Privacy Policy

This Privacy Policy (“Privacy Policy”) along with other policies (collectively called“Platform Policies”), forms an integral part of the Terms of Use, between Companyand you. This Privacy Policy describes our policies and procedures on the collection,use, disclosure, processing, transfer, and storage of the information provided to usby you. By using, browsing and accessing the Platform you agree to be bound by theterms of this Privacy Policy and consent to the collection, storage, possession,dealing, handling, sharing, disclosure or transfer of your information in accordancewith the terms of the Privacy Policy. Accordingly, you are advised to read this PrivacyPolicy carefully before accessing the platform.

This document is an electronic record and is governed by the provisions under theInformation Technology Act, 2000 and rules made thereunder as may be applicable, and the amended provisions pertaining to electronic records in various statutes as amended   by   the   Information   Technology   Act,   2000.   This   electronic   record   is generated by a computer system and does not require any physical or digitals signatures

Your privacy is extremely important to Frolic. At Frolic, we believe in being absolutely transparent about our Privacy Policy so that you can focus on availing the Services provided by the Platform without worrying. We maintain complete.

This Privacy Policy sets out the type of information collected from the Users, including the nature of the Sensitive Personal Data or Information (defined hereinafter), the purpose, means and modes of usage of such information and how and to whom we shall disclose or transfer such information. You may at anytime withdraw your consent for collection and use of your information including Personal Information (defined hereinafter) or Sensitive Personal Data or Information, by way of writing to us on [email protected]. However, please note that if you withdraw your consent, we may no longer be able to provide you with the corresponding service for which you have withdrawn your consent. It is hereby clarified that your decision to withdraw your consent will not affect the processing of Personal Information based on your previous consent prior to the withdrawal.

This Privacy Policy applies to all current and former users accessing or using Our Platform, or otherwise engaging with us through email or other means.

Please take a moment to familiarize yourself with our Privacy Policy. If you do not agree with any provisions of this Privacy Policy or other Platform Policies, we advise you to not use or access the Platform.

We shall not use your information in any manner except as provided under this Privacy Policy. Capitalised terms used herein if not defined shall have the same meaning as ascribed to them under the Terms.

As set out in the Terms of Use relating to the Services, to access and use the Services on our Platform, You must have attained the legal age (minimum age of 18 years). In case You do access/use our Platform in violation of the aforesaid, You shall be solely responsible for any legal actions that may ensue from your use of Our Services.

Some of the information that we require you to provide on first accessing or registering on the Platform is mandatory and essential to the provision of our services to you, and hence if you do not provide such mandatory information, you may not be able to access some of the features of the Platform.

You may be asked to provide your information anytime you visit, access, use orbrowse the Platform. We may share information and use it consistent with theprovisions of this Privacy Policy. We may also combine it with other information toprovide and improve our Service(s), content and advertising.

Information you provide:

While signing up: Your email ID, and/or phone number when you register on our Platform and/or subscribe for our newsletter.

While creating your User Profile   : Name, username, profile picture, gender ,age, location, etc.

Interaction information:

When you interact with the Frolic customer support telephonically, such telephonic interactions may be recorded and stored for quality monitoring and training purposes.

Technical Information about You:

We automatically collect certain information from you when you use the Platform, including your IP address (static or dynamic),location, other unique device identifiers, your browser type, browser language, theURL of the website which you may have used to reach our Platform, other browser history, search terms, number of clicks, domain names, and cookies (defined below), landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time, etc.

From your device:

Type of device, advertising identifier, device identifiers (such asIMEI),   operating   system   and   version,   carrier,   language   settings,   geo-location,network type (2G,3G,4G,WiFi) screen resolution, etc.

Gameplay history:

We record your game playing history on the Platform including games played game session durations, your high scores, your preferred game settings, and more broadly all actions taken within our Platform will be logged.

Usage information:

When you play any game offered by us on the Platform, including any formats of such games, such as tournaments, promotional games, practice games (together, “Games”) or access other Services on our Platform, we collect details related to the manner of your use of and interaction with our Platform and other Users such as the date and time during which you accessed the Platform, location from where you access the Platform, the duration for which you play any game, and the formats of game you participate in.

