Privacy Policy
Effective Date: 25 September 2025
This Privacy Policy (“Policy”) constitutes a legally binding document between InvestAPlay Games Private Limited, a company incorporated under the laws of India, having its registered office at India (hereinafter referred to as the “Company”, “We”, “Us”, or “Our”), and any natural person or legal entity who accesses or uses the website, its constituent webpages, applications, services, and the online gaming platform comprising Quiz, Ludo, Solitaire and such other games or services as may be introduced from time to time (hereinafter collectively referred to as the “Platform”), and shall govern the collection, storage, processing, usage, disclosure, and protection of personal and non-personal information of the users of the Platform (hereinafter referred to as the “User”, “You” or “Your”).
By accessing, visiting, or otherwise using the Platform, You signify Your unequivocal consent to the terms of this Policy, in addition to the Terms of Service, which are deemed to be incorporated herein by reference. In the event You do not agree to the provisions of this Policy, You are hereby advised to forthwith discontinue usage of the Platform.
1. DEFINITIONS
(a) “Applicable Law” shall mean and include the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Digital Personal Data Protection Act, 2023, and such other rules, regulations, notifications, or governmental directions as may be in force in India and applicable to the subject matter herein.
(b) “Personal Information” shall mean any information relating to an identified or identifiable natural person, as may be defined under Applicable Law, including but not limited to name, contact details, email address, and such other details voluntarily provided by the User.
(c) “Sensitive Personal Data or Information” or “SPDI” shall mean such categories of information as may be designated under Applicable Law, including but not limited to passwords, financial information, health data, biometric information, and the like.
(d) “Non-Personal Information” shall mean any information that does not identify a User personally, including device identifiers, cookies, usage statistics, gameplay data, and related technical information.
(e) “Processing” shall mean collection, recording, storage, adaptation, retrieval, consultation, disclosure, erasure, or destruction of Personal Information.
2. COLLECTION OF INFORMATION
2.1 The Company may collect and Process the following categories of information:
(i) Information voluntarily furnished by the User, including Personal Information submitted at the time of registration, creation of an account, or while communicating with the Company.
(ii) The platform will share the following information with Facebook: (a) public profile, which contains followers’ information, friends game-play monitoring etc; (b) email address associated with the Facebook profile of the user; and (c) user friends.
(iii) Information stated in (i) includes name of user, contact number of user, email account of user and date of birth of user.
(iv) Information obtained from third-party service providers, advertisers, and analytics partners who may, subject to Applicable Law, share data with the Company for purposes ancillary to the operation of the Platform.
3. PURPOSE AND LEGAL BASIS OF PROCESSING
3.1 The Company shall Process Personal Information for one or more of the following purposes:
(a) For the provision, operation, maintenance, and administration of the Platform and Services.
(b) For personalization of User experience, including targeted and interest-based advertising.
(c) For compliance with legal or regulatory obligations under Applicable Law.
(d) For legitimate business interests, including monitoring, analytics, and enhancement of the Platform.
(e) For communication of transactional messages, service updates, and other administrative notifications.
3.2 The legal bases for Processing shall include: (i) consent of the User; (ii) necessity for performance of a contract; (iii) compliance with legal obligations; and (iv) pursuit of legitimate interests of the Company.
4. DISCLOSURE OF INFORMATION
4.1 Subject to Applicable Law, the Company may disclose Personal Information to:
(a) Its affiliates, subsidiaries, employees, and agents, strictly on a need-to-know basis.
(b) Third-party service providers including but not limited to AdMob, Unity Ads, Meta Ads, Firebase, etc.
(c) Government authorities or law enforcement agencies where required.
(d) Any third party in case of merger, acquisition, or restructuring.
4.2 The Company shall not sell or rent Personal Information.
5. RETENTION OF INFORMATION
The Company shall retain Personal Information only while the account is active and shall delete it within 30 days after account deletion, unless required otherwise under law.
6. DATA SECURITY
The Company implements reasonable security practices. However, no method is completely secure, and the Company disclaims liability for breaches beyond control.
7. IN-APP PURCHASES
7.1 The Platform may offer optional in-app purchases.
7.2 All payments are final, non-refundable, and non-cancellable.
7.3 Virtual goods have no real-world monetary value and cannot be converted.
7.4 Transaction issues must be reported within 7 days. No cash refunds will be provided.
8. RIGHTS OF USERS
(a) Right to access data
(b) Right to correct data
(c) Right to withdraw consent
(d) Right to request deletion
9. GRIEVANCE REDRESSAL
Name: Pooja Singh Tevatiya
Designation: Grievance Officer
Email: grievance@investaplay.in
Complaints will be acknowledged within 24 hours and resolved within 15 working days.
10. AMENDMENTS
The Company may update this Policy at any time. Continued use constitutes acceptance.
11. GOVERNING LAW AND JURISDICTION
This Policy shall be governed by the laws of India. Courts at New Delhi shall have exclusive jurisdiction.
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