Privacy Policy

  1. General

    (1) This Privacy Policy forms part of the Terms of Use for the website, www.halaplay.com(‘Website’), an online daily fantasy sports platform and the Halaplay App available onGoogle Play, App Store and website (‘App’) (collectively referred to as the ‘Services’)offered by Halaplay Technologies Private Limited (hereinafter referred using ‘our’, ‘we’, ‘us’or ‘HalaPlay’).

    (2) This Privacy Policy governs the access, collection, usage, handling, storage and disclosureof such personal information during the course of the usage of the Services by any personaccessing or using the Services (hereinafter referred using ‘you’, ‘your’, ‘user’).

    (3) In carrying on business as an on-line Daily Fantasy Sports platform, HalaPlay, collectspersonal information about people who:

    1. apply to become or are HalaPlay members;

    2. visit our website www.HalaPlay.com, or use our services;

    3. send us queries or information;

    4. provide services to us or on our behalf;

    5. apply to become or are our employees; and

    6. provide services to us or on our behalf.

    (4) HalaPlay is committed to ensuring that the personal information it collects is collected,used, disclosed and protected in accordance with this Privacy Policy.

    (5) In this Privacy Policy, 'personal information' means any information about an identifiedindividual, or an individual who is reasonably identifiable (whether the information is true ornot, and whether it is recorded in any form or not).

    (6) Before you submit any information to us, please read this Privacy Policy to understand howwe will treat your personal information. By using any part of the Services, you consent tothe collection, use, storage, processing, disclosure and transfer of your personal informationfor the purposes outlined in this Privacy Policy and to the collection, processing andmaintenance of such personal information.

    (7) HalaPlay may review, change or update this Privacy Policy periodically and reserves theright to change the Privacy Policy at any time at its discretion by posting such changes onthe Website or App. We will publish our current Privacy Policy on the Website or App andchanges will take effect immediately at the time of publication. Your continued use of theServices following publication will constitute your acceptance of those changes. You shouldreview this Privacy Policy regularly and remain familiar with its terms.

    (8) If you do not agree to this Privacy Policy, please do not use the Services. Your use of anypart of the Services indicates your acceptance of this Privacy Policy.

    (9) While you have the option not to provide us with certain information or withdraw consent tocollect certain information, kindly note that in such an event you may not be able to takeadvantage of the Services and we reserve the right not to provide such Services to you.

  2. Collection of Personal Information

    (10) If you apply to be, or are, a HalaPlay member, we collect personal information about you inthe following circumstances:

    1. If you wish to subscribe to HalaPlay’s newsletter;

    2. to process your application for HalaPlay membership;

    3. to provide member services to you;

    4. to identify you as a member for security purposes and to comply with our legal obligations;

    5. to maintain and manage your account;

    6. to upgrade and enhance your experience when using our website;

    7. to tailor or develop information, services or products which we think may suit your needs

    8. to communicate with you; and

    9. to share any important updates with you; and

    10. for marketing related purposes, including conducting research, conducting promotions,sending you newsletters and informing you (including via email, SMS or telephone)about products or services we think may be of interest to you.

    (11) The kinds of personal information that HalaPlay generally needs to collect about HalaPlaymembers and applicants for membership are:

    1. name

    2. residential address

    3. date of birth

    4. gender

    5. email address

    6. phone number(s)

    7. personally-submitted preferences

    8. bank account and credit card information

    9. Permanent Account Number (PAN)

    10. financial information

    11. identity verification information

    12. recordings of all website activity and emails

    (12) We will ordinarily collect your personal information directly from you, primarily through youruse of the Services or over the telephone.

    (13) We may also collect personal information indirectly, for example, through agents or affiliateswe engage to undertake marketing activities.

    (14) We are also required by law to collect some personal information about people who use ourServices.

    (15) We may also collect personal information from job applicants, our employees and individuals associated with our business partners and service providers. Usually thisinformation is limited to name and contact details and the other information we need for thepurpose of managing the employment or business relationship.

    (16) When you visit the Services, certain information may also be automatically collected andstored, including the IP address of your computer, browser type and language, the date andthe time during which you accessed the site, the address of the domain name which youmay have used to link to the Services.

  3. Cookies

    (17) When you visit the Services, cookies may be left on your computer. Cookies are pieces ofdata stored by your web browser on your hard drive which contain information relating toyour use of the website. When you access the website, cookies may record details relatingto your use of the website, including what pages you view from the website. HalaPlay usescookies for the detection of fraud, statistical analysis, systems administration and internalmanagement purposes only.

