Legal/Privacy

1. Octro Inc. along with its corporate affiliates and group companies worldwide (hereinafter collectively referred to as the “Company”, “We”, “Us”, “Our” or “Octro”) has a mission to connect the world through games. We deliver fun, social entertainment experiences to people across the globe by developing and publishing online games for website and mobile devices. In pursuit of Our mission, We collect and use certain information from Our users. However, while doing so We respect an individual’s privacy and are committed to protecting the same. This Data Privacy Policy (“Policy”) describes how We collect, use, disclose and transfer Personal Data (as defined below), through Our websites and mobile applications, and/or other domains or platforms operated by Octro currently including
1. https://www.octro.com
2. https://teenpatti.octro.com

and which may be used by the Company in future (collectively referred to as the “Platform”) of the individuals who browse, or access the Platform or provide information on or through the Platform, or whose information the Company otherwise collects, receives or processes in connection with its Services (as defined below) (hereinafter, collectively referred to as “Users”, “You”, “Your”, “Players”).

2. This Policy applies to You when You use Our services which includes Our games, products, content, Platform and applications that reference this Policy (hereinafter referred to as “Services”).
3. Your Acceptance: By accessing and / or using Our Platform, the Services and providing the information as explained in this Policy, by creating an account on the Platform or by agreeing to the terms of this Policy, You understand that We will collect and use Your Personal Data as described in this Policy. We encourage You to read this Policy regarding the collection, use, and disclosure of Your Personal Data. If you are not comfortable with any of the terms or policies described in this Policy, you may choose to discontinue usage of Our Platform and Services.
4. This Policy is an electronic record in the form of an electronic contract. Further, this Policy is published and shall be construed in accordance with the provisions of applicable laws including but not limited to GDPR, CCPA, COPPA, DOPPA, IT Act and IT Rules (each of them as defined below), each of which mandates publishing of a privacy policy by an entity which collects, uses, stores and/or transfers sensitive personal data or information.
5. This Policy is a legally binding document between You and the Company. The terms of this Policy will be effective upon Your acceptance of the same (directly or indirectly in electronic form, by clicking on the “I accept” tab or by use of the Platform or by other means) and will thereafter continue to govern the relationship between the Company and You during Your use of the Platform and the Services. Should You disagree with this Policy and still continue to use the Platform and provide Your Personal Data, the Company disclaims any and all liabilities arising therefrom, and it shall be assumed by Your continued use of the Platform that You have accepted this Policy and any other online terms and conditions, including the terms of service available on the Platform.
6. This Policy does not cover any information that We may receive about You through sources other than the use of our Platform and Services. The Platform may link out to other websites or mobile applications, but this Policy does not and will not apply to any of those linked websites or applications.
7. For the purpose of this Policy, the following terms used herein shall have the meaning ascribed to it below:

European Countries: This shall include countries in the European Union (EU) and the European Economic Area (EEA) and Switzerland;

GDPR: GDPR shall mean the General Data Protection Regulations, applicable as of May 25, 2018 in all member states of European Union (EU) to harmonize data privacy laws across Europe;

CCPA: The California Consumer Privacy Act of 2018;

COPPA: The Children’s Online Privacy Protection Act;

DOPPA: The Delaware Online Privacy and Protection Act;

IT Act: The Information Technology Act, 2000;

IT Rules: The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;

Personal Data: It refers any information about an individual which can be used to distinguish or trace an individual’s identity or any other information that is linked or linkable to an individual. Examples included but not limited to name, an identification number, an online identifier, location data, or one or more factors specific to the physical, physiological, mental, genetic, economic, cultural or social identity of that natural person and any other information that is so categorized by applicable laws. Personal Data includes the information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

8. If You are based in European Countries, please note that for the purposes of data protection laws, the Company may act as the “data controller” or as a “data processor” depending on the Service being provided and the amount of control the Company has over the purpose(s) and means of the data processing.

