Privacy Policy
1. INTRODUCTION
1.1 STARLIGHT GAMING INDIA PRIVATE LIMITED and its affiliates"STARLIGHT GAMING", "we", "us" or "our") takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all users of our "Services". Users refer to a user who registers for an account or who otherwise uses or accesses the Services (“users”, “you” or “your”). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This policy (“Privacy Policy”) is designed to assist you in understanding how we collect, use, disclose, transfer and/or process the personal data you have provided to us and/or possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data. Capitalised terms used in this Privacy Policy that are not otherwise defined have the meanings given to them in the STARLIGHT GAMINGTerrms and Conditions.
1.2 "personal information" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number, and contact information.
1.3 By using the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES. We reserve the right to amend this Privacy Policy at any time, therefor it is suggested that you shall review it frequently. To the fullest extent permissible under applicable law, your continued use of the Services shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.
1.4 This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.
2. INFORMATION COLLECTED
2.1 We will/may collect personal data about you:
• when you use our Services;
• when you submit any form, including, but not limited to, application forms or other forms relating to any of our Services, whether online or by way of a physical form;
• when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our Services;
• when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when you interact with our customer service agents;
• when you use our Services;
• when you grant permissions on your device to share information when using the Services;
• when you link your Account with or other external credentials;
• when you carry out transactions through our Services or with our authorized third-party payment service providers;
• when you provide us with feedback or complaints;
• during your gameplay; and
• when you submit your personal data to us for any reason which is not listed above.
The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.
2.2 The personal data that STARLIGHT GAMING may collect includes but is not limited to:
• name, username and user ID;
• contact information (including email address, telephone number, and/or address);
• transaction information, including bank account and payment information where applicable and subject to applicable law;
• chat and other information about the people and accounts you interact with;
• gender, age, and/or date of birth;
• information sent by or associated with the device(s) used to access our Services;
• photographs or audio or video content that you submit via the Services;
• location related information, including IP address;
• government issued identification or other identification you share with us, where applicable;
• marketing and communications data, such as your preferences in receiving marketing materials, your communication preferences and history of communications with us and our service providers;
• any other information about you provided when you sign up or use the Services, including information shared via anyother credentials; and
• usage and transaction data, including data on your activities, orders, use of the Services and the advertising and other content you engage with.
2.3 You agree not to submit any information to us which is false, inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. Subject to applicable law, we reserve the right at our sole discretion to require further documentation to verify the information provided by you.
2.4 If you sign up to be a user of our Services using other credentials, we may access information about you which you have voluntarily provided to your other credentials’ provider in accordance with such provider's policies, and we will manage and use such personal data in accordance with this Privacy Policy at all times.
2.5 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing. Further information on opting out can be found in the section below entitled "How can you withdraw consent, remove, request access to or modify information you have provided to us?". Note, however, that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services.
3. COLLECTION OF OTHER DATA
3.1 As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you use our Services. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our Games and Site.
3.2 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more purposes including, without limitation, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or the device manufacturer.
3.3 As when you view pages or content on our Site or mobile application, most of the same information is sent to us (including, without limitation, IP Address, information about your operating system, etc.); but, instead of page views, your device sends us information on the content, advertisement viewed and/or software installed and time.
4. COOKIES
4.1 We or our authorized service providers and advertising partners may from time to time implement "cookies" or other features to allow us or third parties to collect or share information in connection with your use of the Services. These features help us improve our Services we offer, help us offer new services and features, and/or enable us and our advertising partners serve more relevant content to you, including through remarketing, subject to applicable law. “Cookies” are identifiers we transfer to your computer or mobile device that record data about your computer or device, how and when the Services or websites are used or visited, by how many people and other activity within our Site and Games. We may link cookie information to personal data. Cookies may also link to information regarding what items you have selected for purchase, pages you have viewed, or games you have played. Depending on the relevant Services, this information may be used to keep track of your shopping cart, to deliver content specific to your interests, to enable us or our third party advertising partners to serve advertisements through the Services or on sites across the internet, and to monitor usage of the Services.
