to remember your sessions, analyze usage patterns, debug issues, and deliver targeted advertising that may be of interest to you. You can manage your cookie preferences through your browser settings, though disabling certain cookies may impact the functionality of the Services.

3.4 Information We Generate or Receive from Others

1. Inferred Information and Profiling: We may use automated systems, including artificial intelligence and machine learning, to generate insights about your gaming preferences, skill level, risk profile, and user segment. This helps us offer you a more personalized experience, suggest relevant games, and enhance our responsible gaming checks.

2. Information from Third Parties: We may receive information from third-party services if you choose to log in via such services (e.g., Google). We may also receive information from financial institutions and fraud prevention agencies to verify your identity and assess risks.

3.4 Visitor & Non‑registered User Data: We collect data from users who access and browse our Services without registering. This includes information gathered through cookies, device and browser logs, usage patterns, and similar tracking technologies, in line with our Cookies Policy.

3.5. Information from Social Features and Invites: If you choose to use features that allow you to invite friends to the Services (such as “Invite a Friend” or “Refer & Earn” features), we may request access to your mobile device’s contact list or social media connections, based on your permission. The contact information accessed is used solely for the purpose of identifying and inviting those individuals to the Services or to provide referral benefits (if applicable).

4. HOW WE USE YOUR INFORMATION

Your information is used for specific, explicit, and legitimate purposes:

4.1 Service Provision and Account Management: To create, manage, and secure your account; facilitate gameplay; and provide timely and effective customer support.
4.2 Legal, Regulatory, and Compliance Obligations: To conduct mandatory KYC verification as required by law; to prevent fraud, cheating, and other illegal activities; to enforce our Terms of Service; and to comply with orders from law enforcement, judicial bodies, or other regulatory authorities.
4.3 Personalization and Service Improvement: To analyze user behavior and trends, which helps us improve the functionality, usability, and overall quality of our Services. This also allows us to provide you with customized content, personalized offers, and relevant promotions.
4.4 Marketing and Communications: To send you information about new games, special offers, tournaments, and other events that may be of interest to you. You can manage these communication preferences in your profile settings at any time.

4.5 Use of Other Personal Information for Marketing and Promotions

1. We may use, share, or disclose your data and information including your personal, gameplay, and behavioural data, and/or aggregated and/or anonymized data and information, to provide you with marketing, advertisement and promotional content of third parties, including that of our Affiliates. This includes sharing your Personal Information with contracted third-party service providers and partners who assist us or the third parties (to whom we share, disclose your data and information) on our or their behalf to deliver marketing, advertisement or promotional services, both on our Services (such as in-app messages, advertisements, banners) and outside our Services (such as through SMS, email, WhatsApp, push notifications, or other digital channels). These Affiliates, third parties, and partners will be contractually obligated to handle your Personal Information in accordance with applicable data protection laws.

2. By using our Services, you grant Junglee Games the irrevocable, perpetual, worldwide, royalty-free, non-exclusive right to record, depict, portray, use, reproduce, publicly display, and distribute your actual or simulated likeness, name, photograph, voice, in-game actions, chat communications, gameplay outcomes, tournament wins, and related attributes, in connection with the development, distribution, advertising, promotion, and publicity of the Services and any related content or experience. This may include, but is not limited to, showcasing User achievements, testimonials, leaderboard placements, and promotional campaigns in all formats and media now known or hereafter developed, across any channels, without any compensation to you, unless prohibited by law.

3. Push Notifications: If you have enabled push notifications, then you can disable (or enable) any time by going to your device “Settings” and clicking on “Notifications,” and then changing those settings for some or all of the apps on your device. (Different device configurations, or updates to devices, may affect or change how these settings work.)

