Who We Are? 

This privacy policy (“Policy” or “Privacy Policy”) sets out how Sahaj Gaming and Edutainment Private Limited (referred to as "Sahaj," "we," "us," or "our") handles, uses and transfers the Personal Information of any person who accesses or uses Our mobile apps or websites (collectively, the "Platform").  This Policy forms part of our Terms and Conditions (the “Terms”) as applicable to the Platform and as available at https://1ludo.com/terms-and-condition.html.

For the purpose of this Policy, wherever the context so requires “you”, “your”, “yourself”, “their” or “User” shall mean any person who accesses or uses the Platform.

Your Consent?

By accessing/using  the Platform in any manner or by using any content, information or service provided through the Platform, you agree to this Policy. This means you inter alia consent to us collecting, storing, and using your Personal Information as described here. If you're not comfortable with this, please don't access the Platform and don’t use our services or any content and information provided on the Platform.

What We Mean by Personal Information?

When we talk about "Personal Information," we mean data about you (the individual) that can identify you or in relation to which you are identifiable, like your name or email. We also consider sensitive Personal Information like passwords, financial information like bank account & card details, health details, and more as "Sensitive Personal Data or Information."

Our Commitment: We comply with the procedures and standards set out under the applicable law, including specifically the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 to keep your Personal Information safe and secure.

Scope: This Policy applies only to our Platform and the services we offer through it.

If you have any questions or concerns about your privacy, feel free to contact us.

i. Our Business & Policy Applicability

     Through the Platform, Sahaj allows Users to access and participate in online games and contests (“Games”) consisting of free-to-play or pay-to-play skill-based games and contests(collectively known as the "Services").

To use our Services, you need to be of legal age, which means at least 18 years old, as stated in our Terms and Conditions. Our Services are intended for users of legal age and those within India. We don't knowingly collect Personal Information from children below the legal age. If we discover that a child has provided Personal Information, we'll take steps to remove it and close the account. If you're aware of a child/minor's Personal Information being shared, please contact us at hello@sahajgaming.com.

In this Policy, unless explained otherwise, all capitalised terms have the same meanings as in the Terms.

1. Third Parties

Remember, this Policy doesn't cover mobile apps or websites that Sahaj doesn't own or control. This includes third-party websites and apps whose links you might encounter while using our Platform; such third-party websites and apps are governed by their own privacy policies and Sahaj does not exercise any control over them. It is your responsibility to read and understand the privacy policy of such websites/applications when you follow a link outside the Platform. We're not responsible for any harm that might occur when you access third-party sites or links encountered on our Platform. Your use of third-party websites or apps is entirely at your own risk. Sahaj won't be responsible for any transactions between you and third-party services.

ii Collection & Use of Information

A. Personal Information

We obtain and you agree to provide your Personal Information when you register or from third-party services you use through us. This includes:

1. Sign-up & Registration: To sign up and register on the Platform, Users may be required to Provide Information which may include, phone number, email ID, name, location, date of birth, Facebook ID, PAN number, and other government ID such as Aadhaar Card or driving licence or voter ID.
2. Wallet and payments: To access wallets and make payments on the Platform/receive payments from the Platform, Users may be required to provide bank account details, payment method, name, and KYC proof documents.
3. Customer support chats: When you seek help from our support, we collect contact information, gameplay details, user ID, financial information, and chat records. If the option is available, you can also share profile information, like a short bio, location, website, phone number, a picture, and account customization details. In addition to using such information to extend any help that you seek, you acknowledge and agree that we might use this contact information to send you updates about our services.

B. Non-Personal / Aggregated Data

Furthermore, Sahaj may use data management services to access:

• Device information, call and message metadata, storage, device IDs, call data, app history, etc. This helps us understand how Users use our services, improve our platform, analyse player activity, and respond to User preferences.
• Advertisements: Advertisers on mobile devices may use advertising identifiers for personalised ads. These identifiers are not personal and relate to your device. We and others may use this data to provide ads that match your interests and evaluate ad campaign effectiveness.
• Location Services: We and others may collect and store location data for special features, personalised ads, service improvement, and to ensure you're not using the platform from restricted areas.
• Links: We track how you interact with links across our services.
• Log Data: Our servers automatically record data like your IP address, browser type, operating system, referring web page, pages visited, location, mobile carrier, device IDs, search terms, and cookies. This helps us provide and enhance our services.
• Third-Party Services: We use third-party services like hosting. These providers may gather data like cookies, IP addresses, location, and device identifiers.

