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Privacy Policy

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Effective date:  Feb 15, 2022

 

STUDIO SIRAH PRIVATE LIMITED is referred to as “Company” or “We” or “Us” and their connotations. 

 

We provide mobile gaming applications (“Apps”), and operate a website (URL: https://www.studiosirah.com/), to receive game registrations, host online forums, competitions, discussions, in connection with our games (together referred to as “Platform”), operated by Us (“Services”). 

 

We gather certain information with prior consent from the users of our Apps and any visitors of our website (collectively “Users” or “You”). Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms and Conditions.

 

Our User’s privacy is extremely important to us. We recognize the privacy concerns of the Users and hence as a commitment to provide safe and secure experience on our Platform, we have formulated this privacy policy to help Users make an informed decision. 


LEGAL BASIS:

 

This Privacy Policy (‘‘Privacy Policy’’) is meant to help the Users understand what information we collect, why we collect it, what information we disclose and how the Users can update, manage, export, and delete their information.  It shall be read with our Terms and Conditions found on (URL: www.studiosirah.com/legal/terms) and in compliance with the following: 

  1. The Information Technology Act, 2000

  2. The Information Technology (Reasonable Security Practices and Procedures and Personal Information) Rules, 2011 (the “IT Rules”)

  3. The Information Technology (Intermediaries Guidelines) Rules, 2011

  4. Any other applicable laws

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CONSENT:
 

The Users will be deemed to have read, understood and agreed to the terms as provided in this Privacy Policy. By granting their assent to this Privacy Policy,

 

Users provide consent to such use, collection and disclosure of Personal Information as prescribed in this Privacy Policy. 

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We reserve the right to update or change our Privacy Policy at any time and the Users should check this Privacy Policy periodically. 

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Continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute the Users acknowledgment of the modifications and their consent to abide and be bound by the modified Privacy Policy. Users have the right to opt out of the Platform and/ or Services at any moment. In addition, the Users can, by sending an email to hello@studiosirah.com, inquire whether the Company is in possession of their personal data, and they may also require the Company to delete and destroy all such information.

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In the event the Services are used on behalf of any other individual (such as a child/ parent etc.), or on behalf of any entity, the Users represent that they are authorised to accept this Privacy Policy and share such data as required on behalf of such person or entity.


INFORMATION COLLECTED:

All information collected by the Company is with the Users’ consent. The Company is however free to use, collect, and disclose information of the Users which is in the public domain.

 

When Users use / register on the Platform, the Users may provide the Company with certain information voluntarily specific to the nature of the service being availed on the Platform and/or certain information may be collected by the Company. This information may include sensitive personal information as defined under the IT rules (“Personal Information”).

 

The Users hereby consent to the collection of such information by the Company. 

Information collected by the Company shall include but not be limited to the following:

(1)    Information We receive while You visit, register and create account through our website:

  • Name

  • Contact Details (Permanent Address, Correspondence Address, Email ID, Mobile No etc.)

  • Date of Birth, Nationality

  • Age, Gender and other Demographics

(2)    Information We receive while You are playing games through our Apps:

  • Your account information such as username, email ID, name, date of birth

  • device ID and type, details of Your hardware, and software, such as hardware identifiers, mobile device identifier, operating system

  • geolocation of your device

  • in-game behavior

In an event where You use your login or credentials from any third-party social media platform, such as google or any other third party to sign-in for receiving our Services, We collect the username, email address that You make available to Us. This allows the User to use our Services from multiple devices using the same email address. 

 

We collect data such as your username, IP address, the date, time, and we save the content of your messages to allow you to interact with other Users while using our Apps. Additionally, while You are using our Apps, We collect data in connection with your in-game behaviour, such as mascot and other in-game movements.

 

We also collect certain information either when the Users provide it using the Platform or Services and / or automatically as you navigate through the Platform (which may include usage details, IP address, device ID and type, your browser type and language, the operating system used by your device, access times, and information collected through cookies, web beacons and other tracking technologies).

We may also receive information when You participate in Services feedback, questionnaires, surveys, or contests or participating in forums discussions, and competitions.

 

If the Company has reasons to suspect that the information provided by any User is misleading, inaccurate, obsolete or incomplete, the Company reserves the right to refuse provision of the Services to the User, at its sole discretion.