When You submit Your Personal Data on Our Platform:

1. Registered Users: The Company collects, processes and stores the Personal Data that You provide while using Our Platform, including when You enter Your Personal Data into data fields on the Platform as part of the registration process. For example, You may submit Your name, postal address, e-mail address, and/or other information in order to register or while using Our Platform and Services. To protect Your privacy, You should not provide the Company with any information that is not specifically requested or that You do not wish to share. You may choose not to provide certain information, but then You might not be able to use Our Platform or certain features of Our Platform.

By undergoing the registration process, You consent to Us collecting Your Personal Data, including the Personal Data described in this Section.

2. Unregistered Users: If You are a passive user of the Platform and do not register for any Service (“Passive User”), You may still be subject to certain passive data collection as set out in Section 2.2 and Section 2.5 below.

3. Automatic collection/Information You generate using Our Services: We also automatically collect and store certain types of information/data whenever You interact with Us, including as a Passive User. Such information includes information about Your use of the Platform and Your interaction with the Services available through the Platform. Like many Platforms, unidentifiable information may be collected using various technologies, such as cookies, internet tags, action-tags, single-pixel gifs and web beacons or similar means (“Pixel Tags”) to compile aggregate statistics about the Platform usage and response rates. Pixel Tags enables the Company to maintain a count of the Users who have visited certain pages of the Platform. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and as to when the email was opened and read by the receiver of the e-mail.
4. Information obtained from third party applications: If You play Our games or access any of Our other Services on connected third-party applications or connect Our Services to any third-party applications, including social networks like Facebook, etc. the Company may receive certain Personal Data about You from the provider of such third-party applications. We may also receive information, such as marketing related or demographic information about You from third parties to enhance our ability to tailor Our content and offer You the Services that We believe may be of interest to You. The information We receive depends on which of Our games you’re playing, the third-party application, Your privacy settings, and, if applicable, Your friends’ privacy settings on that third-party application. The Company is not responsible for the privacy practices of such third-party websites which it does not own, manage, operate or control.
5. Other Sources: We also collect Your Personal Data from third party service providers. We use this information along with information You provide Us directly, for example, to help You and Your friends connect or to serve advertising more tailored to Your interests.
6. Our Services also collect information about Your interactions, including navigation paths, search queries, crashes, timestamps, purchases, clicks and shares and referral URL of the Platform You just visited and the browser version Your computer is operating. The passive information may be collected by the Company through its Platform or received from other sources or third party tools. Such passive information collection technologies can make use of the Platform easier by allowing the Company to provide better Service, customize sites based on consumer preferences, compile statistics, analyze trends, and otherwise administer and improve the Platform. Certain features of the Platform may not work without use of passive information collection technologies. Information collected by these technologies cannot be used to identity You without additional identifiable information. We may also receive/store information about Your location and Your mobile device, including a unique identifier for Your device.

The use and the collection of the Personal Data by the Company is dependent upon how the User interacts with the Platform and/or avail Our Services. For clarity, We collect the following categories of Personal Data in the following ways:

1. During traditional registration or account set-up process, to help Us to identify You or help Us to provide or improve Our Services;
2. When You create a Player profile that other Users of Our Platform can see. Your Player profile may include information like Your profile picture, first and last name, mobile number, game username, gender, biographic details (like Your age or age range), the approximate physical location information that You provide, links to Your profile on various social networks, details about the games You play, and/or an Octro Player ID that is created by Octro and used to identify Your game account on Our Platform;
3. Through the use of Our Platform, We may give You the ability to import Your address book contacts or to manually enter them so that You can locate Your contacts using the Company’s Services and invite them to join You in Our games or other aspects of Our Services. You are responsible for ensuring Your collection and sharing with Us of Your contact information and that it is compliant with applicable laws. This may require You to get Your contact’s permission before You give their contact details to Us. We may also get information about You from other Octro Users importing or entering their contacts. We use and may store this contact information to help You and Your contacts connect through our Services. If You want to remove Your contacts stored by us, follow any instructions provided in the Service to request that We remove them from Our systems or contact Us in the information given below;
4. Your participation in player forums and message boards;
5. Your public posts or comments on other Players’ profiles or gameboards;
6. Your non-public messages or invitations to other Players/Users, made either directly on Our websites or through in-game mechanisms;
7. Your chats with other Players (whether by instant message, live chat or video);
8. Your posted photos, drawings or other User-generated content;
9. Information received from third party applications including social media networks such as – Your first and last name, profile picture, User Identification Number, Your friends; User ID numbers, age, gender, email address used by You on such third party application, information about Your activities on or through the connected third party-application, any information that You or the provider of the third-party application share with the Company;
10. Payment Information: In case You purchase-in-game virtual currency or items in a game You play on any of Our Platform/s, Our third-party payment processor will collect the billing and financial information it needs to process Your charges. This may include Your postal address, e-mail address, and financial information. The payment processors engaged by the Company do not share Your financial information, like credit card numbers, with the Company, but they may share non-financial information with Us related to Your purchases, like your name, billing address, and the items purchased.