  4. Disclosure of Personal Information

    (18) HalaPlay will not disclose, trade, sell or rent your name, e-mail address or other personalinformation provided by you on this site to any third party or information related to yourusage of the Services, except as provided in this Privacy Policy.

    (19) HalaPlay only uses and discloses your personal information for purposes that are related tothe purposes for which we have collected the information. For HalaPlay members and applicants for membership, this means we mainly use personal information for purposesconnected with establishing and administering the membership and providing services andproducts related to the Services.

    (20) HalaPlay may use your personal information to create aggregate data about HalaPlaymembers through demographic profiling and statistical analysis of its database, in order toallow for more efficient operation of HalaPlay’s business. We may provide the informationderived from such profiling or analysis in an anonymized form to potential and existingstakeholders. The Services may use software applications for monitoring traffic and itsanalysis and to gather statistics, used for advertising and for determining the efficacy andpopularity of the Services among others.

    (21) We reserve the right to conduct a security review at any time to validate your identity, age,and the registration data provided by you and to verify your use of the Services as well asyour financial transactions for potential breach of our Terms of Use and of applicable law.By accepting our terms and conditions upon registration, you have given consent forwww.HalaPlay.com to disclose your name, residential address and date of birth to a thirdparty service provider to provide an assessment of whether the personal information soprovided matches (in whole or in part) personal information contained in the identificationverification and other official documents provided by the User. The third party serviceprovider may prepare and provide HalaPlay.com with such an assessment and may useyour personal information including the names, residential addresses and dates of birthcontained in credit information files of you and other individuals for the purposes ofpreparing such an assessment.

    (22) All transactions are processed through a gateway provider and are not stored or processedon our servers. By accepting this Privacy Policy, you expressly consent to your personalinformation being shared with electronic payment gateways / processors and/or financialinstitutions, as necessary, solely for the purpose of processing the relevant financialtransactions. We make our best efforts to ensure that our arrangements with theseelectronic payment gateways / processors and/or financial institutions protect your privacy.

    (23) HalaPlay may disclose your personal information:

    1. to our agents and affiliates who undertake promotional and marketing activities on our behalf (including contacting you with special offers that may be of interest);

    2. to organisations that provide services (including IT, consultancy and advisory services) to HalaPlay;

    3. to any particular third parties or classes of third parties that HalaPlay notifies you at the time of collecting your personal information that your personal information may be disclosed to;

    4. for taking appropriate action if we have reason to suspect that unlawful activity or misconduct of a serious nature in relation to our Services has been, is being or may be engaged in;

    5. to protect and maintain the integrity of particular sports, by assisting controlling bodies in their inquiries or notifying such bodies of any activity HalaPlay considers to be unusual or suspicious;

    6. where you have consented to the disclosure either expressly or by the circumstances and your conduct;

    7. where we consider disclosure is reasonably necessary to eliminate or minimise a risk to public health or safety;

    8. where we consider disclosure is reasonably necessary to investigate or deal with unlawful activity or serious misconduct;

    9. where we consider disclosure is reasonably necessary to locate missing persons;

    10. to establish or defend a legal claim; and

    11. where such disclosure is required or authorised by law.

    (24) HalaPlay will take all reasonable steps to ensure that any personal information which is disclosed to a third party (other than law enforcement agencies or regulators) is protected by that party in accordance with this Privacy Policy and is used only for the prescribed purposes. Usually we do this by imposing contractual requirements on or seeking assurances from third parties as to their compliance our Privacy Policy.

    (25) HalaPlay does not disclose personal information to persons outside India.

  5. Direct marketing and opting out

    (26) When registering as a HalaPlay member, you may choose to receive promotional or marketing information from HalaPlay by selecting the appropriate option on the registration page. If you do, from time to time we may use your personal information to inform you about HalaPlay's products or services or about promotional activities, which HalaPlay believes, may be of interest or of benefit to you. We may do this via email, SMS, telephone or mail.

    (27) If you no longer wish to receive marketing or promotional material from HalaPlay at all or in any particular form, you may contact us at any time by email to care@halaplay.com with your request with which we will comply as soon as is practical. Where we send you commercial electronic messages for direct marketing purposes, each message will contain a functional means for you to opt-out of receiving such messages.

    (28) From time to time we may contact you in relation to the management and administration of your HalaPlay account. These communications can be via any of the modes of contact recorded when registering as a Member. Such communications is not affected by your opt-in or opt-out status for direct marketing communications.

  6. Third Party Web Links

    (29) This Privacy Policy will not apply to other websites which are linked to the website and over which HalaPlay has no control. HalaPlay is not responsible for, the use of, or the protection of information provided to, such websites. It is your responsibility to read and understand the privacy policy of such third party websites when you follow a link outside the Services.

