PRIVACY POLICY

Our Business

We recognize privacy is important to our users. This document describes how and why Good Gamer India Private Limited. (“GoodGamer”, “we”, “us” or “our”), collects, receives, possesses or stores Personal Information (as defined below) as well as non-personally identifiable data from users and website visitors, publishers, mobile applications and end users of publisher sites to GoodGamer (www.goodgamer.in) (“you”/ “your”), and how that data will be used, handled, dealt with and shared with third parties (“Privacy Policy/Policy”). GoodGamer is committed to respect the privacy of personal information as well as non-personally identifiable data.

We urge you to read the Policy carefully in order to gain a clear understanding of the type of Personal Information collected and how we may collect the same, usage or disclosure of your Personal Information in the course of providing you with our products or services, and your use of our website (www.goodgamer.in) and our mobile application (the website and mobile application shall collectively be referred to as “Portal”) as well as reasonable security practices and procedures adopted for the collection and usage of your Personal Information. The user information is collected mainly vide two means: (i) information supplied by the user itself or (ii) automatic retention of the user data during the navigation of the Portal by the user.

This Privacy Policy shall serve as an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder. This Privacy Policy does not require any physical, electronic or digital signature and is a legally binding document between you and GoodGamer.

By using our Portal or services, or otherwise interacting with us, you consent to the collection, usage and disclosure of your Personal Information by GoodGamer in accordance with the terms of and for the purposes set out in the Privacy Policy.

This Privacy Policy covers the following:

Personal Information

1. What is Personal Information?

“Personal Information” means any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information.

Anonymized data

This Policy does not cover anonymized aggregated data from which the identity of an individual cannot be determined. Good Gamer reserves the right to use anonymized data in any way it determines appropriate.

2. What Personal Information do we collect?

We may collect the following Personal Information when you visit our Portal, contact us, register with us, use our products or services or otherwise provide us with information about you and use the same in accordance with the terms of this Privacy Policy:

Automatically Collected User Information

We obtain certain information about your use of our Portal. This information is collected when publishers, advertisers, and advertisement networks use the Good Gamer platform. Additionally, certain other information (such as cookies, described below) may be transmitted by our web server to your computer. Specific types of usage information that may be collected automatically are described below:

Information for complying with law

We may collect information from the users as a matter of compliance with the mandate of the certain law.

Information from the personnel

We may also collect Personal Information from prospective job applicants, our employees and individuals associated with our business partners and service providers. Usually this information is limited to name and contact details and the other information we need for the purpose of managing the employment or business relationship.

3. How do we collect your Personal Information?

Good Gamer only collects Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing our products, services or Portal. We use only fair and lawful methods to collect Personal Information.

Consent

When you provide Good Gamer with the Personal Information, we ask for your express consent to us collecting it and using it for that specific purpose only.

If we ask for your Personal Information for a secondary reason, for e.g. marketing, we will ask you again for your express consent. In either case, we will provide you with an opportunity to say no. We will not share your Personal Information with any third party (other people or businesses) without your prior consent.

Withdrawing your consent

If after you opt-in, you change your mind, you may withdraw your consent for the continued collection, use or disclosure of your information, at any time, by contacting Good Gamer and intimating us of the same in writing.

However, please note that consent cannot be withdrawn retroactively. It should be noted that in certain circumstances, our products or services can only be offered if you provide us with your Personal Information.

Consequently, if you choose not to provide us with the required Personal Information, we may not be able to offer you these products or services. We will inform you of the consequences of the withdrawal of consent.

4. Cookies and tracking technologies

Cookies

We use Cookies to collect usage information when you visit our Portal and to serve advertisements to users. Cookies are small text files placed on your hard drive that assist us in providing a more customized Portal experience. It is our policy to use cookies to make navigation of our Portal easier for visitors.

Declining cookies

If you are concerned about cookies, most browsers permit individuals to decline cookies. To learn how you may be able to reduce the number of cookies you receive from us or disable cookies that have already been installed in your browser’s cookie folder, please refer to your browser’s help menu or other instructions related to your browser.

You can also learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies using different types of browsers. Note that while declining cookies may negatively affect your user experience on our Portal, however it will not prevent us from transacting with you.

