Probabilistic Synergies Private Limited,having its registered office at L-148, 5th Main Road, Sector 6, HSR Layout, Bengaluru, Karnataka - 560102 ("PSPL") owns and operates the ‘TUG’ mobile application and fantasy game platform (the “Platform”). Through the Platform, PSPL offers free to play and pay-to-play versions of a cricket based online fantasy game (“TUG Game”) wherein users participating in the TUG Game may build their Team using the bidding and trading instrumentalities made available in the TUG Game.
This Privacy Policy (“Policy”) forms part of the Platform’s Terms and Conditions of Use (“Terms”) available at https://tuguniversal.com/terms-of-use.
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. “We”, “Us” or “Our” shall mean PSPL, its employees, and authorised agents that perform any services on PSPL’s behalf in relation to the Platform.
By accessing or using the Platform in any manner or by using any content or information provided through the Platform, You shall be deemed to have read, understood, accepted and agreed to be bound by the Terms and this Policy . By accepting the Terms and Policy on the registration page, You consent to provide sensitive personal data or personal information requested at the time of registration, and are aware of the purpose of sharing such information. Please do not register if You do not wish to share the mandatory sensitive personal data or personal information with PSPL, requested at the time of registration. Registration procedure cannot be completed until information in the non-optional fields is provided. We may request certain additional personal data for (i) permitting You to access certain portions of the TUG Game; (ii) extending certain services to you on the Platform; and (iii) to address any query/grievance raised by you. Any information shared by You in furtherance of such requests from Us shall be information You agree You have consented to share and which shall be governed by the terms of this Policy. Capitalised terms not defined herein will have the meaning ascribed to them in Our Terms.
1. Policy Objective
PSPL respects Your privacy and assures You that any information provided by You to PSPL is protected and will be dealt with according to this Policy and the applicable laws in India. To avail the services offered on the Platform, You may have to provide certain information to Us. This Policy provides the procedure followed by PSPL to gather, use, store, disclose and manage Users’ personal data. PSPL only collects, stores, uses and manages Users’ personal data for the purpose of verifying User Accounts, maintaining the Accounts of the Users, completing transactions of the Users, facilitating the Users’ use and access of the Platform and participation in Contests therein, and for analysing User behaviour and requirements.
2. What is included in personal data?
User's personal data includes the following types of personal data or information:
(a) Sensitive Personal Data: such as User Account password and financial information such as bank account number, bank name, bank branch name and address, name of account holder, bank statement/passbook front page copy/cheque with User’s name, or other payment instrument details.
(b) Other Personal Information: such as name, gender, date of birth, telephone number, mobile number, postal/contact address, email address, copies of photo-identity proof and address proof like voter ID / driving license, IP address of Your computer/device, browser type and language, mobile operating system type, date and the time during which You accessed the Platform, Your photograph for testimonials and other promotions and such other information that is defined as personal data or information in law.
3. User Consents
(a) All Users of the Platform consent to the use of Sensitive Personal Data and Other Personal Information for the purpose stated in this Policy. We restrict access of personal information to Our employees, contractors and agents and only allow access to those who need to know that information in order to process it on Our behalf.
(b) Users are entitled to withdraw consent for use of Their Sensitive Personal Data or Other Personal Information by emailing a specific request. Withdrawal of consent with respect to all or any part of the Sensitive Personal Data and Other Personal Information may result in immediate withdrawal of any right to avail the services provided by PSPL on the Platform. Withdrawal of consent shall not restrict the right of PSPL to use Other Personal Information for analysis of User data, subject to the condition that the Other Personal Information used in any analysis is not personally identifiable to any individual User.
(c) Photographs once provided by You for marketing purposes gives PSPL irrevocable and unlimited rights to use the same and it is completely at PSPL's discretion to delete or not use it any further.
(d) PSPL may also use software applications for Platform traffic analysis and to gather statistics, used for advertising and for determining the efficacy and popularity of PSPL and the Platform among others.
4. Consent to use of Cookies:
A cookie is a small text file that uniquely identifies Your browser. You understand that when You visit the Platform, cookies may be left in Your devices. The cookies assigned by the servers of PSPL may be used to personalize Your experience on the Platform. Additionally, cookies may also be used for authentication, game management, data analysis and security purposes. The advertisers of PSPL may also assign cookies when You click on any of the advertisements, which may be displayed on the Platform in which case such cookies are controlled by these advertisers and not PSPL.
