Privacy Policy

Last Updated on [.]

NaagPash ("Platform") is operated by Dyumn Tech Private Limited having its registered office at 101, D Definity Premises Co-operative Society Limited, Survey No-95, Hissa No-CTS No-364, Jayprakash Road No-01, Goregaon East, Mumbai, Maharashtra, India, 400063 (hereinafter referred to as "Company", "We", "Us", "Our"). We offer offline game with online features as provided on the Platform ("Services").

This Policy provides for the practices for the collection, possession, storage, handling and dealing of personal identifiable information/ data and sensitive personal data of the User, if any collected and processed by the Company. We handle your Personal Information in accordance with all the applicable data protection and privacy laws, regulations and statutory requirements in force from time to time in the jurisdiction relevant to the Users as on the relevant date ("Applicable Privacy Laws").

The Company urges the User to read and understand this Policy and the Terms of Service available at [.] ("ToS") carefully for details on the way. By accessing Our Platform or availing Our Services, You consent to the collection, process, use, disclosure, store and transfer of Your Personal Information in accordance with this Policy and for the purposes stipulated herein.

1. Who does this Policy apply to?

This Policy will apply to (a) all persons accessing Our Platform; and (b) all person participating in the games offered by Us or using any of Our Services offered on Our Platform. (hereinafter referred to as "User, "You", "Your").

2. What data do we collect?

2.1 In the course of providing the Services to the Users through the Platform, We may (directly or through Our partners) collect the following personal information ("User Information"):

• Bank account details, UPI details or any other details required to facilitate the payment, if You make any in-app purchases on the Platform.
• The Users' game preferences and activities and profile information to improve the Services and provide You with relevant suggestions.
• When User uses the Platform, We gather data on (i) the type of mobile device that User use, (ii) User's mobile device's Unique ID, (iii) IP address of User's mobile device, (iv) User's mobile operating system, (v) the type of mobile internet browser User use, ((vii)usage patterns (viii) browsing history, and (vi) unique device identifiers and other diagnostic data.
• Each time You use the Platform or play through other devices, We may automatically collect information about Your use of that device and app. If You sign in to an account, We may combine it with other information We have for that account.
• Any other information collected through Tokens.

2.2 This Policy shall not apply to the User Information if the User Information does not qualify as 'personal information' or 'personal data' under the Applicable Privacy Laws ("Personal Information"). Any such non-personal information may be used, processed, or disclosed by us without the restrictions set out in this Policy.

3. How do we collect Your data?

3.1 We collect data and process Personal Information when You:

• Use Our Services.
• Use Our Platform, by collecting session Tokens, API Tokens etc., if applicable.
• View or interact with advertisements shown on the Platform.

4. How We use Your Personal Information

We use the Personal Information for the following purposes:

• Providing Our Service: The processing of Personal Information is important to facilitate the User to use Services vide the Platform.
• Improving the Services: To analyze User's choices, browsing patterns including the frequency of visits and duration for which a User is logged on, to diagnose problems with Our servers, for improving Our systems and Platform and Services.
• Marketing and advertising: We use Personal Information to provide Users with special offers, and promotions, and for other marketing, advertising, and promotional purposes, including general updates about Us and Our Services and new offerings of the Company or any third-party partner services. These communications will be sent in accordance with Your communications preferences, if you specifically opt-in for receiving the same.
• Comply with legal obligations: To meet Our legal obligations under the applicable laws.
• Legitimate Interests: To fulfil Our legitimate interests, or those of a third party in conducting and managing Our business and Our relationship with You as described in this Policy.
• Security: In order to protect You and other Users from fraudulent activities and transactions and to protect You from unauthorized access.

5. What are Tokens and how do we collect and use them?

5.1 We use Tokens to personalize the User's experience on the Platform and the advertisements that may be displayed.

5.2 Tokens are small pieces of information that are stored by the User's application on the User's device's hard drive. Tokens allow Us to serve the User better and more efficiently ("Tokens").