 

USE OF THE INFORMATION COLLECTED:

We collect Personal Information only necessary for the following purposes:

  • To create and maintain your account;

  • To enable you to avail of our Services, and ensure efficient customer care experience and develop new features;    

  • To send surveys or marketing communications to inform you of new products or Services or other information that may be of interest;

  • To improve marketing and promotional efforts, to analyze Platform usage, improve the Platform’s content and Service offerings, and customize the App's content, layout, and Services

  • To dispatch transaction-related communications such as welcome letters and billing reminders;

  • To notify the necessary information related to the App and Services and your account on the Apps from time to time;    

  • To maintain records and provide you with an efficient, safe and customized experience while using the Apps;

  • To analyze overall trends to helps us improve the Apps and Services;

  • Verify your identity and prevent fraud or other unauthorized or illegal activity;

  • To comply with applicable laws, rules, and regulations; 

  • To transfer the data and the rights associated therewith to a third party as part of reorganization or a sale of the assets of any division of the Company or the entire Company itself

  • And in any other way consistent with this Privacy Policy and to support the above activities.

  • Additionally, 

  • We reserve the right to use or disclose your Personal Information in response to any statutory or legal requirements in order to protect our rights, the rights of our other Users, data processors and any other person or property. 

  • Finally, we will use or disclose your Personal Information if we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or property, violations of the Platform’s other policies, or as otherwise required by law when responding to subpoenas, court orders and other legal processes. 

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DATA PROTECTION:
The security of Personal Information is important and We have implemented commercially acceptable means to protect the same. However, remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure and We cannot guarantee its absolute security. We have implemented best industry practices and security policies, rules and technical measures to protect the data including Personal Information that is under the Company’s control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the User’s electronic devices through which the User avails the Services, We shall not be held liable for any loss whatsoever incurred by the User. 

 

In the event, our partners and third parties distribute Personal Information outside the scope of our agreement with such partners or third parties, the Company cannot be held liable for the confidentiality. Further, in case breach of security or actions including without limitation, computer hacking, unauthorized access to computer data and storage device, computer crashes etc., the Company will not be held responsible.
Sharing of Personal Information

 

The Company may share your Personal Information with third party service providers (called ‘data processors’) to perform certain processing activities on our behalf, such as Parties involved in hosting and enabling our Services. Please note that we will not share your Personal Information with third parties allowing them to use this information for their own purposes unless you have given explicit consent thereto. Categories of third-party processors are:
Categories    Legal Requirement 
Storage    To host and store data in connection with our Services.

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Usage Data

The Company may obtain technical and statistical usage related data about Your use of the Services that is non-personally identifiable with respect to You (“Usage Data”), and We may use the Usage Data in any manner it deems fit to analyse, improve, market, support and operate the Services and otherwise to administer our Services. In no event, do We have the ability to identify any User as a source to any Usage Data and You always remain the owner for any non-personally identifiable information that you may share with Us.

 

THIRD PARTY DISCLAIMER:

The Platform may contain links to other websites. Please note that when Users click on one of these links, they are entering another website over which We have no control and for which We will bear no responsibility. Often these websites require the User to enter their Personal Information. We encourage the Users to read the privacy policies of all such websites as their policies may differ from our Privacy Policy. Users agree that We shall not be liable for any breach of your privacy of Personal Information or loss incurred by their use of such websites or services. The inclusions or exclusions are not suggestive of any endorsement by the Company of the website or contents of the website. The Users may visit any third-party website linked to the Platform at their risk. We strongly recommend the Users to read the privacy policies of third-party websites

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Additionally, the Platform may allow for certain content generated by the User, which can be accessed by other Users. Such Users, including any moderators or administrators, are not authorized representatives or agents of the Company and their opinions or statements do not necessarily reflect those of the Company and We are not bound thereby to any contract to that effect. The Company expressly disclaims any liability for any reliance or misuse of such information that is made available by the Users 

 

RIGHTS OF THE USERS: 
As a User, the Company grants complete control of the information submitted. The rights pertaining thereto are enumerated below:

  • The right to access, update or delete the information We have on the User. 

  • This can be done through the User’s account settings available on the Platform.

  • The right of rectification. Users have the right to have their information rectified if that information is inaccurate or incomplete.

