This privacy policy (Privacy Policy) adopted by Sharkpocket Solutions llp (hereinafter referred to as “Sharkpocket”, “We”, “Us” or “Our”) governs the collection, use and transfer of information capable of identifying a person (Personal Information) accessed or shared with Us by virtue of use or access of our mobile applications or websites (Platform).

By agreeing to this Privacy Policy, or by accessing, or by using the Services (defined below) through the Platform, you consent to the collection, transfer, adaptation, alteration, storage, disclosure, and other uses of your Personal Information as described in this Privacy Policy. If you have any concerns about providing data, or having it used in any manner permitted in this Privacy Policy, you should not use the Sharkpocket Services. Unless specified otherwise, this Privacy Policy applies only to the Platform and services, features, software, and functionalities offered by Us, via the Platform.

For the purposes of this Privacy Policy, “Sensitive Personal Data or Information” or “Sensitive Information” means Personal Information, that consists of the

(i) password,

(ii) financial information, such as bank account, debit or credit card details,

(iii) physical, psychological and mental health condition,

(iv) sexual orientation,

(v) medical records and history,

(vi) biometric information,

(vii) any detail relating to the above as provided to the body corporate for providing a service, and

(viii) any of the information received under each of the aforesaid heads by the body corporate for processing, or to be stored or processed under a lawful contract or otherwise.

This Privacy Policy incorporates the requirements under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

Our Business & Policy Applicability

Sharkpocket develops and operates software & technology products/ platforms and associated services for enabling, conducting, and offering online cash-based skill games i.e. games where there is a preponderance of skill over chance, whether through the deployment of physical or mental skill (Services).

By accessing our Platform, users and players (hereinafter referred to as “Users/”You”/”Your“) can access our Services, which include the provision of access to various games available on the Platform. As set out in the terms and conditions relating to the Services (the “Terms“), you must be at least at a legal age (minimum age of 18 years) to access and/or use the Services.

The Services are not directed to persons under the legal age of majority or any such persons residing outside India. We do not knowingly collect any Personal Information from children under legal age. If We become aware that a child under legal age has provided Personal Information, steps will be taken to remove such information and terminate such an account. If you become aware that any Personal Information of a child/minor is provided, please contact our Grievance Officer (defined below).

For the purposes of this Privacy Policy, unless defined hereunder, all capitalized terms shall have the meaning ascribed to them under the Terms. THIS PRIVACY POLICY DOES NOT APPLY TO MOBILE APPLICATIONS OR WEBSITES WHICH ARE NOT OWNED OR CONTROLLED BY SHARKPOCKET, INCLUDING THIRD PARTY LINKS AND APPLICATIONS WITH WHICH YOU MAY INTERACT WHILE USING THE PLATFORM. WE WILL NOT ASSUME ANY LIABILITY FOR ANY HARM CAUSED TO YOU BY ACCESSING ANY THIRD PARTY WEBSITES OR LINKS ADVERTISED ON THE PLATFORM. YOUR ACCESS AND USAGE OF ANY THIRD-PARTY WEBSITES OR APPS IS ENTIRELY AT YOUR OWN RISK. THE COMPANY SHALL NOT BE A PARTY TO ANY TRANSACTION BETWEEN YOU AND A THIRD-PARTY SERVICE.

Collection & Use of Information

 A. Personal Information We obtain and you hereby consent to provide your Personal Information at the time of registration or from third-party service providers you interact with or engaged by us. Such Personal Information includes.

Registration – phone number/Google email ID, name, location

Using wallet, payment functions – bank account details, payment method (including your UPI handle or Virtual Payment Address associated with your regisitered mobile number), name, KYC proof documents. Please note that we do not collect Aadhaar information.

Customer support correspondence: When you ask for assistance from Our customer support, the contact information you provide will be collected, as well as information about your gameplay or activity on the Service, your user ID number, your financial and payment information, and the correspondence. If available through the Services, you may provide Us with certain profile information which you consent to make public, such as a short biography, location, website, cell phone, a picture, information to customize your account, etc. Such contact information may be used to send you information about the Services or related information.

B. Non-Personal / Aggregated Data: Additionally, Sharkpocket may use data management services to access device information; metadata of incoming and outgoing calls and messages; device storage, device identifiers, call related information and records, application history, etc.

These permissions are collected to better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Platform, analyse player traffic and activity, respond to user desires and preferences, and for other research and analytical purposes. This includes.

