Privacy Policy | Flecks Labs

Purpose:
We, Fleckslabs Technology Private Limited, incorporated under the Companies Act, 2013 (hereinafter referred to as “Company”, “we”, “our” or “us”) provides video-gaming services (hereinafter referred to as the “Services”) through the website www.fleckslabs.com and mobile applications and gaming platforms available on iOS, Android, Windows, Facebook Gameroom, Mac platforms etc. (hereinafter referred to as the “Platform”) regardless of how you access or use them, including through mobile or any other devices.

This Privacy Policy (“Privacy Policy”/”Policy”) to set out the practices and procedure we will follow regarding the collection, use, storage, retention, disclosure and protection of any personally identifiable information provided by you to us in order to avail of our Services (hereinafter referred to as the “Personal Information”). We ensure our firm commitment to your privacy vis-à-vis the protection of your priceless information.

Any person accessing, browsing, or otherwise using this website, either manually or via an automated device or program, shall be considered as ‘User’ or is addressed as ‘User’ or ‘You’ or ‘registrant’ in this policy.

User’s consent to the Privacy Policy:
All visitors to the Platform are advised to read and understand our Privacy Policy carefully, as by accessing the Platform and availing the Services you agree to be bound by the terms and conditions of this Privacy Policy and consent to the collection, storage and use of information relating to you as provided herein.

This Privacy Policy represents a binding agreement between you and the Company in any questions or concerns regarding this privacy policy, you should contact our Customer Support Desk at contact@flecklabs.com.

We reserve the right to change the terms and conditions of this Privacy Policy from time to time as we deem fit. In view of the above, users are requested to review the changes carefully every time they visit the platform. If you disagree with the Privacy Policy, you should terminate your use of Platform immediately. If you continue to use this website with the amended privacy policy, it will be deemed that you have given your consent.

Collection of information
We shall only use your name and other information, which relates to you, in the manner outlined in this Privacy Policy. We will only collect information where we must do so and we will only collect such information, which is relevant to our dealings with you. We will only keep your information for as long as law either requires us to or as is relevant for the purposes for which it was collected.

The data(s) such as User’s profile will be collected using a safe and smooth procedure when any User registers for services. Information about User’s profile and all those data(s) will ultimately be stored in our database which shall not be disclosed publicly as per Rule 6 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. We have put in place adequate data security measures.

Information is collected directly when you:

Register with us for any of our services etc.
Correspond with us (either by call, e-mail or others)
Create a listing or avail any other service – free or paid

Categories of Information we collect may include:

Personal Information such as name, address, contact numbers, email address, date of birth
Internet Protocol Address (IP), the domain you used to access the Internet, your website URL, the webpage you came from, and webpage you may visit next
Geo-location
Advertising information such as size, type of ad, data, use of advertising channel (if any).
Information collected by cookies/web beacons and other similar technologies
Information derived from your social media access permissions
Your gamer tags
Information regarding your browsing behaviour and pages visited and
any other information regarding your interaction with the Platform.

The information we collect about you will depend on the services that you opt, on an ongoing basis. To the extent possible, we provide you the option of not divulging any specific information that you wish for us not to collect, store or use.

Please note that if you do not allow us to collect all the information we request on the Platform, then we may not be able to deliver your chosen products/Services effectively.

Children under the age of 13 years
We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If you are under 13, please do not attempt to register with us or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to us. In the event that we learn that we have collected personal information from a child under age 13 we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at contact@fleckslabs.com.

Children in the age group of 13 to 18 years
We recommend that minors over the age of 13 ask their parents for permission before sending any information about themselves to anyone over the Internet.

Reasons to collect said information:

Sending promotional/service e-mails
Share current & future updates of the services provided by us or related, affiliated or associated service providers and partners, that we believe would be of interest to you
Responding to your questions, requests, resolving disputes
Personalized Advertisement & Promotional activities
Service improvement
make the Service more suitable for our users
Conduct survey
notify you if you win any contest; and to send you promotional materials from its contest sponsors or advertisers
comply with applicable laws, rules and regulations; and
provide you with information and offers on products and services, on updates, on

You hereby consent to receiving calls, auto-dialled and/or pre-recorded message calls, e-mails, from the Company or its service partners from time to time. You may opt out of such communication either by unsubscribing on the Platform itself, or by contacting the customer services team.