  • The right to object and restrict. Users can object and restrict to the processing of their Personal Information. This may however, interfere with the provision of Services to its optimum. 

  • The right to data portability. Users have the right to be provided with a copy of the information We have on you in a structured, machine-readable and commonly used format.

  • The right to withdraw consent. Users have the right to withdraw their consent at any time where consent is given pertaining to Personal Information.

Please note that Users may be asked to verify identity before responding to such requests. If the Users are unable to perform these actions themselves, please get in touch with the Grievance Officer for assistance.


DATA PRIVACY RIGHTS FOR RESIDENTS IN THE EUROPEAN UNION (“EU”):
EU General Data Protection Regulation (“GDPR”) has provided the hereinbelow rights to the EU Residents:

  • The right to information including contact details to the Data Protection Officer (as defined in the GDPR), the purposes for processing Personal Information and the rights of the individual.

  • The right to access the Personal Information that are processed to provide You the Services.

  • The right to erasure (” Right to be forgotten”). You may write to us if You wish to stop using our Service and your Personal Information needs to be erased. However, please understand that We may retain some data, only if such retention is required under applicable laws.  

  • The right to rectification. You may request for rectification of any Personal Information that you submit to Us in case it is inaccurate or needs to be changed.

  • The right to data portability of the Personal Information supplied to Us by the EU resident

  • The right to object and opt-out of processing activity. You may choose to restrict the processing of Your Personal Information and opt-out from our Services, unless We otherwise have compelling legitimate grounds under applicable laws.

 

To exercise any of Your above rights under the GDPR or should You have any questions or comment about this privacy policy and our privacy practices, or to register a complaint or concern please contact us through our Data Protection Officer (“DPO”) at:

Attn: Prateek Shah
Address: WL-4, Sanjeeva Town Bungalows, Rajarhat New Town, Kolkata 700156
Email Address: prateek@studiosirah.com    

 

DATA PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

This California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information We Have collected about them and whether We disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. 

Response Timing: We are required to respond to any of Your verifiable consumer requests to exercise these above rights within 45 days. Should we be unable to comply within 45 days, we will contact you and let you know whether we can complete your request or whether we need more time to complete your request with reason. Any disclosure we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.

Regarding information we sell or disclose to third parties, you have the right to opt out of such sale or disclosure at any time. You can exercise your right to opt out (or any other rights) on our website: https://www.studiosirah.com or by emailing us at hello@studiosirah.com. 

Additional Privacy Rights Available Under CCPA:

  • Non-Discrimination. It is the right of California residents not to receive any discriminatory treatment from Us for the exercise of their rights conferred by the CCPA.

  • Authorized Agent. Only the Users, or someone legally authorized to act on behalf of the Users, may make a verifiable consumer request related to their Personal Information. Users may also make a verifiable consumer request on behalf of their minor children. To designate an authorized agent, please contact Us hello@studiosirah.com and provide written authorization signed by the User and his/her designated agent.

  • Verification. To protect Users’ privacy, We will undertake the following steps to verify Users’ identity before fulfilling their request. When You make a request, We will ask you to provide sufficient information that allows Us to reasonably verify that You are the person about whom we collected personal information or an authorized representative, which may include asking You for additional proof of identity and asking questions regarding your account and use of our Services.

  • California “Shine the Light” law. California’s “Shine the Light” law (California Civil Code Section 1798.83) permits Users of our Services that are California residents to request a list of third parties to whom We have any personal information belonging to any of our Users, for their direct marketing purposes. To make such a request, please contact Us at hello@studiosirah.com

  • Do not track. As per California law, CalOPPA (California Business & Professions Code Section 22575(a)), it is required for Us to let You know how We respond to web browser Do Not Track (“DNT”) signals. DNT is a privacy preference that Users may set in their web browsers. Please acknowledge that we do not respond to such DNT requests at this time.

Sales Of Personal Information Under The CCPA:  The Company does not sell personal information, nor do We possess any actual knowledge of any sale of Personal Information of minors under 16 years of age.
 

CONTACT DETAILS:

Users may contact the Company by email or postal mail on the following address of the Grievance Officer:

STUDIO SIRAH PRIVATE LIMITED 
Grievance Officer: Prateek Shah
E-mail ID: prateek@studiosirah.com
 

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