Ads: Advertisers on mobile devices sometimes use advertising identifiers to enable and optimize their advertising, to deliver tailored ads related to your interests (Interest-Based Advertising or IBA). These identifiers are non-permanent, non-personal, device identifiers. We and/or third parties may use your device’s advertising identifier and other information associated with it, to deliver ads that relate to your interests and to improve and measure the effectiveness of ad campaigns.

Location Services: We and/or third parties may use and store information about your location to provide special features, to deliver ads that relate to your interests and/or to improve and customize the Services and to ensure that you are not accessing the Platform from restricted states in India or outside the territorial limits of the Republic of India.

Log Data Services: Our backend servers automatically record information created by your use of the Services. This data may include information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. Log data is received when you interact with the Services. This data is used to provide the Services and to measure, customize, and improve them.

Third-party services: We use a variety of third-party services to help the provision of the Services, such as hosting and other services. These third-party service providers may collect information sent by your browser as part of a web page request, such as cookies or your IP address, location and devices’ unique identifiers. Also, third-party ad partners may share information to measure ad quality and tailor ads, for example, to display ads about things you may have already shown interest in.

Device Management Services: The Device Management Services access device information; data, metadata of incoming and outgoing calls and messages; device storage, device identifiers, call related information and records, application history, etc.

These permissions are collected to better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Services, analyze player traffic and activity, respond to user desires and preferences, and for other research and analytical purposes.

C. Sensitive Personal Data or Information Collected: Please note that We shall always take your express consent before collecting any Sensitive Personal Data or Information.

We are committed to keeping all such Sensitive Personal Data or Information safe at all times and ensure that such data/information is only transacted provided the highest possible degree of care available under the technology presently in use. Sharkpocket will not use Your Sensitive Personal Data or Information for any purpose other than for such specific purposes as you have expressly consented to its use.

If you opt for the paid functions on the Platform, Sharkpocket may collect the billing and financial information necessary to process the charges, including bank account details; and/or do so on behalf of the relevant payment service providers.

Purchases of third-party services are subject to the policies applicable to such providers. Any payment data may need to be retained only within India to comply with directives of the Reserve Bank of India that apply to the payment service providers we engage to provide the services.

Where we permit any third parties to collect and use your Sensitive Personal Information, we, to the best of our knowledge,
(i) ensure that such third parties maintain the same security standards that are adhered to by us and prescribed under applicable data protection laws for the protection of your Sensitive Personal Information and
(ii) take reasonable measures to ensure that the third parties do not disclose the Sensitive Personal Information unless such disclosure has been expressly consented to by you.

When You deposit money to Your wallet on the Platform by using a Virtual Payment Address (VPA) of the Unified Payments Interface (UPI) payment method, We may store such VPA to facilitate seamless and swift deposit transactions for You in the future and for enhancing Your payment experience. You understand, agree and consent to such storing of the VPA by the Platform.

The Platform may also, from time to time, through the Payment System Providers, fetch other VPAs associated with Your mobile number registered with the Platform. These VPAs will be used to facilitate seamless and swift deposit transactions for You and for enhancing Your overall payment experience. You understand, agree and consent to the Platform obtaining such VPAs from relevant Payment System Providers and storing and displaying such VPAs to You on the Platform.

Disbursal Information Services: If you make a purchase in the Services, We may collect and store the billing, payments, and financial information necessary to process the charges/payments; and/or do so on behalf of the relevant payment service providers. Purchases of third-party services are subject to the policies applicable to such providers.

Some of the Personal Information, for example, your name and/or username, may be listed publicly on the Services, including on your profile page and in search results.

You agree that We and/or third parties on our behalf and/or our partners may use and store the Personal Information for the purposes of contacting you as part of customer support; to send you updates or information about the Services; managing your account and relationship with the Service, improving the in-app experience, facilitating seamless transaction, improving the Services, research, surveying, and engaging with you.

For example by sending you communications for these purposes; marketing and promotion of the Services or other products; to personalize and optimize the Services, promotional content and/or advertising; to create reports, analysis or similar services for the purposes of research or business intelligence.

In certain circumstances, such as improving Your user experience or enabling seamless payment transactions for You on any online platform that We operate, we may use Your financial information (including your UPI handle or Virtual Payment Address) to display it on the relevant payment processing or checkout page of such platform.