  7. Management and security of personal information

    (30) When you register with the Services, your account is protected by means of your login information which includes a username and a password that is known only to you. Therefore, you are responsible for maintaining the confidentiality of your login information including your username and password.

    (31) You acknowledge that no data transmission over the Internet is totally secure. Accordingly, HalaPlay does not warrant the security of any information, which you transmit to it. Any information that you transmit to HalaPlay is transmitted at your own risk.

    (32) You further acknowledge that Information posted on bulletin boards or communicated within a social media environment (for example, Facebook, Twitter, Chat Rooms) becomes public information. HalaPlay does not guarantee the security of this type of information.

    (33) HalaPlay will take all reasonable steps to ensure that the personal information, which it collects, uses or discloses, is correct and is stored in a secure environment that is accessed only by authorised persons.

    (34) Your personal information may be retained and may continue to be used by us till such time (a) you access and use the Services; (b) for any period thereafter as may be required by any applicable law, or contractual obligations (c) and for any period wherein the retention of your personal information is required for the establishment, exercise or defence of any legal claim.

    (35) HalaPlay will destroy or permanently de-identify personal information when it is no longer required for any purpose permitted under this Privacy Policy, including our legal or operational obligations. HalaPlay holds personal information in electronic databases owned and operated by HalaPlay.

    (36) By using the Services, you understand that your personal information may be transferred to countries other than India.

    (37) Once HalaPlay receives your transmission, HalaPlay will take reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification and disclosure including by using password protected systems and databases and Secure Socket Layer ("SSL") technology.

    (38) HalaPlay’s employees, agents and contractors are required to maintain the confidentiality of members' personal information.

  8. Personal information about children

    (39) Persons under the age of 18 (‘Children’) are not accepted as HalaPlay members and are excluded from access to our Services.

    (40) We will not accept their information for the purposes of opening an account. It is however, ultimately the responsibility of parents or guardians to monitor their children’s Internet activities including where appropriate by using Internet screening software.

    (41) If a parent or guardian becomes aware that his or her child has provided us with their personal information without the parents’ consent, in violation of the above terms, he/she should immediately contact us at care@halaplay.com. We will delete such information from our files within a reasonable period from receiving such complaint.

  9. Access to and correction of personal information

    (42) We give you the opportunity to correct and update personal information at any time, and may contact you on a periodic basis to seek the most up-to-date information from you.

    (43) If you believe that the personal information HalaPlay holds about you is inaccurate, incomplete or not current, please let us know and we will investigate and correct any inaccuracies if we are satisfied that a correction is required. Your personal information can be updated or corrected by you in the "Account Details" section of the website at any time after you log in. If there are any details you wish to update which you cannot please contact care@halaplay.com.

    (44) You are responsible for the security of and access to the Services. You must log out of your account when you have completed your time on the website, and should not disclose your username, password or any account information to any other person.

    (45) You may access personal information about you held by HalaPlay by following the “My Account” link on the website or by contacting us at care@halaplay.com. To do so, you will need to provide evidence to confirm your identity before we can provide access. We will generally respond to all requests for access within 30 days of the request. If your request is particularly complex, or requires detailed searching of our records, there may be a cost to you in order for us to provide the information.

    (46) Details of your transactions, deposits and withdrawals can also be accessed via the "Transactions" tab of the "Account Balance" section.

    (47) However, we may refuse a request for access in certain circumstances set out in the Privacy Policy, including where: providing access would be unlawful; we are required or authorised to do so by or under an Indian law or court/ tribunal order; or where giving access would be likely to prejudice enforcement related activities by or on behalf of an enforcement body.

    (48) If we refuse your request or cannot give you access in the manner you have requested, we will do what we can reasonably do to meet your requirements by other means. If we refuse access to your personal information, we will advise you in writing of the refusal, the reasons for the refusal, and the complaint mechanisms available to you.

  10. Complaints and further information

    (49) If you believe your privacy has been interfered with and you wish to make a complaint, please contact our Compliance Manager / Grievance Officer (contact information below). The Compliance Manager will investigate your complaint and notify you of the outcome. If your complaint indicates that there has been an interference with your privacy by a person other than HalaPlay, the Compliance Manager may discuss your complaint with that other person in an attempt to resolve it. Please email to care@halaplay.com for the same.

    (50) If you have any queries, requests for access or correction or further information on our Privacy Policy, or if you have any concern about the handling of your personal information or wish to make a complaint, please contact care@halaplay.com.

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