Messages:

When you use our Platform to communicate, we receive and collect the messages you may send or receive on the Platform, and any other content you may upload or share on the Platform.

Cookies:

We use cookies, small text files that uniquely identify your browser and enable Us to recognize the information you have consented to give us, to store certain types of information each time you visit any page on our Platform. These cookies do not contain any personal information and you may choose what cookies you allow by managing your cookies settings on your browser. This will allow you to delete your browser cookies or disable them entirely, however, if you choose to disable all cookies, it will affect your overall experience with our Platform and it may make parts of our Platform non-functional or inaccessible to you in such cases. Therefore, we recommend that you enable cookies for our Platform. The cookies we collect are mainly used to serve advertising banners to you and in doing so we may use the services of third parties. Such third-party service providers do not know the name, phone number, address, email address, or any personal information about you, and no personal information is collected or used in this process.

Please note that if you do not want Frolic to deploy cookies in your browser, you can opt out by setting your browser to reject cookies. If you choose to disable cookies in your browser, you can still use Frolic Services, although your ability to use some of the features of the Platform may be affected. By using the Services, you consent to allowing us to retain all the above-described information in anonymous form as long as Frolic sees fit.

The Third Parties use of cookies and other technologies helps us analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Policy. Please be advised that if you opt-out of any service, you may not be able to use the full functionality of the Services on the Platform.

Web beacons:

We use web beacons, images that are part of the web pages, also called pixel tags or clear gifs, in combination with cookies to understand how you interact with our Platform and the content therein. When you disable cookies, web beacons are also likely to become ineffective. You can also add browser extensions to specifically block web beacons.

From third-party Analytics:

Reports on activity, game performance metrics, usage trends, demographic data from software (such as Google Analytics etc.), which are integrated with our Services on the Platform.

We may collect a variety of information from you, including your name, password, mailing address, phone number, email address and contact preferences, including any other usage and interaction details with us or our affiliates. We may collect such information which when combined with other pieces of information available with us could reasonably allow you to be identified (“Personal   Information”). PersonalInformation shall include but is not limited to your full name, personal contact numbers, residential address, email address, gender or date of birth.

Sensitive Personal Information (“SPI”) means such personal information which consists of information relating to your:

Password; Financial information such as bank account or credit card or debit card or other payment instrument details; Physical, physiological and mental health condition;Any detail relating to the above Personal Information categories as provided to us for providing services on the Platform; and such other information specified as constituting SPI under the applicable laws of India.

We may collect, use or process your information including Personal Information and Sensitive Personal Information for the following purposes:

For creating and giving you access to your registered Frolic account on the Platform. To develop, deliver, process and improve our Products, services, content in order to personalize and improve your experience.process monetary transactions to your Frolic Wallet, and enable Withdrawals; facilitate your participation in various types of Games and activities on the Platform; handle support requests, including investigating a transaction or issuing a refund; measure and understand the effectiveness of the promotions, and advertisements we serve to you and others;To inform you about our Products, services, offers, updates, upcoming events, including providing you information in relation to order confirmations, invoices, technical notices, security alerts.perform internal operations such as troubleshooting, data analysis, testing, research, statistical, internal training, and quality management purposes aimed at improving the Platform, enhancing future game developments, and making advertisements more relevant. Such analysis is aggregated and does not pertain to any specific User.To meet any legal or regulatory requirement or comply with a request from any governmental or judicial authority.To resolve any request, dispute, grievance or complaint raised by you in relation to your use of the Platform.To detect or monitor any fraudulent or illegal activity on the Platform.provide you with user support; and enforce our Platform Policies.

Where you use our referral program, we use

your name/email address in the heads of the email/SMS sent to the person referred; andthe name, mobile number, and email address of the person referred, to communicate with them.

Frolic has a policy of not sharing any personally identifiable information with anyone other than entities specifically authorized by Frolic. However, Frolic may use your name, Username and the state from where you are participating, when announcing the results of any contests run on the Platform. Such contests are further governed by the Terms which shall be available on the Platform as and when such a contest is run on the Platform.