5.3 Type of Tokens We Use

• Tokens can be "Persistent" or "Session" Tokens. Persistent Tokens remain on Platform when You go offline, while Session Tokens are deleted as soon as You close Your Platform.
• We use both Session and Persistent Tokens for the purposes set out below:
  • Necessary / Essential Tokens
    Type: Session Tokens
    Administered by: Us
    Purpose: These Tokens are essential to provide You with Services available through the Platform, ancillary services to enable You to use some of its features. They help to authenticate Users and prevent fraudulent use of User accounts. Without these Tokens, the Services that You have asked for cannot be provided, and We only use these Tokens to provide You with those Services.
  • Tokens Policy / Notice Acceptance Tokens
    Type: Persistent Tokens
    Administered by: Us
    Purpose: These Tokens identify if Users have accepted the use of Tokens on the Platform.
  • Functionality Tokens
    Type: Persistent Tokens
    Administered by: Us
    Purpose: These Tokens allow us to remember choices You make when You use the Platform, such as remembering Your language preference. The purpose of these Tokens is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Platform.
  • Additional Services Tokens
    Type: Persistent Tokens
    Administered by: Third-Parties
    Purpose: These Tokens are used for availing other services on the Platform that are outsourced to the third-party service providers.
  • Tracking and Performance Tokens
    Type: Persistent Tokens
    Administered by: Third-Parties
    Purpose: These Tokens are used to track information about traffic to the Platform and how Users use the Platform. The information gathered via these Tokens may directly or indirectly identify You as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device You use to access the Platform. We may also use these Tokens to test new advertisements, pages, features, or new functionality of the Platform to see how our Users react to them.

If You prefer to avoid the use of Tokens on the Platform, You should uninstall the Platform from Your device.

6. Where is Your Personal Information stored?

We do not store any User Information with Us or on any external servers or cloud storage. Our third party partners or service providers may store the Personal with them and such storage shall be governed by their respective privacy policies. In addition to the foregoing, certain information associated with Your use of the Platform including Tokens and other User Information may be stored locally on the User's device.

7. Why and when we transfer/ disclose Your Personal Information?

7.1 We may transfer the User's Personal Information within India and outside India (provided that such country offers the same or greater level of protection for Personal Information than India), in the following manner:

7.2 To affiliated companies and entities, within India or outside India, that have been contracted to offer services on behalf of the Company. These service providers or vendors are only permitted to use the disclosed Personal Information in accordance with the instructions provided by the Company via binding documents enforceable by the law.

7.3 We can transfer the Personal Information if required by law, legal process, litigation, and/or requests from governmental or regulatory authorities, or for the purpose of national security, law enforcement, or other issues of public importance, including cyber incidents, prosecution and punishment of offences, to disclose the User's Personal Information.

7.4 In connection with a sale, divesture, or transfer of Company (including any shares) or any combination of its products, Services, assets, affiliates, and/or businesses. The User's Personal Information may be among the items sold or otherwise acquired in these types of transactions. We may also sell, assign or otherwise transfer such Personal Information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings.

7.5 To Our third party partners who may process User Information on Our behalf for the functionality of their services to display advertisements and perform analytics or other support functionality and provide such analytics to Us. Any collection, processing, storage, and retention of User Information by such third-party partners shall be subject to and governed by their respective privacy policy.

8. How do We protect Your Personal Information?

8.1 Security Safeguards and Procedure

• We value the security of the User's Personal Information and hence We have implemented technical and organizational security measures that are designed to help protect the User's Personal Information from unauthorized access, disclosure, use and modification. From time-to-time, We review Our security procedures to consider appropriate new technologies and methods. These measures include the following:
  • use of secure HTTPS connections for all AI API requests and data transmissions;
  • ensuring no logging or transmission of to-do data to external services except for transient processing by AI APIs;
  • if AI responses or any data is cached locally, it is stored securely and encrypted where feasible;
  • providing you with built-in options to clear all stored data or reset the Platform to factory settings for full transparency and control.
• We value the security of the User's Personal Information and hence We have implemented technical and organizational security measures that are designed to help protect the User's Personal Information from unauthorized access, disclosure, use and modification.
• From time-to-time, We review Our security procedures to consider appropriate new technologies and methods.
• Please be aware, however, that no data security measures can guarantee 100% security.
• If We learn of a security breach, We may (a) attempt to notify the User electronically so that the User can take appropriate protective steps; or (b) post a notice on the Platform, or (c) take suo-motto steps to rectify the breach without any notice to the User. If the User have any questions about the security of the User's Personal Information, please contact the Grievance Officer.