You acknowledge and consent to the above stated gathering of data.

C. Sensitive Personal Data or Information Collected:

Please note that we always ask for your explicit consent before collecting Sensitive Personal Information (SPI). SPI means such Personal Information which consists of information relating to User account password and your financial information, such as information regarding the payment instrument/modes used by you to make payments, which may include cardholder name, credit/debit card number (in encrypted form) with expiration date, banking details, wallet details, bank account number, bank name, name of account holder, bank statement/passbook front page copy/cheque with User’s name, etc. This information is presented to you at the time of making a payment to enable you to complete your payment expeditiously.

We take utmost care to keep this data safe and only use it for the purposes you've agreed to.

If you choose to pay to play Games or otherwise make any purchases on our Platform, we may collect billing and financial information, including bank details to the extent permitted under applicable laws. This data is stored within such jurisdictions as permitted under applicable law.

Any SPI collected by Sahaj shall not be disclosed to any third-party service provider without your express consent, save as otherwise set out in this Policy or as provided in a separate written agreement between Sahaj and you or as required by law. When we share SPI with any third-party service provider,, we make sure they maintain security standards similar to ours and that they won't disclose the information without our and your consent.

iii. How We Use Your Information

Some of your Personal Information, such as your name or username, may be visible to the public on our Services. This includes your profile page and search results. You agree that we, our third-party partners, and our associates may use your Personal Information for the following purposes and in this regard agree that Sahaj may share your Personal Information with our third-party partners and associates for the following purposes::

• Delivery of the Services
• User Support: We may use it to assist you better.
• Updates and Information: Sending you updates and information about our Services.
• Account Management: Managing your account and your relationship with our Service.
• Enhancing User Experience: Improving the in-app experience and the overall Services.
• Research and Surveys: Conducting research, surveys, and engaging with you.
• Marketing and Promotion: Promoting our Services or other products.
• Personalization: Tailoring and optimising the Services, promotional content, and ads to suit your preferences.
• Reports and Analysis: Creating reports, analyses, or similar services for research and business insights.

Where Sahaj shares your Personal Information with any associate/ third-party partner/affiliate, we will, on a best efforts basis, require them to comply with the same standards as applicable to Sahaj in relation to maintaining the security of the Personal Information.

iv. Information sharing and disclosure

We might share your Personal Information including SPI under the following circumstances, and you agree to this sharing:

1. Provision of Services:

We may share your information with third-party service providers as needed to provide the services you want through our Platform. For instance, to process payments, your information must be shared with payment processors. Here are some examples:

Third-Party Data Recipient Entity Name

Service/Function

Payment gateways and payment aggregators

For making transactions, depositing money and withdrawing money with us

Agency conducting Card-on-file tokenization

To tokenize card details following applicable RBI guidelines.

SMS OTP providers

For generating OTPs

IP Reverse Geolocation Providers

To identify and act against Users in restricted areas.

Analytical and data management service providers

To ensure smooth platform functioning and customization for Users, including sharing data with analytics services and tools.

2. Law Enforcement:

• We may share your information with persons/entities as required by applicable law.
• If necessary under the law, we might disclose your information to government or statutory authorities, courts, or judicial forums.
• We may also share your information when we believe it's needed to respond to valid claims and legal processes, protect Sahaj's property and rights, ensure public safety, prevent illegal or unethical activities, or stop ongoing illegal activities.
• If we need to enforce our rights, we may share your information with relevant persons/entities.

3. Affiliates:

We may share your information with our associate companies, business partners, agents, or third parties for services or any marketing and promotional activities carried out by or on our behalf.

4. Change in Control:

In case another entity legally acquires Sahaj or its Platform, your Personal Information may be transferred as part of that transaction. These Privacy Policy's material terms  will apply to your Personal Information when transferred to the new entity provided that in the event of any material deviation of the applicable terms of this Privacy Policy, you shall be notified of the same.

v. Your Rights

We don't keep your Personal Information longer than necessary unless required by the law. Your Personal Information will be used only as long as:

1. It's needed for the purposes outlined in this Privacy Policy or any agreement with you.
2. Required by laws and regulations, or for evidence.
3. Necessary for tax, fraud control, defence against disputes or claims (considering statute of limitations under applicable laws).

You can review, modify, delete the information you provided to us anytime and withdraw consent for us to collect, process, or transfer your Personal Information by contacting us at hello@sahajgaming.com.  If you withdraw consent, some features, services, etc., that rely on that information may not be available, or we may need to delete it from our records. Your requests won't be fulfilled if they negatively affect another user or their rights.