Frolic may also use cumulative non-personal information for auditing and analysis purposes with the aim of improving its services.

We may, from time to time, be required to disclose the information collected from you, to our trusted third party service providers, who assist us in order to facilitate the provision on the Platform. For instance, we may share your information with third party payment gateway provider to process transactions on the Platform. By using the Platform, you consent to any such disclosure of your information with third party service providers. We ensure that such third party service providers are bound by reasonable confidentiality obligations and/ or use, maintain and follow generally accepted industry and security standards with respect to such information.

We may also disclose your information when such disclosure is requisitioned under any law or judicial decree or when we, in our sole discretion, deem it necessary in order to protect our rights or the rights of other Users, to prevent harm to persons or property, to fight fraud and credit risk.

We may also disclose or transfer your information to any third party as a part of reorganization or a sale of the assets, division or transfer of a part or whole of us. We shall ensure that, third party to which we transfer or sell our assets will have, appropriate confidentiality and security measures, at least as protective as those described in this Privacy Policy, to handle your Personal Information. You will have the opportunity to opt out of any such transfer if the new entity's planned processing of your information differs materially from that set forth in this Privacy Policy.

A third party payment gateway provider may be required to collect certain financial information from you including, but not restricted to, your credit/debit card number or your bank account details (collectively referred to as “Financial Information”). All Financial Information collected from you by such third party payment gateway providers will be used only for billing and payment processes. The Financial Information collected from you is transacted through secure digital platforms of approved payment gateways which are encrypted, thereby complying with reasonably expected technology standards. The verification of the Financial Information shall be accomplished only by you through a process of authentication in which we shall have no role to play and hence, we shall bear no liability in relation to the same. We shall neither be liable nor responsible for any actions or inactions of third party payment gateway providers or any breach of conditions, representations and warranties given by them. We shall also not be obligated to mediate or resolve any dispute or disagreement between you and such third party payment service providers.

While we take best efforts to ensure that your information including Personal Information, Financial Information and Sensitive Personal Information or Data is duly protected by undertaking security measures prescribed under applicable laws, you are strongly advised to exercise reasonable discretion while providing Personal Information or Financial Information while using the services given that the Internet is susceptible to security breaches.

We may share your information with group companies of Frolic that aid us in the provision of our Services and the functioning of the Platform, and for our internal business purposes.

We reserve the right to conduct a security review at any time to validate your identity, age, the state from where you are accessing the Platform and other registration data provided by you and to verify your use of the services and your financial transactions for potential breach of our Terms of Use and of the applicable law. By using our Platform, you authorize us, our staff, agents to use your Personal Information and to disclose your Personal Information to third parties for the purposes of validating the information you provide to us.

The information collected by us from users of the Platform is securely stored and processed on servers located in India.

Your information may also be transferred, stored or processed in any country other than the one where you access the Platform. For purposes of sharing or disclosing data in accordance with the Privacy Policy, we reserve the right to transfer your information outside of your country. By using the Platform, you consent to such transfer of your information outside of your country and also within our affiliates, subsidiaries and partners whose personnel and subcontractors, provided they have agreed to ensure the same level of data protection as prescribed under this Privacy Policy and the data protection laws of India. The information may be transferred in the event it is necessary for the performance of the services, operation of the Platform and provision of Products as agreed upon between us and the third party.

The security of your Personal Information is important to us. We have implemented security policies, rules and technical measures, as required under applicable law including firewalls, transport layer security and other physical and electronic security measures to protect the Personal Information from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss. When you submit your information on the Platform, your information is protected through our security systems. Please note that we use international and industry-recognized standards, as per applicable laws, rules and regulations.

Your information is contained within secured networks and is only accessible by a limited number of authorized persons who have access rights to such systems or otherwise require such information for the purposes provided in this Privacy Policy. These authorized persons are also under an obligation to keep such information confidential.

Although we make best possible efforts to transmit and store all the information provided by you in a secure operating environment that is not open to public, you understand and acknowledge that there is no such thing as complete security and we do not guarantee that there will be no unintended disclosures of any information and potential security breaches. You agree not to hold us responsible for any breach of security or for any action of any third parties that receive your Personal Information or events that are beyond our reasonable control including, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.