When You play Octro’s games or access any of Our other Services on connected third-party applications or Platforms (like Facebook, Apple, Google, or Amazon), any purchases You make will be processed by that third-party application and subject to that third-party application’s terms of service and privacy policy. For these purchases, the Company does not receive Your financial information, but may receive non-financial information related to Your purchases, like Your name, approximate physical location, and the items purchased. The information Octro receives depends on the Octro game You’re playing and the third-party application. Our policies and terms related to charges, billing, third-party credits, and virtual currencies are explained in the terms of service and this Policy. Please note that purchases of any third-party credits or currencies are also subject to those parties’ terms of service and privacy policies.

11. Customer Support Correspondence: When You ask for help from Our customer support team, We will collect and store the contact information You give them (generally Your name and e-mail address), information about Your game play or activity on Our Services, and Your Octro player and/or social network ID number. We will also store the communications You have with Our Customer Service team and any additional information in those communications for training purposes and in order to improve the Services provided by Us. We recommend You not to share any financial information, such as credit card number, OTPs, login passwords and other sensitive information in Your correspondence with Our customer support team.
12. We use information collected from cookies and other technologies (e.g., beacons, pixel tags, clear gifs, and device identifiers), to improve Your experience and the overall quality of Our Services (for more information please refer to paragraph on cookies policy below). When showing You tailored ads, We will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health. We also allow Our service providers and others to use cookies and similar technologies on Our Platform to collect and analyse certain kind of technical information including IP address, type of computer or mobile device the User is using; mobile device identifiers (for instance MAC address, apple identifier for advertising and/or android advertising ID); Your browsing type and language, number of clicks on app feature or webpage, URLs, pages viewed, time spent on each of those pages etc.

We shall use Your Personal Data in a fair and reasonable manner, and where We have a lawful reason to do so. Our use of Your Personal Data depends on the purpose for which You interact with Us. We may process Your Personal Data for the following purposes:

1. To create Your game accounts and allow You to play Our games;
2. To improve and optimize our Services and our Players’ experiences;
3. To identify and suggest connections with other Octro players and personalize Our Services to You;
4. To provide technical support and respond to Player inquiries (live chat, email or phone inquiries);
5. To enable Players to communicate with each other;
6. To protect the safety and well-being of our Players;
7. To protect Octro’s rights and property in connection with our Services;
8. To administer rewards, surveys, sweepstakes, contests, or other marketing/ promotional activities or events sponsored or managed by Us or Our business partners;
9. To conduct internal research on Our User’s demographics, location, interests, and behavior to better understand and serve You and improve Our Platform;
10. Allow You to log in with a social media account and share activities on Your social media pages;
11. To communicate with You about the Services You’re using, including in-game updates, new Services, and promotional offers that We think might be of interest to You;
12. Meet any applicable law, regulation, legal process or enforceable governmental request;
13. Establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings;
14. Preventing, detecting, investigating and taking action against crimes (including but not limited to fraud and other financial crimes), any other illegal activities, suspected fraud, or violations of Company’s terms of service in any jurisdiction;

The legal basis on which We collect Your Personal Data:

1. Performance of a Contract: Processing of some of the Personal Data is necessary for the performance of Our agreement with You. It is contractually necessary to process Your Personal Data (such as username, email, password, cookie data, IP address and other similar information) to fulfil Our obligations as provided in Our terms of service i.e.to provide You with high quality games and a social game network from ourselves and Our affiliates.
2. Legitimate Interests: Legitimate interests will include where We believe You have a reasonable expectation that We will perform a particular type of processing on Your behalf. We have legitimate interest in (i) conducting analytics, measurement of usage, game telemetrics to provide more customized experience for Our Users and Platform visitors (ii) storing User’s purchase history to improve Our Services and for the purpose of providing Users help in fixing payment related issues; (iii) enabling third party ads, data collection on Our Platform and marketing/promotion activities to inform Users of updates and offers; (iv) storing and processing Your Personal Data for fraud detection and prevention on Our Platform.

We make clear disclosures when Users sign up on Our Platform and offer opt outs for anyone not interested (as discussed below)

3. Compliance with a legal obligation: Our processing of Your Personal Data is necessary in order to allow Us to comply with a legal obligation or to protect vital interests of Our Users. For instance, where We are required to retain business records for fixed periods of time in order to comply with local legal requirements.
4. Consent: In certain limited situations, We rely on Your consent in order to process Your Personal Data. We seek Your consent at the time of provision, and such processing will only be performed where consent is secured. For instance, We obtain consent for the processing of data for chatrooms and any optional profile information, or where Users log in with social media accounts. Consent is also obtained to add and engage with friends and other scenarios as deemed appropriate. You can withdraw Your consent, as per this Policy where applicable, by sending an email to the email id provided in the “Contact Us” section below.

We may share Your data, including Personal Data, with third parties such as other Users, Our affiliates or service providers that perform certain Services on Our behalf or that receive Services from Us. We share Your Personal Data with the following third parties:

1. Your Friends and other Octro Players: In most Octro games, if You play through a social network or connect to a social network (for example, Facebook), Your social network, who also play a Octro game will see Your name, photo, Player profile (which may include the information described above and information about You that You share with Us directly), and descriptions of Your in-game activity.

Further, in several Octro games (For instance, Octro Teen Patti), other players regardless of whether they are Your social network friends will be able to see Your player profile, view description of Your in-game activity, communicate with You within Our Services and send You game or friend requests through Our Platform or related social media network.

2. With our group companies and affiliates: We may share Your Personal Data within the Octro group of companies to enable the Octro group to carry out the purposes set out in this Policy and Our terms of services.
3. Third party service providers who perform Services on Our behalf based on Our instructions such as payment processing, analytics, hosting services, customer service, marketing and advertising optimization and includes Our third-party business partners such as Apple, Google, Facebook etc. However, these service providers will not be authorized to use or disclose such Personal Data except as necessary to perform Services on Our behalf or comply with legal requirements.
4. Third-party advertising including behavioral advertising and analytics: We use third party advertising to enable Us to offer some of Our games/game features, and other Services for free. These advertisements may include, without limitation, banner ads on game boards or Services themselves, as full-screen ads between moves or games, or through an “offer wall” in which third-party advertisers offer to provide virtual currency or other in-game items to Players in exchange for watching an advertisement or for completing a task, such as signing up for an account with one of the advertisers, completing a survey, or finishing a particular game level. Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Octro.

We do not actively share Personal Data that directly identifies You with third-party advertisers for their direct marketing purposes unless You give Us your consent. To enable advertisers, ad networks, and offer wall providers to serve You with more relevant ads, they may collect, or We may collect and share with them via cookies or other similar technologies, certain information including performance data (like the number of clicks on an advertisement); technical information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID); a unique identifier (such as social network ID, Octro player ID) and or other contextual data about Your game play.

Please note, after clicking on a third-party advertisement or offer, You may no longer be on a site or app controlled by Octro or the social network through which You are playing Octro games. The practice of third-party advertisers on our Servicers are subject to their own privacy policy and terms of services.

1. Should We plan to merge/sell all or substantially all of Our business to another business entity or similar other transaction or be required by that business entity, We may transfer or disclose Your Personal Data to that business entity who may collect, use, process or disclose such information for the purposes of evaluating the proposed transaction or for operating and managing the affairs of the acquired business or for other purposes identified in this Policy.

