Adda52 Privacy Policy

OBJECTIVE

The objective of this Privacy Policy (“Policy”) is to protect the privacy of persons dealing with Deltatech Gaming Limited (“we", "our", "us" or “Adda52”) and to explain how we collect, use, disclose and store Information in accordance with legal requirements and in order to mitigate operational risks.

OVERVIEW

This privacy policy forms a part of the Terms of Use.

For the purposes of this Policy, any reference to "Services" is a reference to all the products and services offered by us, whether available online or offline. We provide Services via multiple domains.

ASSURANCE OF PRIVACY

At Adda52, our attempt is to offer you a safe, protected and reliable environment to play. Adda52 respects your privacy and thus assures you that any information provided by you to Adda52 is protected and will be dealt with according to this Policy. Adda52 shall not provide, distribute, trade, sell or rent your name, e-mail address or other personal information provided on this site, or information related to your usage of the Website and Mobile Application (collectively, “Adda52”) to any third party, except as provided in this Policy.

Adda52 shall not collect your personal data or information unless -

• the information is collected for a lawful purpose connected with a function or activity of Adda52 or any person on its behalf; and
• the collection of the personal data or information is considered necessary for that purpose.

INFORMATION GATHERED

• Your identity, demographics and any other information shared by you including your name, address, gender, date of birth, occupation, proof of identity, proof of address, contact details, passwords, financial information (including bank account details and bank statement), physical, physiological and mental health condition.
• Your usage/call data records, other device data, including phone numbers, phonebook and contacts information, calendar information, phone location, device details (including device OS-specific identifiers), phone usage, web usage, purchasing habits and browsing history.
• Any detail relating to the above provided to Adda52 for providing Services.
• Your communication history in connection with customer support (e.g., call recording, email or letters).
• Please note that we may collect and process your Aadhaar information to verify your identity. The provision of Aadhaar information is voluntary and not mandated. Should you choose not to provide us with your Aadhaar information, we will provide you with alternate options, such as the submission of your [PAN, passport information, voter’s ID, driver’s license].
• We also maintain a record of the content posted by users on Adda52, or otherwise provided to us when you access or use our website or app, including the location, date, and time of submission, as well as any other information contained in such content.
• We collect information about your preferences in receiving marketing messages from us and our third parties, and your communication preferences.
• We allow players from all states and union territories in India except Andhra Pradesh, Assam, Odisha, Meghalaya, Nagaland, Arunachal Pradesh, Sikkim, and Telangana. In compliance with applicable laws, we will collect location data about you to ensure that only residents of states where real-money poker is permitted are able to access our platforms.
• When you visit Adda52, certain information may also be automatically collected and stored, including the IP address of your computer, mobile phone, browser type and language, the date and the time during which you accessed Adda52, and the address of the website which you may have used to access Adda52.
• When you visit Adda52, cookies may be left in your computer. A cookie is a small text file that uniquely identifies your browser. The cookies assigned by the servers of Adda52 may be used to personalize your experience on Adda52. Moreover, cookies may also be used for authentication, game management and security purposes. In some cases, cookies may collect and store personal information about you. We extend the same privacy protection to your personal information, whether gathered via cookies or from other sources. You can adjust your internet browser to disable cookies or to warn you when cookies are being used. However, if you disable cookies, you may not be able to access certain areas of our web sites or take advantage of the improved web site experience that cookies offer.
• We may also collect information such as time zone settings, operating systems, device information and other technology that you use to access the facilities offered, in order to prevent cheating on the facilities offered through Adda52.
• Cookies may also be assigned by the advertisers of Adda52 when you click on any of the advertisements which may be displayed on Adda52. Such cookies are controlled by the respective advertisers and not by Adda52.

HOW 'ADDA52.COM' USES THE COLLECTED INFORMATION

Your personal information may be used to:

• Verify your identity.
• Assist you to subscribe to Adda52's and/or its associate's products and services.
• Provide the services you require.
• Administer and manage those services.
• Announce the results of any contests.
• Inform you of ways the services provided to you could be improved, or of additional products, services or plans that you may be interested in subscribing to.
• Send you communications. When you register your email address with Adda52, you agree to receive email communication from Adda52, entities specifically authorized by Adda52, and other users on Adda52. You also agree and acknowledge that when you use our referral program to refer someone, Adda52 will send emails to that person on your behalf and the email headers will carry your email address as the address from which such emails are sent. Your personal information is also collected so that Adda52 can promote and market its or its associates’ or any third party services to you (including by way of direct mail, telemarketing, SMS and MMS messages). Adda52 does this to keep you informed of its products, services and special offers as also any promotional offers designed by Adda52 in collaboration with third parties. If you do not wish Adda52 to promote and market its products, services, and special offers to you, please contact our Customer Support.
• Respond to your inquiries, to provide any information that you request, to address technical support tickets, and to provide customer service support.
• Conduct appropriate checks for credit-worthiness and for fraud.
• Research and develop Adda52's and/or its associates' products and services.
• To administer, monitor, improve and customize our Services and platforms, for our internal operations, including troubleshooting, network management and network optimization, research and analytical purposes, so that we can provide our customers with a better customer experience.
• Gain an understanding of your information and communication needs in order for Adda52 to provide you with a better service.
• Maintain and develop Adda52's business systems and infrastructure, including testing and upgrading of these systems.
• To defend any demands, claims and litigations or proceedings arising against Adda52.
• Investigate, prevent or take action regarding illegal activities, fraud, threats to our property or personnel and violations of our Terms of Use and/or applicable law, and also to meet our legal and regulatory obligations.
• Carry out any activity in connection with a legal, governmental or regulatory requirement applicable to us, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.
• The 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, Adda52 cannot guarantee any security for such information.
• When you register with Adda52, your account is protected by means of login information, which includes a username and a password that is known only to you. Therefore, you are responsible for maintaining the confidentiality of your login information including your username and password. Adda52 is not responsible for any activity which is undertaken when your password is used. We suggest that you do not disclose your password to anyone. If you become aware of or reasonably suspect any breach of security, including compromise of your login information, it is your responsibility to immediately notify Adda52.
• Adda52 may contain links to other websites. Such websites are governed by their own privacy policies and Adda52 does not exercise any control over them. It is your responsibility to read and understand the privacy policy of such websites when you follow a link outside Adda52.

WHERE WE DISCLOSE YOUR PERSONAL INFORMATION

In order to deliver the services you require, Adda52 may disclose your personal information, to the extent required, to agencies/organizations outside of Adda52. Your personal information is disclosed to these agencies/organizations only in relation to the services being provided to you and/or in connection with improvisation of our Services through innovations:

• Subsidiaries and affiliates.
• Sales and marketing vendors.
• Business associates/business partners/channel partners/agents/advertisers, who are contractually associated with us for providing any services to us or to our customers, either directly or indirectly.
• Third-party service providers, including third-party customer support service providers.
• Market research agencies.
• Business Transfers. If we are acquired by or merge with another company, or if substantially all our assets are transferred to another company (which may occur as part of merger, demerger, assignment, sale of business and/or on account of liquidation proceedings), or if we file for bankruptcy or become insolvent, we may transfer your personal data to such other company/s. We may also need to disclose your personal data before any such acquisition or merger, for example, to our advisers and any prospective purchaser's advisers.
• Sharing Aggregated and De-Identified Information. We may use your personal data to create aggregated and anonymized information which we may share with third parties. Nobody can identify you from that anonymized information. In certain cases, we may pseudonymise your personal data before sharing it with a third party so that we can re-associate you with the information once it has been processed and returned to us. Whilst the third party will not be able to identify you from the pseudonymised information, we will still be able to. We treat pseudonymised data as though it were personal data and ensure the same level of protection for it when sharing with third parties.
• Adda52 may transfer your personal information to any other body corporate or person in India, or located in any other country, that ensures the same level of data protection that is adhered to by Adda52, provided such transfer of personal information is necessary for the performance of the lawful contract between Adda52 or any person on its behalf with such other body corporate or person in India, or located in any other country.

DATA RETENTION AND DESTRUCTION

You agree and acknowledge that your personal data will continue to be stored and retained by us for as long as necessary to fulfil our stated purposes and for a reasonable period after the termination of your account on Adda52, in compliance with applicable laws.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Upon completion of the retention period for each category of personal data as described above, we shall delete or destroy, to the extent technically possible, personal data in our possession or control, or render the personal data into anonymised data, so that it no longer constitutes personal data, in which case we may use this information indefinitely without further notice to you.

PROTECTION OF CHILDREN

The Services are not intended for or directed at persons under the age of eighteen (18). Where any person informs us that their age is eighteen (18) years or above, it is our policy to uncover the services which may require us to access and verify the person's personal information. If we become aware that a minor has attempted to or has submitted personal information via the Services, we will not accept this information and will take steps to remove such information from our records in a secure manner.