Due to the communications standards on the Internet, when you visit, access or browse the Platform, we automatically receive the uniform resource locator of the site from which you visit, access or browse the Platform, details of the website you visit on leaving the Platform, the internet protocol (“IP”) address of each User’s computer operating system, type of web browser the User is using, email patterns, and the name of the User’s internet service provider. This information is used solely to analyse overall User trends and to help us improve our services. Please note that the link between the User’s IP address and the User’s personally identifiable information is not shared with third parties without such User’s permission or except when required by law or to provide or facilitate the User with the services. Notwithstanding the above, the User acknowledges that we reserve the right to share some of the aggregate findings, including the personal information provided by the Users in an unidentifiable, aggregate form, and not the specific data with advertisers, sponsors, investors, strategic partners, and others in order to help grow the business. The amount of information sent to us depends on the settings of the web browser used by the User to access the Platforms. The User may refer to the browser used, if the User wishes to learn what information is provided to us.

The Platform uses temporary cookies to store certain data. We do not store Personal Information in the cookies. Information collected by us, by any means whatsoever, that does not personally identify the User as an individual (such as patterns of utilization described above) is exclusively owned by us and may be used by us and third party service providers for technical administration of the Platforms, user administration, research, development, and other purposes.

You understand that you may set or amend your web browsers to delete or disable cookies. If you choose to disable cookies on your computer or mobile telecommunication device, it may impair, degrade or restrict access to certain areas of the Platform.

We may allow other companies or entities to serve advertisements to you. These companies or entities include third party advertisement servers, advertisement agencies, advertisement technology vendors and research firms. We may target some advertisements to you that fit a certain general profile. We do not use Personal Information to target advertisements to you. In the course of serving advertisements or optimizing the services to its Users, we may allow authorised third parties to place or recognize a unique cookie on the User’s browser.

We cannYou agree and understand that we do not exercise control over third party websites displayed as search results or links on the Platform. These other sites may place their own cookies or other files on the Users’ computer, collect data or solicit personal information from the Users, on which we have no control and shall not be held responsible or liable. We do not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor do we guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by us of such websites, the websites’ provider, or the information on the website.ot be held responsible for any of the instances pertaining to the Offer and nor will We re-issue, compensate, accept or provide any remedy of reasons including but not limited to:

We may keep records of telephone calls received from and made to Users for the purpose of administration of services, research and development, training, business intelligence, business development, or for User administration. We may share such telephone records with third parties when required by law or when required to provide or facilitate the User with the services.

We do not acYou consent to our reproduction/publishing of all testimonials and reviews given by you on the Platform in relation to the services or the Products. You agree that we may edit the testimonials and reviews provided by you and reproduce/publish such edited or paraphrased versions of the testimonials and reviews on the Platform. If the User has any concerns with the reproduction/publication of any testimonial or review provided by you, the User may contact us at Customer care id: [email protected]cept responsibility for network, computer, or software failures of any kind and have no responsibility for lost, delayed or misdirected entries.

The third party service providers with whom we may share information provided by you are not permitted to market their own services or send promotional e-mails or engage in promotional communication with you. We provide you with the opportunity to opt-out of receiving non-essential, promotional, or marketing-related communication from itself or its partners.

If you wish to remove your contact information from all our mailing lists and newsletters, you can click on the "unsubscribe" link or follow the instructions in each e-mail message. Alternatively, you can contact us at our Customer Care Email ID: [email protected]. We reserve the right to limit membership based on availability of contact information. All Users will be notified by email prior to any actions taken.