     

When you request deletion of your Personal Information, we follow a deletion process that ensures that your Personal Information is safely and completely removed from our servers or retained only in anonymised form. We try to ensure that our services protect information from accidental or malicious deletion. Due to this, there may be delays between when your request for deletion and when copies are deleted from our active and backup systems.

Your right to withdraw consent applies to further collection or processing of your Sensitive Personal Information. However, withdrawal won't:

• Delete records needed for statutory purposes.
• Apply if required for ongoing contractual obligations unless the contract requiring Sensitive Personal Information collection is terminated with the withdrawal request.

Your data will be erased or deleted when it has served its purpose, consent is withdrawn, or retention conflicts with applicable law.

Vi. Protecting your Information

Sahaj takes necessary technical and physical measures to safeguard your information against destruction, loss, alteration, unauthorised access, disclosure, and unlawful processing (Security Practices). All data you provide is stored securely on a server in India. These Security Practices include encryption, firewalls, password protection, limited access, de-identification, and physical security measures to prevent unauthorised access to the server and its information.

Sahaj's Security Practices match the information we protect and our business nature. By using the Platform, you accept these reasonable Security Practices designed to protect your information. Your Personal Information, including Sensitive Personal Information (except data subject to data localization due to legal obligations), may be transferred and stored at global locations outside India or your collection location, ensuring a similar level of protection as per applicable Indian laws. However, we can't guarantee that Personal Information can't be accessed, disclosed, altered, or destroyed due to breaches. We take all reasonable steps, including notifying users of breaches when required by law, to ensure secure and compliant Personal Information handling.

Regardless of your location or data supply, you authorise us to use your Personal Information per this Privacy Policy in any country where we operate.

PLEASE NOTE: While we strive to protect your Personal Information, there's no absolute online/internet security. Please avoid sharing Sensitive Personal Information on the Platform if it's not necessary for using our Services. You understand that transmitting information over the internet isn't entirely secure, and there are associated risks. Although we do our best to protect your Personal Information, we can't guarantee its security during transmission to our Platform. Any transmission is at your own risk.

Vii. Term or Duration of Data Retention

We may keep your information as long as needed to achieve the purposes for which it was collected or necessary to provide the Services. This includes situations where we need to comply with legal obligations, meet regulatory requirements, resolve disputes between users, prevent fraud, or for other valid purposes. After such a period, except to the extent required by law, we will delete or anonymize your Personal Information once its purpose has been fulfilled.

Viii. Addressing Grievances

If you have questions about this Policy , or want to exercise your rights regarding your Personal Information, or any complaints, concerns or feedback, contact our Grievance Officer as follows:

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Grievance Officer: Chandhini Jain

Email: hello@sahajgaming.com  

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We'll respond as soon as possible, typically within 30 days but in any event not later than as required under applicable law. 

     

IX. Limitation of Liability

Sahaj confirms that this Policy is only a description of its operation regarding User data. This Policy is not intended to and does not create any legal rights in your favour or in the favour of any other person. Sahaj reserves the right to change this Policy at any time without giving you prior notice. Any changes to our 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. The liability of Sahaj shall be limited to removal of SPI from the system of the Platform and removal of personally identifiable elements in accordance with this Policy.

SAHAJ DOES NOT WARRANT THAT ITS PLATFORM, ITS SERVERS, OR EMAILS SENT BY IT OR ON ITS BEHALF ARE VIRUS FREE. SAHAJ WILL NOT BE LIABLE FOR ANY DAMAGES OF ANY KIND ARISING FROM THE USE OF ITS PLATFORM, INCLUDING, BUT NOT LIMITED TO COMPENSATORY, DIRECT, INDIRECT, INCIDENTAL, PUNITIVE, SPECIAL, EXEMPLARY AND CONSEQUENTIAL DAMAGES, LOSS OF DATA, GOODWILL, BUSINESS OPPORTUNITY, INCOME OR PROFIT, LOSS OF OR DAMAGE TO PROPERTY AND CLAIMS OF THIRD PARTIES.

X. Updating Information

You will promptly notify Sahaj if there are any changes, updates or modifications to your Personal Information. 

XI. Severability

If any court or competent authority deems any part of this Privacy Policy invalid or unenforceable, the other terms remain unaffected. 

XII. Applicable Law and Jurisdiction

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This Privacy Policy is governed by the laws of the Republic of India. Any disputes related to this Privacy Policy fall under the exclusive jurisdiction of the courts in Bengaluru, Karnataka, India.

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