3. We may share Personal Data with Our other corporate entities who may use the said data in accordance with this Policy to help detect and prevent identity theft, fraud, and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of Our Platform. If You have any objection to such sharing, then We request not provide Us with any information.
4. Notwithstanding anything contained in this Policy, We may disclose Personal Data if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to any court orders or other legal processes. We may disclose Personal Data to law enforcement offices, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to: (a) enforce Our terms of service or this Policy; (b) respond to claims that an advertisement, posting or other content violates the rights of a third party; (c) respond to any authority, having the right to receive such information under law; (d) or protect the rights, property or personal safety of Our Users or the general public.

1. We may store Your personal data using Our own secure on-site servers or other internally hosted technology. Your Personal Data may also be stored by third parties, via cloud services or other technology, with whom the Company has contracted, to support the Company's business operations. Your Personal Data may be stored and processed in India or other countries outside of where You live or registered as a User, for the purposes as described in this Policy. This is necessary to operate globally and provide our Services to You. These third parties do not use or have access to Your Personal Data other than for cloud storage and retrieval, and the Company requires such parties to employ at least the same level of security that We use to protect Your Personal Data. At present we store Your personal data on secure servers located in California, United States.
2. We retain Your Personal Data for as long as it is necessary to provide Our Services or as long as You have an active account with Us, or until You ask Us to delete Your Personal Data. However, You acknowledge that We may retain some Personal Data after You have closed or We have deleted Your account where necessary to enable Us to meet Our egal obligations or to exercise, defend, or establish Our rights under applicable local laws. If You wish to delete Your Personal Data, You should submit a delete request on the email id provided in “Contact Us” section below. Please note, We may require additional information so as to verify Your identity through the email address or telephone number associated with Your use of Our Platform prior to fulfilling any such request and reserve the right to deny a request where We are unable to satisfactorily complete this process.

1. The Company is a global company, with its affiliates and group companies “Affiliated Entities” located in several countries. Your data may be transferred to Our Affiliated Entities, or to Our business partners and service providers from time to time for legitimate business purposes identified in this Policy.
2. We store Personal Data about Players and visitors to Our Platforms on servers located in the United States and We may also process this information in other countries where Our Affiliated Entities, business partners and service providers have their operations. Personal Data collected in the United Kingdom (“UK”) or European Countries may be transferred to, and stored at, a destination outside of the UK or European Countries (as applicable) for purposes such as: (a) the processing of transactions and Your payment details; or (ii) the provision of customer care Services.
3. When We transfer Your Personal Data internationally, We will take reasonable steps to ensure that Your Personal Data is treated securely, lawfully, and only in accordance with and as permitted by the law of Your home jurisdiction. Please be aware that the laws and practices relating to the protection of the Personal Data are likely to be different and, in some cases, may be weaker than those within Your home jurisdiction. Regardless, in all events, We shall apply the provisions of this Policy to Your Personal Data wherever it is located.

1. We value Your trust in providing Us with Your Personal Data and We will strive to use commercially acceptable means of protecting such information. We take appropriate and reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of Our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where We store Personal Data. All information gathered on Our Platform is securely stored within Our controlled database. The database is stored on servers secured behind a firewall which encrypts information You input; access to the servers is password-protected and is strictly limited.
2. If You have an account registered directly with Octro, Your profile information is protected by the password You use to access Your Octro account. It is important that You protect and maintain Your Octro account’s security and that You immediately inform Us of any unauthorized use of Your account. If You access Our Services through a social network and Your social network account is hacked or otherwise compromised, this may lead to someone accessing or deleting Your Octro game accounts without Your permission. Hence, We urge You to be careful with Your social network account information. We request You to log out of Your Octro account and any social network account You have used to access our Services when you are finished using them.
3. While We take precautions against possible security breaches of Our Services and Our User databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and We cannot guarantee the security of Your information while it is being transmitted to Our Service. Therefore, while We strive to protect Your information, We cannot guarantee its security. We will notify as soon as possible but no later than 72 (seventy-two) hours from when We determine that Our systems have been hacked and Your Personal Data disclosed as a result of such hacking or any other unauthorized breach of Your systems and databases. If You have any questions about the security of Our websites, please reach out to Us via details provided under “Contact Us” section below.