4.2 You may refuse the use of cookies or web beacons by selecting the appropriate settings or adjusting your preferences on your browser or device. However, please note that if you do this you may not be able to use the full functionality of our Site, Games or the Services.
4.3 You may also be able to opt out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.
5. USAGE OF PERSONAL INFORMATION
5.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
(a) to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;
(b) to manage, operate, provide and/or administer your use of and/or access to our Services(including, without limitation, your preferences), as well as your relationship and user account with us;
(c) to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
(d) to protect personal safety and the rights, property or safety of others;
(e) for identification and/or verification;
(f) to enforce, maintain and administer and improve our Services, including to troubleshoot, report, or address any issues (e.g., to respond to errors or crash reports) that may be required from time to time to ensure the smooth running of the our Services;
(g) to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;
(h) to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(i) to allow other users to interact, communicate, or connect with you, including to inform you when another user has sent you a private message or posted a comment for you via the Services;
(j) to allow for audits and surveys (via offline and online surveys, including on third parties platforms, among other things, validate the size and composition of our target audience, and understand their experience with STARLIGHT GAMING’s Services;
(k) for marketing and advertising for any marketing activities where permissible under applicable law, and in this regard, to recommend products and/or services relevant to your interests, to send you by various mediums and modes (including email or SMS) of communication marketing and promotional information and materials relating to Services that STARLIGHT GAMING may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters or marketing materials from us;
(l) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on STARLIGHT GAMING or on its related corporations or affiliates;
(m) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
(n) to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
(o) to audit our Services or STARLIGHT GAMING's business;
(p) to prevent or investigate any actual or suspected violations of our Terrms and Conditions, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
(q) to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
(r) to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves STARLIGHT GAMING as a participant or involves only a related corporation or affiliate of STARLIGHT GAMING as a participant or involves STARLIGHT GAMING and/or any one or more of STARLIGHT GAMING's related corporations or affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal, transfer of or financing of an organisation or a portion of an organisation or of a portion of or all of any of the business, business activities, or assets of an organisation; and/or
(s) to verify your qualification and/or to submit your application/request when you register for participation in the game specific contests, events or tournaments, and to give you rewards where applicable; and
(t) other purposes which are permissible under applicable law and which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”).
5.2 You acknowledge, consent and agree that STARLIGHT GAMING may access, preserve and disclose your Account information and Content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over STARLIGHT GAMING or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over STARLIGHT GAMING, (c) enforce the STARLIGHT GAMINGTerrms and Conditions, or this Privacy Policy or other Terms enter between you and STARLIGHT GAMING; (d) respond to any threatened or actual claims asserted against STARLIGHT GAMING or other claim that any Content violates the rights of third parties; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of STARLIGHT GAMING, its users and/or the public.
5.3 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.
6. THE PROTECTION OF PERSONAL INFORMATION
6.1 We implement a variety of security measures and operational controls, and we strive to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security.
6.2 We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interest warrant further retention of such personal data. If you cease using our Services, or your permission to use the Services is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.
7. DISCLOSURE OF YOUR PERSONAL INFORMATION
7.1 In conducting our business, we will/may need to disclose your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, for one or more of the above-stated Purposesunder applicable laws and regulations. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Such third parties include, without limitation:
• our subsidiaries, affiliates and related corporations;
• other users of our Services in connection with your use of the Services and for one or more of the above-stated Purposes;
• contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as mailing houses, our game development partners, payment or financial services providers, advertising and marketing partners, telecommunication companies, game development partners, information technology companies, and data centres;
• governmental or regulatory authorities having jurisdiction over STARLIGHT GAMING or as otherwise permitted under Section 6.2;
• a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of STARLIGHT GAMING’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, or transition of any of our Services, in which personal data held by STARLIGHT GAMING about our users is among the assets transferred; or to a counterparty in a business asset transaction that STARLIGHT GAMING or any of its affiliates or related corporations is involved in, including any entity which succeeds or to which we transfer the operation of any of our Services; and
• third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.