Storage of information:
We only collect and use such information from you that we consider necessary for achieving a seamless, efficient and safe experience, customized to your needs. We use reasonable safeguards to preserve the integrity and security of your information against loss, theft, unauthorised access, disclosure, reproduction, use or amendment. To achieve the same, we use reasonable security practices and procedures as mandated under applicable laws for the protection of your information. Information you provide to us may be stored on our secure servers located within or outside India. You understand and accept that there’s no guarantee that data transmission over the Internet will be completely secure and that any information that you transmit to us is at your own risk. We assume no liability for any disclosure of information due to errors in transmission, unauthorized third party access to our Platform and data bases or other acts of third parties, or acts or omissions beyond our reasonable control and you shall not be entitled to hold the Company responsible for any breach of security. We will hold the information shared by you in the manner described above for as long as we reasonably require for fulfilling the purpose for which we collected such information. This includes for any regulatory, archival purposes, or to protect/defend the Company from any legal claims by anyone.

Device Information: We may collect certain information about the device you use to access the Services, including but not limited to IP addresses for your devices, unique device identifiers, browser types, and browser language.
User History: We may log certain usage information about your use of the Services, which may include a history of the pages you view. If you download and use our platform or application on your device, the log files will automatically be collected by the application and sent to our servers when your device syncs up for the latest content available.
Mobile/Location Information: We may collect additional information from you if you access the Services through a mobile device, for example we may collect your unique device identifier, your device’s operating system, mobile carrier, or your location when you opt in for us to do so. However the degree to which your location can be identified depends on the device you are using (e.g. laptop, smart phone, tablet) and how you are connected to the internet (e.g. via cable broadband connection, Wi-Fi, etc.). If you enable location services for the Services we may collect your regional location data periodically as you use or leave open the Services. We may also collect your location information from your IP address.
We may also use location data internally or in conjunction with our third party service providers to customize your experience and provide offers that may be relevant to you. Depending on the device you use to access the Services (e.g. Apple™ iOS, Google™ Android, Windows, etc.) you may be able to control whether location data is collected from the settings on your wireless device.

Retention period
We retain your personal information as long as it is necessary and expedient for our operations. Besides, we may retain personal information from closed accounts to comply with national laws, prevent fraud, collect any payment owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our terms of use and take other actions permitted or required by applicable Indian laws. In the event it is no longer required for us to retain your personal information, we dispose-off in a secure manner according to our relevant policies.

User Rights
User may at any time request information about the data, which we hold about the user as well as about their origin, recipients or categories of recipients to which such data is forwarded.
User may request immediate correction of any incorrect personal data related to them or opt for a restriction of the processing. The user is also entitled to request completion of incomplete personal data also by means of a supplementary declaration.
You can opt-out of interest-based advertising on mobile applications by writing to us.
In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please contact us using the information below. Please note that to ensure that we do not collect any further information you should also delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form.
User is entitled to receive the respective personal data provided to us in a structured, common, and machine-readable format and user is entitled to transmit such data to other data controllers without restriction if the processing was based on user consent or if the data was processed by means of automated procedures.
User may withdraw the given consent to the use of his/her data at any time.
If you have created an account with us, you can ask us to deactivate that account by contacting us using the information above. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items, will be lost and we may not be able to restore them in the future.

Cookies:
We use data collection devices such as "cookies" on certain pages of our Websites. "Cookies" are small files sited on your hard drive that assist us to identify you and provide you with customized services, and make the Platform more user friendly. We also offer certain features that are only available through the use of a "cookie". Cookies can also help us provide information, which is targeted to your interests. Cookies may be used to identify logged in or registered users. Most browsers will permit you to decline cookies but if you choose to do this, it might affect the Services on some parts of the Platform. We might also use other technology to track how you interact with the Platform and/or employ some third party agencies to use the data on our behalf.

External links:
The Platform may include hyperlinks to other web sites or content or resources (“Third Party Site(s)”). We have no control over any websites or resources, which are provided by companies or persons other than us. If you choose to use any services provided on a Third advertising, products or other materials on, or available from Third Party Sites. These Third-Party Sites and the entities which operate the same may have their own privacy policies governing the storage and retention of your personal information that you may be subject to. We recommend that when you enter a Third-Party Site, you review the Third Party Site’s privacy policy as it relates to safeguarding your personal information. We use third-party advertising companies to serve ads when you visit the Platform.

Marketing communications
We will respect your wishes not to receive marketing communications. You can change your marketing preferences by contacting us. Please note that we will continue sending you service-related communications regardless of any opt-out request.

Recorded communications
We may record calls for training, quality and research purposes. All recordings will be treated as confidential. If you do not want us to record your call, you will be given a chance to opt out. If your call is already in progress, you may ask us to turn off the recording at the start of the call.

Confidentiality
We restrict access to your Information to employees who we have determined need it in order to provide products or services to you. We train our employees to safeguard customer information, and we require them to sign confidentiality and non-disclosure agreements. We maintain strict physical, electronic, and procedural safeguards to protect your Information from unauthorized access by third parties.

