This privacy policy forms part of our Applications Terms of Service, by accepting the Terms of Service and the Privacy Policy on the registration page, you consent to provide sensitive personal data or personal information and are aware of the purpose of sharing such information. The following policy applies to your use of Arvesi Technologies Private Limited’s (hereinafter referred to as “Troop” or “we” or “us” “our”) website and/or Services, and covers information collected in connection with your access to and use of our website and/or Services. Please read this Privacy Policy carefully.

By registering with us and continuing to interact with us, you are consenting to the practices described in this Privacy Policy. The registration procedure to access our services cannot be completed until the information in the non-optional fields is provided. Certain additional personal information may also be requested by Troop to permit you access to any Cash Games organized by us.

1. Policy objective

We respect your privacy and assure you that any information provided by you to Troop is protected and will be dealt with according to this Policy and the applicable laws. To avail the services offered on www.troopapp.in and application(s) (hereinafter singly referred to as the "Platform" and collectively referred to as “Platforms”), you may have to provide certain information to us. This Policy provides the procedure followed by Troop to gather, use, store, disclose, and manage users' personal data. Troop only collects personal data for the purpose of verifying user accounts, maintaining the accounts of the users, completing transactions of the users, analyzing user behavior, and other related requirements

2. What information do we collect:

We collect or receive information you provide when you use, register on our Platform, access your account, communicate with us, answer our surveys, upload content, or otherwise use our Services. We collect the following information about you:

1. Sensitive Personal Data:

• Account password

• Financial information such as Bank account, credit card , debit card, UPI id or other payment instrument details

2. Other Personal Information:

• Name

• Date of birth

• Telephone number

• Postal/Contact address

• PAN number (as applicable)

• The IP address of your computer, browser type and language.

• The date and the time during which you accessed the site.

• The address of the website which you may have used to link to any Website

• Your photograph for testimonials and other promotions.

• Such other information that is defined as sensitive personal data or information in law.

3. How we use your information:

We may use information about you for number of purposes, including:

a. For providing our services:

All users of Troop consent to the use of Sensitive Personal Data and Other Personal Information for verifying user accounts, maintaining the accounts of the users, completing transactions of the users, for analyzing user behavior and other related requirements.

b. Providing, Improving, and Developing our Services:

We may also use software applications for Platform traffic analysis, to gather related statistics, for advertising and for determining the efficacy and popularity of Troop among others.

c. Marketing:

Photographs provided as a part of testimonials and promotions by you specifically for marketing purposes give us irrevocable rights to use it for that purpose. We retain the discretion to delete or not use it any further, subject to the User Control of Personal Data and Information clause of this Privacy Policy.

Presently, Troop also displays advertising and remarketing through Google Analytics, wherein third party vendors including google, display our ads on sites across the internet and use first party cookies and third party cookies together to inform, optimize and serve ads based on visits of visitors to our website. Our visitors are free to opt out of Google Analytics for display advertising and customize google display network ads using ads preference manager.

d. Sharing Data:

We may be required to share information received from you, with our employees, contracts, agents, and regulatory authority(ies). We restrict access of personal information to these abovementioned parties and only allow access to your data on a need-to-know basis in order to process it for providing our Services or otherwise if requested in case of regulatory authority(ies).

We may also share personally identifiable information with advertisers and sponsors of Troop. We may also use your name, photo, Login ID, and the state from where you are participating when announcing the results of any contests run on the Platform. Such contests are further governed by terms and conditions which shall be available on the Platforms as and when such a contest is run on any Platform. Troop conducts periodic analysis and surveys of the traffic to the Platform for market research and advertising purposes. In pursuance of the same, we reserve the right to share your registration information with Troop appointed market research and advertising companies or firms from time to time for the said purposes. Troop may also use cumulative non-personal information for auditing and analysis purposes with the aim of improving its services.

e. Cookies:

What is a Cookie: A cookie is a small text file that uniquely identifies your browser when you visit a website. Cookies allow us to retain your preferences and account settings, among other things.

You understand and accept that when you visit our Platform(s), cookies may be left on your computer. These cookies assigned by the servers of Troop may be used to personalize your experience on the Platform(s). Additionally, cookies may also be used for authentication, game management, data analysis, and security purposes.

Cookies may also be assigned by the advertisers of Troop when you click on any of the advertisements which may be displayed on any Website in which case such cookies are controlled by these advertisers and not Troop.

f. Email communication:

When you register your email address with Troop, you agree to receive email communication from Troop, entities specifically authorized by Troop, and other users. You also agree and acknowledge that when you use our referral program for referring someone, Troop will send emails to the person referred by you on your behalf. The email headers will carry your email address as the address from which such emails are sent.

Troop may also access and store such information relating to your contacts to send invitations and other promotions to them periodically.

g. Use of SMS API for OTP

We use SMS (Short Message Service) for the purpose of delivering one-time passwords (OTP) to your provided phone number for account verification and security purposes. We do not store your OTP or phone number after it has been successfully delivered.

4. Data Security:

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices, and security measures. We also undertake measures including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. Troop has a comprehensive information security program and information security policies which contain managerial, technical, operational, and physical security control measures adopted by Troop for the protection of Sensitive Personal Date and Other Personal Information.

Information gathered by Troop is stored securely using several information security applications. However, security is always relative and Troop cannot guarantee that its security measures are absolute and cannot be breached. Data that is transmitted over the Internet is inherently exposed to security risks or threats. For instance, information transmitted via chat or email can be compromised and used by others. Therefore, Troop cannot guarantee any security for such information in the course of transmission through the internet infrastructure or any unsolicited disclosures made by any user availing the services of the Platform.

When you register with Troop, your account is protected by means of login information which includes a username and a password that is known only to you. Therefore, you should not provide your user credentials and related personal information to anyone whosoever, and breach hereof constitutes a violation of this Policy and can also result in the closure of the account in certain cases. If you become aware of or reasonably suspect any breach of security, including compromise of your login information, it is your responsibility to immediately notify the same to Troop.

5. User control on personal data or information:

You have control over your data in the following ways:

a. Updating your information

You shall be entitled to update the information provided by you by updating it on the platform.

b. Deletion of Data

Users can anytime delete their account on Troop app

Please note that we may have to also retain such personal data or information if any exception applies as stated in the Exclusions clause of this Privacy Policy or if applicable laws require us to maintain archives or retention of data including such personal data or information.

6. Data Retention Policy:

Troop shall retain the information provided by the users for such period of time as is required to fulfil the purposes for which such information is collected, as outlined in this Privacy Policy, subject to such longer time periods of retention as may be required under any applicable laws.

7. Exclusions:

Troop may share Sensitive Personal Data and Other Personal Information if sharing of such information is necessary:

• to comply with legal processes or governmental request;

• to enforce the Terms of Service and this Privacy Policy;

• for prevention of fraud;

• for issues involving information security, or

• to protect:

  1. your rights;

  2. rights of Troop; and

  3. rights of the general public.

8. Limitation of Liability:

Troop confirms that this Privacy Policy is only a description of its operation regarding user information. This Policy is not intended to and does not create any legal rights in your favour or in the favour of any other person. Troop reserves the right to change this Policy at any time without giving you prior notice. The liability of Troop shall be limited to removal of Sensitive Personal Data from the system of the Platforms and removal of personally identifiable elements of the Other Personal Information. Notwithstanding anything to the contrary contained in this Policy and elsewhere, the aggregate liability of Troop for all claims for damages pursuant to provisions of services on the Platforms, including claims in respect to the violation of this Policy, shall be limited to the aggregate maximum amount of liability as provided in the Terms of Service