7.2 We may, among other things, disclose your gaming history and/or disclosing records showing which games were viewed or accessed by which IP addresses. We may also share statistical and demographic information about our users and their use of the Services with advertising partners and third party suppliers of advertisements, remarketing, and other programming subject to applicable law.
7.3 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply.
7.4 Third parties may unlawfully intercept or access personal data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.
8. INFORMATION ON CHILDREN
8.1 The Services are not intended for children under the age of 13. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 13 nor is any part of our Services directed to them. As a parent or legal guardian, please do not allow such children under your care to submit personal data to STARLIGHT GAMING. In the event that the personal data is identified as a child under the age of 13 within the Services, We will not collect, store or use such personal information, and will promptly delete such personal information in a secure manner.
9. LINKS TO THIRD PARTIES
9.1 The Services may contain links to the websites, applications, products or services to third parties. STARLIGHT GAMING is not responsible for the privacy practices or the content of such websites, applications, products or services. Based on your acceptance provided to such third parties, they may collect information from you..
9.2 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked websites, applications, products or services. These links are only for your convenience and you. It is to our suggestions that you shall read the privacy policies of such applications, websites or services before you submit any personal information.
10. OVERSEAS TRANSFER OF YOUR PERSONAL INFORMATION
10.1 Your personal data will be processed and stored in our servers in India. STARLIGHT GAMING will only transfer your information overseas in accordance with Privacy Laws, and you hereby consent to such transfer and processing.
11. WITHDRAW CONSENT, REQUEST ACCESS TO OR CORRECT PERSONAL INFORMATION YOU HAVE PROVIDED
11.1 Withdrawing Consent
11.1.1 You may withdraw your consent for the collection, use and/or disclosure and/or request deletion of your personal data in our possession or under our control by sending an email to our Data Protection Officer at service@starlightgaming.in. We will process such requests in accordance with this Privacy Policy and our obligations under applicable Privacy Laws and other applicable law.
11.1.2 However, your withdrawal of consent and/or request to delete personal data in in our possession or control may mean that we will not be able to continue providing the Services to you, and we may need to terminate your existing relationship and/or the contract you have with us.
11.2 Requesting Access to, or Correction of personal information
11.2.1 If you have an Account, you may personally access and/or correct your personal data currently in our possession or control through the account settings page through Services. If you do not have an account with us, you may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Please submit your written request by sending an email to our Data Protection Officer. In addition, where required by law, we will take steps to inform any third parties who have received or used your personal information of such correction.
11.2.2 Where permitted under applicable law, we reserve the right to reject certain requests and/or may charge you a reasonable fee for the handling and processing of your requests to access your personal data. In such cases, we will inform you and will provide you with a written estimate of any applicable fees. Subject to applicable law, will provide you the requested personal data within a reasonable time after you pay the applicable fees.
11.2.3 Please submit your written request by sending an email to our Data Protection Officer. Subject to applicable law, we reserve the right to only respond to data subject requests submitted in accordance with this Policy.
11.2.4 Erasure
You have the right to request that we erase the personal information we hold about you.
However, we may retain thepersonal information if there are valid grounds under applicable law for us to do so (e.g., for the exercise or defense of legal claims, where we have a legal obligation or right to retain certain information, freedom of expression, etc.).
11.2.5 Retention of personal information
We may retain your personal information as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws or for the exercise or defense of legal claims.
11.2.6 Objection against Profiling and Targeted Marketing
At any time you have the right to object to our processing of personal information about you in order to send you promotions, special offers and marketing messages, including where we build profiles for such purposes and we will stop processing the personal information for that purpose.
For any issues in relation to the collection and processing of your personal information, you may reach out to ourData Protection Officer at service@starlightgaming.in. The Data ProtectionOfficer will respond to your concerns and queries at the earliest and in compliance with applicable law.
