PRIVACY POLICY

Nirdesa Networks Private Limited (“Pocket52”, or “we” or “our” or “us”) operates the Pocket52 mobile/desktop application and website (“Platform”), which enables users in select States of India (“Users”, or “you” and its grammatical variations) to access and participate in a wide variety of online game of poker in various formats and variations.

This policy (“Privacy Policy”) forms an integral part of the Terms of Service between Pocket52 and Users and governs how Pocket52 collects, uses, shares, and protects the personal information disclosed by Users in the course of their usage of the Platform. Accordingly, you are advised to read this Privacy Policy carefully before accessing the Platform.

1. Types of information collected

   1.1 We may collect the following types of information:

   • Information you provide: when you register on the Platform, you may be required to provide us with your name, email address, mobile number, display picture, social media account ID (where submitted by you), and other relevant profile information. Additionally, you will be required to provide your bank account details when you make use of the add cash or cash withdrawal options for cash Games, and your Permanent Account Number (PAN) when you use the cash withdrawal option. In some cases, such as referral programs, you may provide us with the personal information of another person.
   • Transaction details initiated by you: When you initiate a cash transaction in relation to your Account, we receive and store details pertaining to such transaction, including the payment method used, the amount added to the Account, and the date and time of the transaction.
   • Interaction information: When you interact with Pocket52’s customer support telephonically, such telephonic interactions may be recorded and stored.
   • Technical information about you: - We automatically collect certain information from you when you use the Platform, including your IP address, location, other unique device identifiers, your browser type, language, the URL of the website which you may have used to reach our Platform, and cookies (defined below).
   • Usage information: When you play any game offered by us on the Platform, including any formats of such games, such as tournaments, promotional games, practice games, and cash games (together, “Games”) on the Platform, we collect details related to the manner of your use of and interaction with our Platform and other Users such as the date and time during which you accessed the Platform, the location from where you access the Platform, the amount of money spent on each Game you participate in, the duration for which you play any Game, and the formats of Game you participate in.
   • Messages. When you use our Platform to communicate, we receive and collect the messages you may send or receive on the Platform, and any other content you may upload or share on the Platform.
   • Cookies: We use cookies, small text files that uniquely identify your browser and enable Us to recognize the information you have consented to give Us, to store certain types of information each time you visit any page on our Platform. These cookies do not contain any personal information and you may choose what cookies you allow by managing your cookies settings on your browser. This will allow you to delete your browser cookies or disable them entirely, however, if you choose to disable all cookies, it will affect your overall experience with our Platform— it may make parts of our Platform non-functional or inaccessible to you in such cases. Therefore, we recommend that you enable cookies for our Platform. The cookies we collect are mainly used to serve advertising banners to you and in doing so we may use the services of third parties. Such third-party service providers do not know the name, phone number, address, email address, or any personal information about you, and no personal information is collected or used in this process.
   • Web beacons: We use web beacons, images that are part of the web pages, also called pixel tags or clear gifs, in combination with cookies to understand how you interact with our Platform and the content therein. When you disable cookies, web beacons are also likely to become ineffective. You can also add browser extensions to specifically block web beacons.

   1.2 Some of the information that we require you to provide on first accessing or registering on the Platform is mandatory and/or essential to the provision of our services to you, and hence if you do not provide such mandatory information, you may not be able to access some of the features of the Platform.

2. How we use your information

   2.1 In addition to the uses of information we describe elsewhere in this Privacy Policy, we use your information to do the following:

   • enable your access and use of the Platform;
   • process cash transactions to your Account, and enable Withdrawals;
   • facilitate your participation in various types of Games and events on the Platform;
   • send you Pocket52 service-related emails and communications, including notifications about changes to our policies or services;
   • market our services or products or services of our group companies, affiliates and subsidiaries to You;
   • handle support requests, including investigating a transaction or issuing a refund;
   • perform internal operations such as troubleshooting, data analysis, testing, research, statistical, internal training, and quality management purposes aimed at improving the Platform, enhancing future game developments, and making advertisements more relevant. Such analysis is aggregated and does not pertain to any specific User;
   • Verification of users and their accounts;
   • measure and understand the effectiveness of the promotions, and advertisements we serve to you and others;
   • personalize the Platform for you, including the promotions and advertisements that may be served to you;
   • provide you with user support; and/or
   • enforce our Platform Policies.

   2.2 Where you use our referral program, we use

   • your name/email address in the heads of the email/SMS sent to the person referred; and
   • the name, mobile number, and email address of the person referred, to communicate with them.

   2.3 Where you join the Platform via our affiliate program, we will share

   • your name/email address/user ID in the email/SMS sent to the affiliate through whom you have been onboarded to the Platform; and
   • the details of your gameplay, including date you joined the Platform, add cash details on your Wallet, Discount details, rake generated, etc. will be shared by the Platform with the affiliate through whom you have been onboarded to the Platform.

   2.4 Optional use: We may use your personal information for the purpose of testimonials and other promotions.

3. How we store your information

   3.1 The information collected by us from users of the Platform is securely stored and processed on servers located in India.

