PRIVACY POLICY

Privacy Policy

DSPS Tech Platform Private Limited formerly known as DSG Experiences Private Limited operates the portal in India, which offers fantasy stock trading games through the web-portal [•] and partner website(s) and mobile application(s) (collectively referred to as the “Portal”) (DSPS Tech Platform Private Limited referred to herein as “SMPL” or “we” or “us” “our”).

Any person utilizing the Portal (“User” or “you” or “your”) or any of its features including participation in the various contests and games (“Game” or “Services”) being conducted on the Portal shall be bound by the Privacy Policy. Your use of any part of the Portal indicates your acceptance of this Privacy Policy and of the collection, use and disclosure of your personal information in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Portal. Further, while you have the option not to provide us with certain information, withdraw your consent to collect certain information, request temporary suspension of collection of information or request deletion of information collected, kindly note that in such an event you may not be able to take full advantage of the entire scope of features and services offered to you and we reserve the right not to provide you with our services.

Our privacy policy may change at any time without prior notification. To make sure that you are aware of any changes, kindly review the policy periodically.


Information provided by You

To avail certain services on our Portal, Users would be required to provide some personally identifiable information for the registration process, which includes but is not limited to the following:

Name

Email address

Mobile number

Permanent Account Number (PAN)

Date of Birth

Gender

Address

We may require you to provide additional details, as and when required, in order to comply with any applicable regulatory requirement or for additional services/products offered via the Portal, as and when offered. In the course of providing you with access to the Services, and in order to provide you access to the features offered through the Portal and to verify your identity, you may be required to furnish additional information, including your Permanent Account Number, Know Your Customer (KYC) information, bank account details.

In certain instances, we may also collect certain financial information that may qualify as Sensitive Personal Information (“SPI”) such as information regarding the payment instrument/modes used by you to make such payments, which may include cardholder name, credit/debit card number with expiration date, banking details, wallet details etc. (in encrypted form). This information is presented to you at the time of making a payment to enable you to complete your payment expeditiously.

Except for any financial information that you choose to provide while making payment for any Services on the Portal, SMPL does not collect any other SPI in the course of providing the Services. Any SPI collected by SMPL shall not be disclosed to any third party without your express consent, save as otherwise set out in this Privacy Policy or as provided in a separate written agreement between SMPL and you or as required by law. It is clarified that this condition shall not apply to publicly available information, including SPI, in relation to you on the Portal.

Express Consent

While providing your details/documents via the Portal, including but not limited to personal information as mentioned herein above, you expressly consent to SMPL (including its marketing channels and business partners) to contact you through SMS, call and/or e-mail and to follow up with regard to the Services / Games provided through the Portal, for imparting product knowledge, offering promotional offers running on the Portals & various other offers/services by our business partners.

In the course of providing the Services, Users may invite other existing Users or other users ("Invited Users") to participate in any of the Services by providing the email address or Facebook username of such users. SMPL may thereafter use this information to contact the Invited User and invite such user to register with SMPL (if such Invited User is not an existing User) and participate in the Game in relation to which such person was invited by the User. The participation of the Invited User in any of the Game shall be subject to the terms of this Privacy Policy and the Terms and Conditions for the use of the Portal. The User hereby represents that the Invited Users have consented and agreed to such disclosure to and use of their email address or Facebook username (as the case may be) by SMPL.

Information automatically collected while using the app or website

When you browse through the Portal we may collect information relating to your use of our Portal such as your IP address, browser type, mobile operating system, manufacturer and model of your mobile device/computer, access time and time spent, and anonymized statistical data. We may also collect information about the screens/pages you view within our Portal and other actions you take while using our Portal.

We may use third party services for such automatic collection, however no personally identifiable information will be shared with such third parties, unless required under applicable laws.

Use of Personal Information

For Providing Our Services

All information collected from the User will be utilized for the purpose of providing services, including but not limited to the services requested by the User. The information as supplied by the Users enables us to improve the Services and provide you the most user-friendly game experience.

Sharing with Service Partners

SMPL may also share such information with affiliates and third parties in limited circumstances, including for the purpose of providing services requested by the User, storage, complying with legal process, preventing fraud or imminent harm, and ensuring the security of our network and services. However, we do not share any information with third parties for soliciting products and services offered by them.

Marketing

SMPL (including its marketing channels and business partners) may use your information to contact you through SMS, call and/or e-mail and to follow up with regard to the Services / Games provided through the Portal, for imparting product knowledge, offering promotional offers running on the Portals & various other offers/services by our business partners.

Advertising

We allow advertisers and/or merchant partners (“Advertisers”) to choose the statistically anonymized information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers.

Information Sharing

We may need to share limited personal information with our partners and third party service providers who perform services for us and help us operate our business, for the purpose of data analytics or other similar purposes, for the purpose of storage, and improving services provided by SMPL. We require our partners to safeguard this information and only use your personal information for the purposes we specify.

Where we propose to use your SPI (that is not otherwise publicly available) for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for your use other than as listed above.