5. Consent to email communication:
When You register with PSPL and provide Your email address and mobile number with PSPL (“Communication Channels”), You agree to receive communications from PSPL, entities specifically authorized by PSPL and other Users through such Communication Channels. You also agree and acknowledge that when pursuant to PSPL’s offering of a referral program, You use Our referral program for referring someone, PSPL will send emails to such person referred by You on Your behalf and the email headers will carry Your email address as the address from which such emails are sent.
6. Data Security
(a) We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of Our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where We store personal data. PSPL has a comprehensive information security program and information security policies, which contain managerial, technical, operational and physical security control measures adopted by PSPL for the protection of Sensitive Personal Data and Other Personal Information.
(b) Information gathered by PSPL is stored securely using several information security applications including firewalls. However, security is always relative and PSPL cannot guarantee that its security measures are absolute and cannot be breached. Data, which is transmitted over the internet, is inherently exposed to security risks or threats. For instance, information transmitted via chat or email can be compromised and used by others. Therefore, PSPL cannot guarantee any security for such information in the course of transmission through the internet infrastructure or any unsolicited disclosures made by any User availing the services of the Platform.
(c) When You register with PSPL, Your Account is protected by means of login information, which includes a username and a password that is known only to You. Therefore, You should not provide Your personal information to anyone whosoever and breach hereof constitutes violation of this Policy and can also result in closure of Account in certain cases. 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 PSPL.
(d) The Platform may contain links to other websites or applications. Such websites/applications are governed by their own privacy policies and PSPL 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. You are advised to exercise caution in sharing any personal information with any third party that advertises on the Platform and PSPL shall not be responsible for such information provided by You on/with third party websites/applications.
(e) PSPL has a policy of not sharing any personally identifiable information with anyone other than entities specifically authorized by PSPL, which may include advertisers, vendors, service providers and sponsors of PSPL. However, PSPL may use Your name, photo, login ID, team name and the state of Your residence or from where You are participating when announcing the results of any Contests run on the Platform. Such Contests are further governed by terms and conditions which shall be available on the Platform as and when such a Contest is run on the Platform. PSPL conducts periodic analysis and survey of the traffic to the Platform for market research and advertising purposes. PSPL reserves the right to share Your registration information with PSPL appointed market research and advertising companies or firms from time to time for the said purposes. PSPL may also use cumulative non-personal information for auditing and analysis purposes with the aim of improving its services.
7. Exclusions
PSPL may share Sensitive Personal Data and Other Personal Information if sharing of such information is necessary:
(a) to comply with legal processes or governmental request;
(b) to enforce the Terms and this Policy;
(c) for prevention of fraud, money-laundering or any other illegal act;
(d) for issues involving information security; or
(e) to protect Your rights, rights of PSPL and rights of the general public.
8. Retention of Personal Data
Your personal information may be retained and may continue to be used until: (i) the relevant purposes for the use of Your information described in this Policy are no longer applicable; and (ii) We are no longer required by applicable law, regulations, contractual obligations or legitimate business purposes to retain Your personal information and the retention of Your personal information is not required for the establishment, exercise or defence of any legal claim.
9. Change of Control
In the event that ownership or control of the Platform was to change, Your personal information may be transferred. If such a transfer results in a material change in the use of Your personal information, PSPL will provide notice about the choices You have, to decline to permit such a transfer.
10. Limitation of Liability
PSPL confirms that this Policy is only a description of its operation regarding User information. This Policy is not intended to and does not create any legal rights in Your favour or in the favour of any other person. PSPL reserves the right to change this Policy at any time without giving You prior notice. The liability of PSPL shall be limited to removal of Sensitive Personal Data from the system of the Platform and removal of personally identifiable elements of the Other Personal Information.
11. Contact Us
Any questions or clarifications with respect to this Policy or any complaints, comments, concerns or feedback can be mailed to hflplatform@tuguniversal.com.
PSPL DOES NOT WARRANT THAT ITS PLATFORM, SERVERS, OR EMAILS SENT BY IT OR ON ITS BEHALF ARE VIRUS FREE. PSPL 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. IN NO EVENT WILL PSPL BE LIABLE FOR ANY DAMAGES WHATSOEVER IN AN AMOUNT IN EXCESS OF AN AMOUNT OF INR 100.