4.6 Data Sharing - General with Affiliates

We may disclose or share your data and information, including your personal, gameplay, and behavioural data, with one or more of our Affiliates including for the reasons to support platform operations, marketing, analytics, product improvement, fraud prevention, due diligence, and other business purposes, including developing or operating products and services similar or related to us. Our Affiliates will have the right to use and handle this Personal Information for these purposes, in compliance with applicable data protection laws, to ensure a seamless and consistent experience across our services.

In the event we undertake or subject to (either voluntary or under any legal process) a strategic transaction, sale (either of business or of assets), merger, acquisition, other change in control, your data and information, including your personal, gameplay, and behavioural data, may be transferred to another affiliate or successor entity, in accordance with applicable data protection and data localization laws.

4.7 Security and Fair Play

To actively monitor gameplay and User activity for fraud, cheating, collusion, and other malicious activities. This is essential to maintain a secure, fair, and trustworthy gaming environment for all our users.

4.8 Recording and Use of Gameplay

1. We may record your gameplay, including but not limited to screen activity, interactions, in-game communications (such as chats or voice), and gameplay outcomes while you use our Services. This gameplay data may be used for multiple legitimate purposes, including but not limited to:

a. Fraud detection and prevention: Identifying suspicious gameplay patterns, collusion, unfair practices, or violations of fair play policies.
b. Security monitoring: Ensuring platform integrity, protecting against automated bots, and securing user accounts.
c. Product improvement: Analyzing user interactions to improve the User interface, game mechanics, and platform performance.
d. Customer support: Reviewing recorded gameplay to resolve disputes or investigate user complaints.
e. Legal and regulatory compliance: Retaining gameplay logs to assist with investigations by law enforcement or regulatory bodies, as required.
f. Marketing and promotional use: Using excerpts or highlights of gameplay (such as tournament footage, notable plays, or leaderboard moments) for promotional content, including advertisements, tutorials, social media, and in-app promotions.

2. All such recordings will be handled in accordance with this Policy and applicable data protection laws.

4.9 Inter-platform Gameplays with Affiliate and Partner Platforms

1. We may, from time to time, enable users to participate in common gameplay formats, including games, tournaments, and competitions ("Inter-platform Gameplays") hosted jointly with its Affiliates ("Partner Platforms"). These Inter-platform Gameplays are designed to enhance user experience by reducing wait times, improving matchmaking, and offering access to a broader and more diverse pool of players.

2. In order to facilitate such Inter-platform Gameplays, we may share your Personal Information, gameplay data, and other gameplay-related information with Partner Platforms. This includes, but is not limited to:

Your user ID, username/avatar, skill tier, and gameplay history
in-game rank or points
Matchmaking or pairing parameters

3. Such data sharing is strictly limited to what is necessary for:

Enabling gameplay across platforms.
Preserving fair matchmaking and competitive integrity.
Ensuring continuity of gameplay, including prize distribution for any non-monetary rewards.
Complying with applicable legal, tax, or reporting obligations.

4. You expressly consent to this data sharing by participating in any game offered through our Services. All Partner Platforms are contractually obligated to protect and process your Personal Data in accordance with applicable data protection laws, with security and confidentiality standards equivalent to those of us.

5. DISCLOSURE AND TRANSFER OF YOUR INFORMATION

We do not sell or rent your Personal Information. We may disclose your data under limited and controlled circumstances:

5.1 With Our Service Providers: We share information with third-party contracted vendors who perform services on our behalf, such as , data analysis, cloud hosting, customer service, and marketing assistance. These providers are contractually obligated to protect your data with security standards at least as stringent as ours and are permitted to use it only for the purposes for which it was disclosed.
5.2 With Our Group Companies and Affiliates: We may share your information with our Affiliates, for internal business purposes, including providing integrated services, enhancing security, and preventing fraud across our Services.
5.3 For Legal and Safety Reasons: We may disclose your information to comply with applicable laws, or in response to any order, notice, direction, request, or demand from any government authority, law enforcement agency, regulatory body, investigative agency, judicial or quasi-judicial body, administrative or statutory authority, including but not limited to in connection with:
- 1. Enforcement of applicable laws;
- 2. Enforcement of our Terms of Service, Privacy Policy, or any other applicable terms or policies;
- 3. Responding to legal processes such as court orders or warrants;
- 4. Detecting or investigating fraud, illegal activity, security breaches, or technical issues;
- 5. Protecting or safeguarding our Services, infrastructure, users, personnel, and business operations.