By using the Portal, you hereby expressly agree and grant consent to the collection, use and storage of this information by SMPL. SMPL reserves the right to share, disclose and transfer information collected hereunder with its own affiliates. In the event SMPL sells or transfers all or a portion of its business assets, consumer information may be one of the business assets that are shared, disclosed or transferred as part of the transaction. You hereby expressly grant consent and permission to SMPL for disclosure and transfer of information to such third parties. SMPL may share information as provided by you and data concerning usage of the Services and participation in the Game with its commercial partners for the purpose of facilitating user engagement, for marketing and promotional purposes and other related purposes

SMPL further reserves its right to disclose information to third parties when it is requested or required by law or by any court or governmental agency or authority to disclose.

Information Security

All information gathered on SMPL is securely stored within SMPL controlled database. The database is stored on servers secured behind a firewall; access to such servers being password-protected and strictly limited based on need-to-know basis. However, we understand that as effective as our security measures are, no security system is impenetrable. Thus, we cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. Further, any information you include in a posting to the discussion areas will be available to anyone with Internet access. By using the Portal, you understand and agree that your information may be used in or transferred to countries other than India.

SMPL also believes that the internet is an ever-evolving medium. We may periodically review from time to time and change our privacy policy to incorporate such future changes as may be considered appropriate, without any notice to you. Our use of any information we gather will always be consistent with the policy under which the information was collected, regardless of what the new policy may be. Any changes to our privacy policy will be posted on this page, so you are always aware of what information we collect, how we use it, how we store it and under what circumstances we disclose it.

Log Files

This information may include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may use the collected log information about you to improve services offered to you, to improve marketing, analytics, or Portal functionality.

Links

SMPL also includes links to other websites. Such websites are governed by their respective privacy policies, which are beyond SMPL's control. Once the User leaves SMPL's servers (the User can tell where he/she is by checking the URL in the location bar on the User's browser), use of any information provided by the User is governed by the privacy policy of the operator of the site which the User is visiting. That policy may differ from SMPL's own. If the User can't find the privacy policy of any of these sites via a link from the site's homepage, the User may contact the site directly for more information. SMPL is not responsible for the privacy practices or the content of such websites.

Confidentiality of your account

You are solely responsible for maintaining the security of your account and must not provide these credentials including the Personal Identification Number (PIN) if assigned to you for the Portal itself to any third party. We are not responsible or liable if someone else accesses your account through the credentials they have obtained from you or through a violation by you of this Privacy Policy.

Cookies

We use “cookies” that are text files containing small amounts of information which are downloaded to your device when you visit a website, in order to provide a personalised browsing experience. These cookies help the Portal identify unique users, unique sessions, gather information and store information. No personally identifiable information is retrieved or stored. The only personal information that a cookie can contain is information supplied by the User.

SMPL'S advertisers may also assign their own cookies to the User's browser (if the User clicks on their ad banners), a process that SMPL does not control. SMPL and its affiliates are not responsible for cookies placed in the device of Users by any other website and information collected thereto

Cookies allow users to navigate between pages efficiently, remembering their preferences, and generally improving their browsing experience. These cookies collect information analytics about how users use a website, for instance, often visited pages, time spent on each page etc. All information collected by third party cookies is aggregated and therefore anonymous. By using the Portal, the user agrees that these types of cookies can be placed on his / her device. The user is free to disable/ delete these cookies by changing his / her web browser settings.

Data Retention

We will retain your information for as long as it is necessary for the purpose for which the information was collected or the information is required to be retained by applicable law, regulations, or contractual obligations, whichever is later.

Users are entitled to request SMPL to delete their User accounts and their personal information by sending an email with their written request to support@smpl.com (“Termination Request”). SMPL will comply with all Termination Requests promptly and in any event within one month of the receipt of the Termination Request or receipt of any additional information sought by SMPL to enable SMPL to comply with the Termination Request. Provided however (i) there may be delays between when you request deletion and when copies are deleted from our active and backup systems; and (ii) we will continue to retain any information (including SPI) required to be retained by us as per any applicable laws.

However, SMPL reserves the right to continue to use your anonymised data, post termination of your account, aggregated or in combination with anonymised data of other users. We use this aggregated anonymised data for data analysis, profiling and research purposes. We may keep your contact information along with your application details (if any) for fraud prevention purposes and for the exercise/ defense of a legal claim or for providing evidence in legal proceeding(s) if required.

If you wish to review, correct or rectify your SPI or withdraw your consent for processing your SPI, you may submit a request at support@smpl.com In addition, SPI may also be updated, corrected or rectified by logging into Your profile page on the Portal. However, we will continue to retain any information (including SPI) required to be retained by us as per the applicable laws.

Grievance Redressal Policy

If you have any grievance or complaint, questions, comments, concerns or feedback in relation to the processing of information or regarding this Privacy Policy or any other privacy or security concern related to the Portal, you can send an email to SMPL at support@smpl.com

Updating Information

You are responsible for promptly notifying SMPL of any changes, updates, or modifications to your personal information. Additionally, you can review, update, or modify your information and user preferences at any time by logging into your Profile page on the Portal.

Contact Us

Any questions or clarifications with respect to this Policy or any complaints, comments, concerns or feedback can be sent to SMPL at support@smpl.com or by normal/physical mail addressed to:

Attn: SMPL Team

Sensix Tech Pvt Ltd

Office No. 319, Centura Square, Rd Number 27, Wagle Estate, Shree Nagar

Thane West, Maharashtra 400604