CONSENT

• By using our website, it is understood that you have given your consent to the collection and use of this information by Adda52 and its partners and affiliates.
• In order to play real money games, you will be required to send money to and receive money from us. We may use third-party electronic payment processors and/or financial institutions (“ESPs”) to process such financial transactions. By accepting this Policy, you expressly consent to personal information necessary for the processing of transactions being shared with ESPs. We take steps to ensure that our arrangements with ESPs protect your privacy.
• We reserve the right to conduct a security review at any time to validate your identity, age, the 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 applicable law. By using our website, you authorize us, our staff, agents and suppliers to use your personal information and to disclose your personal information to third parties for the purpose of validating the information you provide to us.
• By filling your mobile number on our site, you are giving us the right to contact you by call/SMS to provide you information on all promotional activity/events conducted by Adda52 and its partners. Your mobile number will not be used for any third-party communication whatsoever.

CONSENT TO USE OF ANTI-CHEATING SOFTWARE

Our software package contains certain features designed to detect use of automated programs that enable artificial (non-human) intelligence to play on our site. Use of such 'bot' software programs violates our Terms and Conditions of Use, where we deem it detrimental to other players. By installing our software and using the Services, you consent to our software performing the functions described in this section. Our software may perform any or all of the following functions in order to detect the use of illicit automated programs and ensure that we maintain a 'cheat-free' environment for all users:

• Scan your list of active software applications while you are using the services;
• Scan your list of active processes while you are using the services; and
• Scan the files in your Services and site-related program folders to ensure that only 'non-hacked' versions of our software are being used. If any of the foregoing processes reveals a suspect application or process, our software may scan the files associated with the suspect application or process and compile a composite mesh (i.e., a profile that characterizes the files associated with the application or process) to be matched against profiles for known illicit automated programs. Our software will not perform any random search of large portions of your hard drive, equipment or files, and it will not transmit any information to us or to any third party other than the information you provide to us.

YOUR LEGAL RIGHTS

Under certain circumstances and subject to applicable laws and the Terms of Use, you may have certain rights in respect of your personal data, such as the right to review and correct your personal data, or revoke or deny consent.

If you wish to exercise any of the rights set out above, please write an email to the Grievance Officer, whose details are mentioned below.

NDNC Policy

By using the website and/or registering yourself at Adda52, you authorize us to contact you via email or phone call or SMS and offer you our Services, impart product knowledge, offer promotional offers running on Adda52 and offers offered by associated third parties, for which reasons personal information may be collected. Irrespective of whether you have registered yourself under DND or DNC or NCPR service, you still authorize us to give you a call from Adda52 for the above-mentioned purposes for a period of three hundred and sixty-five (365) days from your registration with us. This Policy covers Adda52’s treatment of personal information that Adda52 collects when you are on Adda52, and when you use the Services. This Policy also covers Adda52’s treatment of any personal information that Adda52’s business partners share with Adda52. This Policy does not apply to the practices of companies that Adda52 does not own or control or to people that Adda52 does not employ or manage. Adda52 collects personal information when you register for a Adda52 account, when you use certain Adda52 products or services, when you visit Adda52 pages, and when you enter promotions. Adda52 may also receive personal information from our business partners. When you register with Adda52, we ask for your first name, last name, contact number, email, date of birth and gender. Once you register with Adda52 and sign in to our Services, you are not anonymous to us. During registration, you may be requested to register your mobile phone and email ID, pager, or other device to receive text messages, notifications, and other services to your wireless device. By registering with us, you authorize us to send SMS/email alerts to you for your login details and any other service requirements, or certain advertising messages/emails.

CHANGE IN PRIVACY POLICY

We keep our Policy under regular review and may amend it from time to time, at our sole discretion

The terms of this Policy may change and if they do, these changes will be posted on this page and, where required by law, notified to you.

LIMITATION OF LIABILITY

Adda52 cannot protect any information that you make available to the general public in any publicly accessible area of our website or any other media. Adda52 shall not be responsible for any breach of security or disclosure of personal information, unless Adda52 has been proven to be grossly and wilfully negligent.

GRIEVANCE OFFICER

You may contact us with any enquiry relating to this Policy or an enquiry relating to your personal data (including reviewing or updating). You can also do so by writing to our Grievance Officer, Ms. Deepika Poonia, at grievance@deltatech.gg.