Such disclosures will be made in good faith, and only to the extent we believe it is reasonably necessary or required under applicable law.

5.4 In Case of a Business Transfer: In the event of a merger, acquisition, financing, or sale of company assets, your information may be transferred to a successor entity. We will notify you before your information is transferred and becomes subject to a different privacy policy, providing you with an opportunity to opt-out if you so choose.

6. DATA SECURITY, STORAGE, AND RETENTION

6.1 Data Security: We have implemented and maintain robust technical and organizational security measures under the applicable laws. We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information. This includes encryption of data, firewalls, and strict access controls to prevent unauthorized access, disclosure, alteration, or destruction of your Personal Information. While we strive to implement robust security, we cannot guarantee that our security measures are absolute and cannot be breached. You are responsible for keeping your login information confidential and secure and must immediately notify us of any suspected breach of security.

6.2 We use commercially reasonable security practices and procedures, consistent with industry standards, to help keep your Personal Information safe and secure. However, please note that the transmission of information over the Internet is not completely secure. While we strive to protect your Personal Information, we cannot guarantee the security of data transmitted through our Services, and any such transmission is at your own risk. We also ensure, on a commercially reasonable efforts basis, that any agents or third parties we engage comply with the same security standards that we apply for the protection of your Personal Information.
6.3 Data Retention: We retain your Personal Information for as long as your account is active. Post closure or dormancy of your account, we may retain certain information for a longer period (typically up to 7 years, or longer if required by law) to comply with our legal, regulatory, fraud prevention, and audit obligations. This is necessary to handle any potential legal disputes and to meet our statutory record-keeping requirements.
6.4 Data Location: All your Personal Information is stored and processed on secure servers located within the territory of India. However, we may use third-party service providers located outside India. If we transfer your Personal Information or SPDI outside India, we will do so in compliance with applicable law.

7. YOUR RIGHTS AND CONTROLS

We provide you with rights and controls over your Personal Information:

7.1 Right to Access and Correction: You can access and update most of your profile information directly through account settings. For any information that you cannot correct yourself, you may contact our support team, and we will assist you in making the necessary changes.
7.2. Right to Deactivation and Deletion:
- 1. Account Deactivation: You can request a temporary suspension or deactivation of your account. Your data will be retained, but your account will not be active.
- 2. Account Deletion: You can request the permanent deletion of your account and associated Personal Information. Upon deletion, you will lose access to the Services and your data, subject to our legal data retention obligations.
7.3 Right to Withdraw Consent: You have the right to withdraw your consent for the collection or use of your Personal Information or SPDI at any time by contacting our Grievance Officer. If you withdraw consent for information that is necessary for us to provide our Services, we may no longer be able to provide some or all of our Services to you. Upon withdrawal, we will cease processing your data for the purposes for which consent was withdrawn, unless another lawful basis exists for continued processing.

8. CHILDREN'S PRIVACY

8.1 Our Services are intended solely for individuals who are eighteen (18) years of age or older, and we do not knowingly solicit, collect, or store Personal Information from individuals under the age of 18.

8.2 We have implemented age verification measures at the time of account registration and/or during KYC (Know Your Customer) processes to reasonably ensure that users meet the minimum age requirement under applicable laws.

8.3 If we become aware at any time that we have inadvertently collected or processed Personal Information from an individual under the age of 18, we will take prompt steps to delete such data from our systems and deactivate any associated accounts. We may also block access to the Services from that account to prevent further use.