You agree to provide information, which shall be true, correct, up to date and accurate. You may access, amend, alter or require deletion of your information partially or fully by contacting us atCustomer Care Email ID: [email protected]

When you register with us, each time you login into your Frolic account, you shall be required to provide your registered mobile number and the One-Time-Password (“OTP”) received on such registered mobile number. You are responsible for maintaining the secrecy of your OTP and Frolic Account information, at all times. Therefore, you should not provide your OTP or login credentials to anyone whosoever. Breach hereof, constitutes a violation of this Privacy Policy and may result in termination of your Frolic Account in certain cases. If you become aware of or reasonably suspect any breach of security, including compromise of your OTP, you must notify us immediately by writing an email to us at [email protected]

Data which is transmitted over the Internet is intrinsically exposed to security risks or threats. For instance, information transmitted via chat or email can be compromised and used by others. Therefore, Frolic cannot guarantee any security for such information.

Further, you may choose to disclose information about yourself on our communication feature, chat rooms & forums, or while creating your Frolic Account. Information that you disclose on our Platform, in any manner, is public information, and will be accessible to anyone who uses our Services on the Platform. We are not responsible for the actions of any third parties with whom you share personally-identifiable information. Finally, you can always refuse to supply the aforementioned personally-identifying information, with the caveat that it may prevent you from engaging in certain activities on the Services.

While we take best efforts to ensure that your information including Personal Information, Financial Information and Sensitive Personal Information or Data is duly protected by undertaking security measures prescribed under applicable laws, you are strongly advised to exercise reasonable discretion while providing Personal Information or Financial Information while using the services given that the Internet is susceptible to security breaches.

We may retain the Information, for as long as is necessary to fulfil the purposes, for which it was collected or as needed to provide the Services, even after you have discontinued or deleted any account, or after the end of the provision of the Services, if retention of such Information is reasonably necessary to comply with legal obligations, meet regulatory requirements, resolve disputes between users, prevent fraud, or any other use.

The Platform may contain links to third-party websites or services (“External Resource”). Your browsing on and interaction with any External Resource, irrespective of whether the link to such External Resource originated on our Platform, is subject to the terms and privacy policies of such External Resource. We are not responsible for the functionality, privacy, or security measures of any other entity and this Privacy Policy will not govern your use and access of such website or service you are redirected to.

Our Platform is not directed towards minors. We do not knowingly collect Personal Information from any User who is under 18 (Eighteen) years of age. If we are made aware that we have collected the Personal Information of a person below the age of 18 (Eighteen) years, we will take steps to delete the information within a reasonable time frame. If a parent or guardian becomes aware that their child has provided their information on the Platform without such parent or guardian’sconsent, he or she shall, contact us for the deletion of such information. In the event, where in contravention to the Privacy Policy and Terms, a person below the age of 18 (Eighteen) years, uses the services, we shall not be held liable or responsible for any damage or injury suffered by such person.

In case, you have any questions, grievance or complaints about this Privacy Policy, or the Platform, you may contact us on the below mentioned details:

Email Address: [email protected]Registered Office Address: Shopsense Retail Technologies Limited 1st Floor, Wework Vijay Diamond, Opp. SBI Branch, Cross Road B, Ajit Nagar, Kondivita, Andheri East, Mumbai 400093

In case, you have any questions, grievance or complaints about this Privacy Policy, or the Platform, you may contact us on the below mentioned details:

Email Address: [email protected]Registered Office Address: Shopsense Retail Technologies Limited 1st Floor, Wework Vijay Diamond, Opp. SBI Branch, Cross Road B, Ajit Nagar, Kondivita, Andheri East, Mumbai 400093

The terms of this Privacy Policy shall be governed and construed in accordance with the laws of India. Any dispute regarding or arising out of this Privacy Policy shall be subject to the exclusive jurisdiction of the courts in Mumbai, Maharashtra.

Whenever possible, each section of this Privacy Policy shall be interpreted in a manner so as to be valid under applicable law. However, in the event any provision is held to be prohibited or invalid, such provision shall be ineffective only to the extent of such prohibition or invalidity, without invalidating the remainder of such provision or other remaining provisions of this Privacy Policy.

If the User has any concerns, feedback, review or any request, the User is free to contact the Company at Customer Care Email ID: [email protected]

Company Details: Shopsense Retail Technologies LimitedRegistered Office Address: 1st Floor, Wework Vijay Diamond, Opp. SBI Branch, Cross Road B, Ajit Nagar, Kondivita, Andheri East, Mumbai 400093