As a User of Our Platform, You may avail Yourself of the rights explained in this section. Please note, We may attempt to verify Your identity through the email address or telephone number associated with Your use of Our Platform prior to fulfilling any such request and reserve the right to deny a request where We are unable to satisfactorily complete this process. If You authorize someone to make a request on Your behalf, We may also deny Your request if We are unable to verify with You that the individual making the request is authorized to act on Your behalf.

In cases where We are data processors, We will forward any requests, inquiries or claims concerning these processing activities to the respective data controller for further assessment and necessary action.

1. Right to access and delete Your data: The Users can access or request deletion of their Personal Data whether or not associated with their game account by sending an email to the email id provided in "Contact Us" section below; We will take reasonable measures to delete Your Personal Data from Our records. We will keep certain records/information pertaining to payment or Service matters wherever necessary in order to ensure compliance with applicable laws or to exercise, defend or establish Our rights.
2. Right to rectify /restrict processing and request portability of Your data: You can correct or update Your Personal Data, object to processing of Your Personal Data, ask Us to restrict processing of Your Personal Data or request portability of the same. You have the right to object to the legitimate interest processing of Your Personal Data for marketing purposes;
3. Opting Out of marketing/promotional communications and withdrawing consent: If You want to stop receiving promotional e-mails from Us, click on the “unsubscribe” link at the bottom of any promotional email from Octro or visit Our email settings page. Your unsubscribe request or e-mail preferences change will be processed promptly and in no longer than 10 (ten) business days. During the processing period, You may receive additional promotional emails from Us.

If You want to stop receiving push notifications, which are messages an app sends You on Your mobile device even when the app is not on, You can turn off push notifications by visiting Your mobile device’s “settings” page. Many of Our games also offer the ability to turn off push notifications in the in-game “settings” page.

You can opt out of receiving SMS text messages by sending an email to the email id provided in "Contact Us" section below. When We receive an opt-out message from You for SMS text messages, We may send a text message confirming receipt.

Please note that if You opt out of receiving promotional communications from Us, We may still communicate with You from time to time if We need to provide You with information about the Services You are using from Us, if We need to request information from You with respect to a transaction initiated by You, or for other legitimate non-marketing reasons, for example, if We are required under applicable laws to notify You of updates to this Policy or Our terms of service.

Withdrawing consent: If We have collected and processed Your Personal data with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We conducted prior to Your withdrawal, nor will it affect processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about Our collection and Use of Your Personal Data, subject to EU GDPR. For more information, please contact Your local data protection authority. (For Users located in European Countries only)

To exercise Your rights to access or deletion, please submit a request through Our Personal Data Request Portal. If You have any problems with the Portal or would like to exercise any of Your other rights, You can send an email to the email id provided in the Contact Us section below. We respond to all data protection requests We receive in accordance with applicable data protection laws.

The Company does not knowingly collect data of children under the age of 13 (or under 16 for children located in the UK or European Countries or under 18 in the State of Delaware) (collectively, “Children” or “Child”). If You are a Child, You must ask Your parent or guardian for permission to use our Platform and/or Our Services. If any Child submits Personal Data to the Company and We learn that the Personal Data is the information of a Child, We will attempt to delete the information as soon as possible. If You believe that We might have any Personal Data of a Child, please inform Us by sending an email to the email id provided in the “Contact Us” section below.

We use third-party analytics services to evaluate Your use of the Platform, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the Platform and mobile and internet usage. These third parties use cookies and other technologies to help analyse and provide Us the information and, in some cases connect such information with other data held by Our, or third party, environments. You consent to the processing of Personal Data about You by these analytics providers in the manner and for the purposes set out in this Policy.