Log Files

In order to properly manage our Portal, we may anonymously log information on our systems, and identify categories of visitors by items such as domains and browser types. These statistics are used to manage the operational efficiency of our systems.

5. Online Behavioral Advertising and Ad Tracking

As part of our ad delivery and reporting, we log page views and collect information for the purpose of delivering advertisements or providing advertising-related services, including providing a specific advertisement based on a particular type of browser or time of day; statistical reporting in connection with the activity on a website; and tracking the number of advertisements served on a particular day to a particular website (tracking web analytics data). To do so, we collect information about the type of browser, referrer and operating system of website visitors, as well as the domain name, day and time of visit, and page(s) visited. We do so across multiple web domains owned or operated by different entities.

Opt-out: You can opt-out of the use of your Personal Information for the purposes of Online Behavioral Advertising by contacting us, or by visiting Your Ad Choices at http://youradchoices.ca/choices. The Your Ad Choices opt-out tool allows you to opt-out of any advertising networks participating in the self-regulatory program for online behavioral advertising. However, note that opt-outs will not be effective if your browser is configured to reject cookies, or if you subsequently erase your cookies, use a different computer or change browsers.

6. How do we use your Personal Information?

Good Gamer uses the data collected from users and Portal visitors, including Personal Information, in order to:

We may also use statistical or aggregated information about the Portal’s use and share, publish, post, disseminate, transmit or otherwise communicate or make available such information, to suppliers, business partners, sponsors, affiliates and any other third party, at our sole discretion.

Use of Push Notifications

We use push notifications to send you periodic alerts when we publish important and/or sponsor-related news items to the platforms. When you first enter our platforms, you may choose to approve or deny receiving push notifications. If you no longer wish to receive these notifications, you may turn them off at the browser or mobile device level.

Combined anonymized data

With respect to data collected via the Good Gamer platform, we may share with third parties, advertisers, and/or business partners anonymized, non-personally identifiable, or aggregated data we receive or collect. The use and disclosure of such anonymized, non-personally identifiable, or aggregated information is not subject to any restrictions under this policy.

Logging in through third party social media platforms

If you log in to the Good Gamer platform through your account on a third-party social media platform, your Personal Information that you shared through that social media platform may be aggregated and disclosed to participating advertisers and ad networks for the purpose of improving the relevance of the advertising presented to users.

Please note that logging in through your account on a third-party platform is optional. If you do not wish for your Personal Information available through a third-party social media platform to be used for these purposes, you may log in using your email address. If you had previously logged in through your third party social media account, and wish to opt out of the use and disclosure of your Personal Information for the purposes of improving the relevance of advertising presented to you, you may do so by contacting us or by revoking access given to Good Gamer through the third-party social media platform.

Our use of Personal Information is limited to the purposes described in this Policy. We do not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information we have obtained.

7. How do we share your Personal Information?

Good Gamer may disclose the data collected from users and Portal visitors, including Personal Information, to the following parties, provided that such disclosure shall be for the purposes which are related to the objectives for which such information is collected:

Provided however, our partners and service providers may change basis commercial needs and requirements.

8. How the information disclosed to the third-party to be protected?

The parties to whom the Personal Information is shared in accordance with the Paragraph 7 above, shall maintain the confidentiality of the same and we shall undertake reasonable steps for ensuring that the information shared to the third-party (for the above mentioned purposes) is protected by the third-party, in accordance with the terms of this Policy document. Usually we do this by imposing contractual requirements on or seeking assurances from third-parties as to their compliance our Privacy Policy.

9. How long do we retain your Personal Information?

We keep your Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with us, but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. As such, we may keep your account information after the termination of your account.

When your Personal Information is no longer required for the purposes for which it was collected, we will destroy, delete, erase or convert it into an anonymous form. If we learn that we have unintentionally stored Personal Information (e.g., if we become aware that a URL that we store contains Personal Information), we will use commercially reasonable efforts to anonymize or purge this information.