8.2 How long We keep Personal Information

• We shall retain the User's Personal Information only for as long as is necessary, and after such reasonable time, it is destroyed appropriately and securely or anonymized in accordance with the law.
• We shall retain the User's Personal Information for: (i) as long as We have a continued relationship with the User; (ii) as long as needed in order to comply Our legal, statutory and contractual obligations; (iii) as long as needed to provide Services to the User and shall be subject to periodic update or deletion of unnecessary data.

9. What are Your Rights and obligations in relation to Your Personal Information?

9.1 Save and except the rights provided herein in this Policy, all rights to the Personal Information shall belong to the User. The Users shall ensure the following:

• To provide true and accurate details of Personal Information.
• To keep their information up to date.
• To regularly review this Policy.
• To keep their account credentials confidential and notify the Company of any security breaches.

9.2 You have the following rights pertaining to the Personal Information shared by You:

• Right to know what Personal Information We hold and to have the information communicated to You;
• Right to access the copies of Your Personal Information. We may charge You a small fee for this service;
• Right to request that the Personal Information held by Us be corrected, rectified or deleted;
• Right to object to the processing of the Personal Information or to request restriction thereof;
• Right to withdraw Your consent to submit or process any or all Personal Information or decline to provide any permissions on its Platform as covered above at any time.

9.3 Any such request to update, delete or correct the Personal Information, or to withdraw consent regarding sharing and use of Personal Information should be shared with the Grievance Officer as per Paragraph 13 below. Please note that we may take time to process such requests, and your request shall take effect no later than 5 (Five) business days from the receipt of such request, after which we will not use your personal data for any processing unless required by us to comply with our legal obligations.

9.4 In case You choose to object processing of the Personal Information, withdraw consent in regard to the Personal Information or delete the Personal Information shared, then Your access to the Platform and Services may be limited, or We might not be able to provide the Services to You.

9.5 We will evaluate any request for deletion of Personal Information on a case-to-case basis and take the requisite action as per applicable law. In this regard, please note that information sought to be deleted may remain with Us in archival records for the purpose of compliance of statutory enactments, or for any other lawful purpose. Therefore, You are requested to carefully evaluate what types of information You would like to provide to Us.

10. Should children access this Platform?

10.1 We do not knowingly collect or process personal information of children below age of 18 (eighteen) years without obtaining verifiable parental consent to process the personal information.

10.2 You cannot access this Platform if you are below 13 (thirteen) years of age.

10.3 If You are under the age of 18 (eighteen) years, You must have Your parent or legal guardian's permission to use avail the Services. Please have Your parent or legal guardian read these Terms with You. You represent that Your legal guardian has reviewed and agreed to these Terms. If You are a parent or legal guardian, and You allow Your child to avail the Services, then these Terms apply to You and You are responsible for your child's activity in relation to the Services.

11. How do we update this Policy?

11.1 This Policy is current as of the last updated date set forth above.

11.2 We may periodically change this Policy to keep pace with new technologies, industry practices, and regulatory requirements, among other reasons. While, We expect most such changes to be minor, We request the Users periodically to review the changes.

12. Governing Law

12.1 This Policy shall be governed by and construed in accordance with the laws of India and the Parties agree that they are bound by the laws of India for the purposes of this Policy. The Parties agree that the Company shall not be required to follow laws of any other jurisdiction, whether or not such User belongs to a different jurisdiction other than India.

12.2 Parties shall try to resolve any dispute arising out of or in relation to this Policy by mutual discussions, failing which the same shall be submitted to arbitration under the provisions of the Arbitration and Conciliation Act, 1996 by a sole arbitrator appointed by the Company. The place of arbitration shall be Mumbai, Maharashtra, India and the language of arbitration, English. Subject to the foregoing, the courts at Mumbai, Maharashtra, India shall have exclusive jurisdiction.

13. How to contact Us?

Any complaints with regards to use, processing or disclosure of Personal Information provided by the User or breach of the terms of this Policy may be taken up with the Grievance Officer. The details of the Grievance Officer are as follows:

Grievance Officer: Mr. Ravi Ram Jonnalagadda
Email: grievance@virbhumi.com
Address: 101, D Definity Premises Co-operative Society Limited, Survey No-95, Hissa No-CTS No-364, Jayprakash Road No-01, Goregaon East, Mumbai,, Maharashtra, India, 400063

The Grievance Officer shall acknowledge and dispose of the complaint within such time period as prescribed under the applicable laws.