   3.2 Some of our affiliates and/or service providers may store or process information in jurisdictions other than India.

4. How we share your information

   4.1 We may share your information with various third parties who assist us in providing you with our services, including the following:

   • Service providers, such as information technology and payment service providers, whose services form a part of or are necessary for the provision of our services;
   • Advertisers and advertising networks that require the information to select and serve advertisements to you and other users;
   • Cloud storage providers to store the information you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;
   • Cloud storage providers to store the information you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;
   • Analytics and search engine providers that assist us in the optimisation and improvement of the Platform;
   • Entities that provide us with marketing assistance; and/or
   • Entities that provide us with customer support services.

   4.2 We may share your information with subsidiaries, affiliates and group companies of Pocket52 that aid us in the provision of our services and the functioning of the Platform. We may also share your information with subsidiaries, affiliates and group companies of Pocket52 for our internal business purposes including without limitation data analysis.

   4.3 We may share your information with law enforcement agencies, public authorities, or other organizations if legally required to do so, or if such use is reasonably necessary to:

   • comply with any legal obligation, process, or request from government or judicial authorities;
   • enforce our Platform Policies, including investigation of any potential violation thereof;
   • detect, prevent, or otherwise address security, fraud, or technical issues; or
   • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection).

   4.4 The service providers we engage are bound by data processing agreements that require them to take sufficient technical and organizational measures to safeguard your information.

   4.5 If we sell or otherwise transfer our business, or our assets, in full or part, to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), your information may be among the items sold or transferred. The buyer or transferee would be obligated to honor the commitments made in this Privacy Policy.

5. How long we retain your information

   5.1 We retain your information for as long as is necessary to provide you with our services; thereafter, we may retain your information to comply with our legal obligations, resolve disputes and enforce our agreements, and to protect Pocket52’s legal rights, subject to limitations under applicable law.

6. Your rights and preferences

   6.1 Access and Updation: You may access and update the personal information that you have provided to us by logging into your Account, and using the options available therein, though this may be restricted in instances where you are not able to verify your identity or there is any suspicious activity associated with your Account.

   6.2 Withdrawal from providing information: You have the right to withdraw or decline your consent to the collection of any information you provide us at any time by writing to us at support@pocket52.com. Please note, this may affect your usage and access to our Platform.

   6.3 Deletion of Information: You can also request for deletion of any and all personal data or information stored with Pocket52 by sending an email to support@pocket52.com. Once your request for deletion has been received and confirmed, We will delete your personal data or information from our records. However, we shall also reserve the right to discontinue the services for which the information was originally collected. Please note that we may have to retain such personal data or information if required under applicable laws and regulations; fraud prevention; to maintain archives; to enforce rights under this Privacy Policy and Terms of Service.

   6.4 Communications Opt-Outs: You can opt-out of marketing or advertising emails by sending an email to support@pocket52.com

7. Security and protection of your information

   7.1 We use industry standard and legally mandated safeguards to keep the information collected by us secure. These measures include periodic reviews of our data collection practices, storage and processing practices, cyber security measures such as encryption, and physical security measures to guard against unauthorized access to systems where we store Users’ personal information. We have a comprehensive information security program and information security policies that contain managerial, technical, operational and physical security control measures adequate for the protection of personal information, including sensitive personal information.

   7.2 When you register with us, your Account is protected by means of a unique password, which is known to or may be accessed only by you. You are responsible for maintaining the secrecy of your unique password and information, and for controlling access to emails between you and us, at all times. Therefore, you should not provide your password to anyone whosoever: breach hereof constitutes a violation of this Privacy Policy and may result in termination of your Account in certain cases. If you become aware of or reasonably suspect any breach of security, including compromise of your password, you must notify us immediately.

8. Information relating to children

   The Platform is not intended or directed at anyone under the age of 18, and we do not knowingly collect or solicit any information from, or allow the registration on the Platform of, anyone under the age of 18. Upon learning that we have collected personal information from a user under the age of 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under age 18, please contact our Grievance Officer in the manner provided in Clause 10 below.

9. Third party platforms and services

   The Platform may contain links to third-party websites or services (“External Resource”). Your browsing on and interaction with any External Resource, irrespective of whether the link to such External Resource originated on our Platform, is subject to the terms and privacy policies of such External Resource. We are not responsible for the functionality, privacy, or security measures of any other entity and this Privacy Policy will not govern your use and access of such website or service you are redirected to.

10. How to contact us

    If you have any thoughts or questions about this Privacy Policy or the Platform, or any concerns or grievances about the processing of your personal information by us, please contact our Grievance Officer at: Name: Mr. Deepak YadavEmail address: grievance.officer@pocket52.com2nd Floor, B-Wing, Elnath Building, Exora Business Park, Prestige Tech Park, Kadubesanhalli Bangalore, Karnataka- 560103 India

11. Changes to this Privacy Policy

    Pocket52 may modify or update this Privacy Policy from time to time, and we will notify you, via email or in-app/website notifications of any such changes. However, you are advised to review this Privacy Policy periodically, as your continued use of our Services after any modification to this Privacy Policy will constitute your acceptance of such modification.