10. Where do we store your Personal Information?

Good Gamer may transfer Personal Information to a service provider which is located outside of India where privacy laws may offer different levels of protection from those in India. Your Personal Information may also be subject to access by and disclosure to law enforcement agencies under the applicable foreign legislation. Any and all financial information shall always be stored in India, except in case of cross-border payment transaction, the copy of such financial information can be stored outside India, if required. The ‘financial information’ includes within its ambit the end to end transaction details, information regarding payment and settlement transaction that is collected as a payment instruction which may inter alia include: customer data (name, mobile number, email, Aadhaar number, PAN number, etc. as applicable); payment sensitive data (customer and beneficiary account details); payment credentials (OTP, PIN, passwords, etc.); and, transaction data (originating & destination system information, transaction reference, timestamp, amount, etc.).

Additionally, we will transfer any Personal Information to any other body corporate located in India or outside which ensures the same level of data protection that is adhered to by us and if you have consented to such transfer.

11. How do we protect your Personal Information?

Our Portal is analyzed on a regular basis for any security gaps and identified vulnerabilities for the purpose of securing the Personal Information collected by us. Information that we collect is stored on servers that Good Gamer solely manages, using standard physical, procedural and technical security procedures and practices appropriate to the nature of the information in an effort to protect information from unauthorized access, destruction, use, modification, or disclosure. The server is password protected and is strictly limited. We further protect Personal Information by restricting access to it to those of our employees that require access to the information in order to provide our products or services on Portal.

However, no security precautions or systems can be completely secure. We cannot ensure or warrant the security of any information you transmit to Good Gamer, and you do so at your own risk. We cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet, telephone or any other networks.

We do not favour any specific commercial product or service or any firm, trade name or corporation name which is used or referenced on our Portal. The reference of such is only limited to the informational purposes for the public.

We do not provide any direct or indirect representation or warranty with regard to the non-infringement of the third-party rights, title, merchantability, fitness and freedom of any computer virus in relation to the product or service provided vide this platform. We shall not be held liable for any direct, indirect, incidental, compensatory loss, loss of goodwill, loss of income or profit or claims of third parties.

The information which is communicated vide a social media platform comes within the public domain and we do not guarantee the security of the same.

Management and security of Personal Information

The user is advised to maintain the confidentiality of the login information which is provided by the user for registering with us. Such login information includes username and a password, which should be within the knowledge of the user only and should not to be disclosed to any other person.

12. What do we do to the Personal Information provided by children?

The minimum age limit of the User to enter into any transaction in relation to the products and services offered by us, is 18 years. The persons under the 18 years age are expressly excluded from availing the services on our platform. We request the parent/guardian to inform us on an immediate basis of their children’ submission of the Personal Information with us, by contacting at privacy AT goodgamer DOT in. We shall ensure the prompt deletion of such Personal Information, upon receiving of such complaint by the parent/guardian.

13. How do we ensure protection of your payment transaction?

All the information in relation to the payment of the transactions are processed through the payment gateways and are not stored on our servers. The information stored with the payment gateways is encrypted through the Payment Card Industry Data Security Standard (“PCI-DSS”). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by the store and its service providers.

14. What do we do in case of a privacy or security breach?

A “breach of security safeguards” is defined as the loss of, unauthorized access to or unauthorized disclosure of Personal Information resulting from a breach of an organization’s security safeguards or from a failure to establish those safeguards.

In case of a breach of security safeguards involving your Personal Information under our control, we will notify you in the circumstances to believe that the breach creates a real risk of significant harm to you, including physical, financial or reputational.

We will also notify any other organization or government institution that can reduce the risk or mitigate the harm from the breach. We will keep a record of all breaches in accordance with our legal obligations.

15. How can you access or correct any inaccuracies in your Personal Information?

Good Gamer endeavors to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary to the extent provided by you, for the purposes for which we use that information.

If we become aware that Personal Information is inaccurate, incomplete or out of date, we will revise the Personal Information and, if necessary, use best efforts to inform third party service providers or contractors which were provided with inaccurate information so that those third parties may also correct their records. However, we shall not be held responsible for the authenticity of Personal Information as supplied by the user and we make no claim, guarantee or promise for the accuracy of the data and expressly disclaim any liability arising out of the inaccuracy in the content of information.

Good Gamer permits the reasonable right of access and review of Personal Information held by us about an individual and will endeavour to provide the information in question within a reasonable time, generally no later than 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.