1. We may send one or more cookies or other anonymous identifiers to Your device through the Platform to collect and store information when You visit the Platform.
2. We may use both session cookies, which expire once You close Your web browser, and persistent cookies, which stay on Your computer until You delete them and other technologies to help Us collect data and to enhance Your experience with the Platform. Cookies are small text files a website can use to recognize a repeat visitor to the website. We may use cookies for various purposes, including to:
1. Authenticate Users;
2. Personalize Your experience;
3. Analyse which portions of the Platform are visited or used most frequently; and
4. Measure and optimize advertising and promotional effectiveness.

4. If You do not want Us to deploy cookies in Your browser, You can opt out by setting Your browser to reject cookies or to notify You when a website tries to put a cookie in Your browser software. If You choose to disable cookies in Your browser, You can still use the Platform, although Your ability to use some of the features may be affected.
5. Please note that We do not control cookies in third party advertisements, and You are encouraged to check the privacy policies of advertisers and/or services to learn about their use of cookies and other technology. The ads appearing on the Platform may be delivered to You by third-party advertising companies who may use information about Your visits in order to provide advertisements on the Platform and other websites that might be of interest to You.

Please note that We review and may make changes to this Policy from time to time and as required under applicable laws. We will not reduce Your rights under this Policy without Your explicit consent. When changes are made, the Policy link will include a notation “Last Updated date.” indicating that You should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. The notation will be included in this Policy link for at least seven (7) days after the update has been made. We will also use reasonable efforts to notify You of such change via email address, if such information is provided by the User. By accessing the Platform after any changes have been made, You signify Your agreement on a prospective basis to the modified Policy and any changes contained therein. In case You miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Policy.

1. As a Californian resident, You may exercise the following rights as stipulated in this Section at any point of time in connection with Your Personal Data (in accordance with CCPA).
2. To exercise such rights please submit Your request at the email id provided in the “Contact Us” section below. We might request certain additional information in order to verify Your identity in relation to the request. You must also specify the rights You wish to exercise. We will verify Your request and respond to You within 45 (forty-five) days.
3. Your rights include:
1. Right to know: You have right to request the following information: (i) categories of the Personal Data that We have collected from You over the past 12 (twelve) months and the specific pieces of Personal Data, We have collected from You; (ii) categories of the sources from which Personal Data was collected; (iii) business or commercial purpose for which the Personal Data was collected; (iv) categories of the Personal Data that was disclosed for a business purpose or sold during the past 12 (twelve) months (v) categories of third parties to whom the Personal Data was disclosed or sold;
2. Right to request deletion: You have right to request that the Personal Data collected from You is deleted. However, We might not delete Your Personal Data in certain events including (i) to detect security incidents; (ii) to debug to identify and repair errors; (iii) exercise free speech; (iv) to comply with California Electronic Communications Privacy Act; (v) to engage in public, peer-reviewed, historical or statistical research; (vi) to comply with legal obligations.
3. Right to “opt-out” from sale of Personal Data: You have right to “opt-out” by requesting that Your Personal Data not be sold in any form;
4. Right to non-discrimination: You have the right to not be discriminated against for exercising Your privacy rights under the CCPA;
5. Right to know information disclosed to third-parties: You have the right to request the categories of Personal Data that We disclosed to third parties in the last 12 (twelve) months for direct marketing purposes and any other related information on the relevant third parties.
4. You may designate another person or entity (“Authorized Agent”) to act on Your behalf in connection with Your request for rights that are guaranteed by the CCPA. An Authorized Agent is a natural person or business entity registered with the Secretary of State to conduct business in California that You have authorized to act on Your or to make a request to know or to delete. You Authorized Agent can submit a request by sending an email to the email id provided in the “Contact Us” Section below attaching the signed permission. Please note that We may deny a request from an Authorized Agent that does not submit proof that they have authorized by You.

Under the CCPA, Your Authorized Agent is responsible for implementing and maintaining reasonable security procedures and practices to protect and use Your Personal Data only for the purpose of fulfilling Your request.

If You have any questions, comments or concerns regarding our Policy, you may contact Us through our customer support page or through information provided below:

You can contact our grievance officer at: Email: mailto:teenpatti.support@octro.com

The grievance officer is identified above pursuant to the provisions of applicable laws including but not limited to the IT Act, 2000 and the Consumer Protection Act, 2019, and the rules enacted under those laws.