8.4 If you are a parent or legal guardian and believe that your child under the age of 18 has provided us with Personal Information without your consent, you may contact our Grievance Officer and we will take appropriate steps to investigate and address the issue, including permanent deletion of the child’s data from our systems.

8.5 By using the Services, you represent and warrant that you are at least 18 years of age and legally competent to enter into a binding agreement under applicable law.

9. FRAUDULENT COMMUNICATIONS

9.1 We are committed to safeguarding your account and personal information. Please note that we will never ask you to share your password, OTP (one-time password), PIN or any other sensitive security credentials through email or phone call, SMS, whatsapp or any other communication channel not authorised by us.

9.2 If you receive any unsolicited communication claiming to be from us, or from someone impersonating our employees, agents, or support team, especially requesting sensitive data, login credentials, you should treat it as fraudulent and take the following steps:

1. Do not respond, click on links, download attachments, or share any personal or financial information.
2. Report the communication immediately to our Customer Support team through the official support section of our app/website or by emailing us at support@rummy.com.
3. If applicable, take screenshots or preserve evidence of the message/email for reporting and investigation.

9.3 Such fraudulent schemes may include, but are not limited to:

1. Fake offers or prize winnings asking for a “processing fee” (Please be aware that all our games are free-to-play and freeroll tournaments, and we will never ask for payment to claim a prize, except applicable statutory deductions or taxes).
2. Links to phishing websites that resemble our Services
3. Calls or messages claiming “account verification” or “bonus credit eligibility”
4. Requests for remote access to your device via apps like AnyDesk, TeamViewer, etc.

9.4 We disclaim all liability for any loss or damage caused by such unauthorized or fraudulent communications not initiated or authorized by us. We do not take responsibility for any user action arising from interaction with third-party scammers, fraudsters, or impersonators.

9.5 To protect yourself, please always verify that you are on our official domain (www.rummy.com) and use our in-app support for queries. We do not operate any customer care phone numbers, unless otherwise notified on our official Services.

9.6 We reserve the right to investigate and cooperate with legal authorities in cases of fraud or impersonation. Your vigilance is essential to maintaining a safe gaming environment for all users.

10. LEGAL AND MISCELLANEOUS

10.1 Limitation of Liability: While we are committed to protecting your data, you agree that we shall not be liable for any loss arising from any unauthorized access to your information, except as a result of our gross negligence or willful misconduct. Our liability will be limited to the extent permitted by applicable law.
10.2 Governing Law and Jurisdiction: This Policy shall be governed by the laws of India. You agree to submit to the exclusive jurisdiction of the courts located in Bengaluru, Karnataka, India, for the resolution of any disputes.
10.3 Changes to This Policy: We reserve the right to amend this Policy at any time. We will notify you of any material changes by email or through an in-app notification. Your continued use of the Services after such notification will constitute your acceptance of the revised Policy.
10.4 Severability: If any provision of this Policy is held to be invalid, illegal, or unenforceable by a court or other competent authority, such provision shall be enforced to the maximum extent permissible under applicable law, and the remaining provisions shall continue in full force and effect.
10.5 Limitation of Liability: To the maximum extent permitted by applicable law, we including our Affiliates, directors, officers, employees, and agents shall not be liable for any indirect, incidental, consequential, special, punitive, or exemplary damages (including, without limitation, loss of profits, data, goodwill, or business opportunities) arising out of or in connection with your use of this Services or reliance on this Privacy Policy. Our total liability, whether in contract, tort (including negligence), or otherwise, for any claims (including attorney fee) arising out of or relating to this Policy or your use of Services will be limited to refunding only the Withdrawable Balance, if any, in your Rummy.com account back to you, even if we have been advised of the possibility of such damage.

GRIEVANCE OFFICER

Please address your grievances, feedback, or questions, without limitation, with respect to the collection, processing, usage, disclosure, and security of your information in writing to:

Name: Ms. Parul Gupta

Email: grievance.officer@rummy.com