Refusal to access the Personal Information

We reserve the right of refusal of the request for access of the Personal Information in certain circumstances including, where providing such access would be unlawful or we are required or authorized to do so by or under an Indian law or court/ tribunal order or where giving access would be likely to prejudice enforcement related activities by or on behalf of an enforcement body. The refusal statement shall be conveyed to the individual in writing along with the reasons for such refusal and the appropriate grievance redressal mechanism for raising objections against the refusal.

16. Your choices with respect to the collection, use and disclosure of your Personal Information

Depending on the products, services or your use of our Portal, your choices may include the following:

17. Links to other websites

We may provide links to, or automatically produce search results for, third-party websites or resources, or third-party information referencing or linking to third-party websites or resources. Good Gamer has no control over such third-party websites and resources, and you acknowledge and agree that Good Gamer is not responsible for the content or information contained therein. When you follow such a link, you are no longer protected by our Privacy Policy, and we encourage you to read the privacy statements or other disclaimers of such other parties. Good Gamer is not responsible for the privacy or security practices or the content of external websites, services or products.

Good Gamer cannot and does not guarantee, represent or warrant that the content or information contained in such third-party websites and resources is accurate, legal, non-infringing or inoffensive. Good Gamer does not endorse the content or information of any third-party website or resource and, further, Good Gamer does not warrant that such websites or resources will not contain viruses or other malicious code or will not otherwise affect your computer. By using Good Gamer’s Portal to search for or link to a third-party website, you agree and understand that Good Gamer shall not be responsible or liable, directly or indirectly, for any damages or losses caused or alleged to be caused by or in connection with your use of, or reliance on, Good Gamer to obtain search results or to link to a third-party website.

18. Changes to this Privacy Policy

Good Gamer reserves the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Portal. If Good Gamer makes material changes to this Policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. The continued usage of our platform shall be treated as a deemed acceptance to the modifications to the Privacy Policy, as and when such modifications are undertaken. If Good Gamer is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to be able to transact with you.

19. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of India and the applicable Indian privacy laws. You agree to submit any dispute arising out of your use of this Portal to the exclusive jurisdiction of the courts of India.

20. Data Protection Regulation

The Company shall on a best effort basis protect the Personal Data of its Users in the following manner, in addition to its statutory obligations as stated under Clauses 1 to 19 of the Privacy Policy. The Company is not obligated to treat the User’s data in the manner as stipulated under this Clause 20 until statutorily required to do so under the laws of India.

Personal Data” means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, mobile device, precise location data and biometric data.

a. Legal grounds for processing your Personal Data

We may tell you about the legal basis we’re relying on to process any Personal Data about you.

The legal basis for us processing your Personal Data for the purposes set out above will typically be because:

• You provided your consent. In order to store and gain access to information stored on your device, we rely on your consent. For this so-called “cookie consent” (which applies not only to “cookies” but also to mobile ad identifiers), we rely on our own compliance steps and our web and mobile partners’ compliance steps, designed to ensure that consent is collected and passed on to partners, and to ensure that we only facilitate the collection of legally obtained data. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to such consent and its withdrawal.

• The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing Personal Data, in order to provide our and/or other data controllers’ services. Such processing goes beyond the original collection of mobile ad identifiers. A legitimate interest we rely on, for instance, is the tailoring of promotional communications to users of web and mobile properties, which is beneficial to users and is an integral part of the ecosystem by which freely available content is funded through advertising revenue. This also sometimes includes providing analysis of and reporting about ad campaigns, as well.

• We also rely on legitimate interest when we use Personal Data to maintain the security of our Services, such as to detect fraud or to ensure that bugs are detected and fixed.

• Contractual Relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our customer records and contact information).

• Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.

b. Transfers of Personal Data

As Good Gamer works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside India, and which have no data protection laws or laws that are less strict compared with those in India.

When we transfer Personal Data outside of India, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. Feel free to contact us at the contact information below, for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.

c. Personal Data Retention

As a general matter, we retain your Personal Data for as long as necessary to provide our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. We generally render our own identifiers (e.g., those we use to “sync” our customers data to online users) inactive after 13 months, provided that we may retain them if we have a legal or significant operational need to do so, such as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.

d. Your Rights as a Data Subject

The following rights may apply to you, in addition to persons located in India:

e. GoodGamer as a data controller and a data processor

EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). As noted above, we are not always a data controller of the data in our possession but are sometimes a data processor for other companies such as our customers. In such cases, we may direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data.