Dispute resolution and Jurisdiction
It is expressly agreed to by the Parties hereto that the formation, interpretation, and performance of this Policy, and any disputes arising from here will be resolved through a two-step Alternate Dispute Resolution (“ADR”) mechanism. It is further agreed to by the Parties that the contents of this Section shall survive even after the termination or expiry of the Policy and / or Terms.

a) Mediation: In case of any dispute between the parties, the Parties will attempt to resolve the same amicably amongst themselves, to the mutual satisfaction of both Parties. If the Parties are unable to reach such an amicable solution within ninety (90) days of one Party communicating the existence of a dispute to the other Party, the dispute will be resolved by arbitration, as detailed hereinbelow.

b) Arbitration: If the Parties are unable to amicably resolve a dispute by mediation, said dispute will be referred to arbitration by a sole arbitrator to be appointed by us, and the award passed by such sole arbitrator will be valid and binding on both Parties. The Parties shall bear their costs for the proceedings, although the sole arbitrator may, in his / her sole discretion, direct either Party to bear the entire cost of the proceedings. The arbitration shall be conducted in English, and the seat of Arbitration shall be in the city of Hyderabad, India. The arbitral process shall follow the applicable laws of India.

The Parties expressly agree that the Privacy Policy, Terms of Use and any other agreements entered into between the Parties, such as Vendor Agreement are governed by the laws, rules, and regulations of India, and that the Courts at Mumbai shall have exclusive jurisdiction over any disputes arising between the Parties.

The Parties expressly agree that the Privacy Policy, Terms of Use and any other agreements entered into between the Parties, such as Vendor Agreement are governed by the laws, rules, and regulations of India, and that the Courts at Mumbai shall have exclusive jurisdiction over any disputes arising between the Parties.

Grievance redressal mechanism
Any complaints or request or concerns with regards to use, processing or disclosure of information provided by you or breach of these terms may be taken up with the designated grievance redressal officer as mentioned below via post or by sending an email at contact@fleckslabs.com to Mr. Akash Agrawal.

We request you to please provide the following information in your complaint:
a) Identification of the information provided by you.
b) Clear statement as to whether the information is personal information or sensitive personal information.
c) Your address, telephone number or e-mail address.
d) A statement that you have a good-faith belief that use of the information has been processed incorrectly or disclosed without authorization.
e) A statement, that the information in the notice is accurate, and that you are authorized to act on behalf of the owner of the right that is allegedly infringed.

We shall not be responsible for any communication, if addressed, to any non-designated person in this regard.

DISCLAIMER We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy due to the inherent limitations of electronic communications. As a user of the Platform, you understand and agree that you assume all responsibility and risk for your use of the Platform, the internet generally, and the documents you post or access and for your conduct on and off the Site.

Information is collected directly when you:

Register with us for any of our services etc.
Correspond with us (either by call, e-mail or others)
Create a listing or avail any other service – free or paid

Categories of Information we collect may include:

Personal Information such as name, address, contact numbers, email address, date of birth
Internet Protocol Address (IP), the domain you used to access the Internet, your website URL, the webpage you came from, and webpage you may visit next
Geo-location
Advertising information such as size, type of ad, data, use of advertising channel (if any).
Information collected by cookies/web beacons and other similar technologies
Information derived from your social media access permissions
Your gamer tags
Information regarding your browsing behaviour and pages visited and
any other information regarding your interaction with the Platform.

Please note that if you do not allow us to collect all the information we request on the Platform, then we may not be able to deliver your chosen products/Services effectively.

Children in the age group of 13 to 18 years
We recommend that minors over the age of 13 ask their parents for permission before sending any information about themselves to anyone over the Internet.

Reasons to collect said information:

Sending promotional/service e-mails
Share current & future updates of the services provided by us or related, affiliated or associated service providers and partners, that we believe would be of interest to you
Responding to your questions, requests, resolving disputes
Personalized Advertisement & Promotional activities
Service improvement
make the Service more suitable for our users
Conduct survey
notify you if you win any contest; and to send you promotional materials from its contest sponsors or advertisers
comply with applicable laws, rules and regulations; and
provide you with information and offers on products and services, on updates, on

Information we collect automatically:
When you use the Services, we (or our third party partners) may collect information about your device and usage of the Services.. We may use a variety of technologies (collectively, “Tracking Technologies”) to collect some of this information.

We may use Tracking Technologies to automatically collect the information described below:

Device Information: We may collect certain information about the device you use to access the Services, including but not limited to IP addresses for your devices, unique device identifiers, browser types, and browser language.
User History: We may log certain usage information about your use of the Services, which may include a history of the pages you view. If you download and use our platform or application on your device, the log files will automatically be collected by the application and sent to our servers when your device syncs up for the latest content available.
Mobile/Location Information: We may collect additional information from you if you access the Services through a mobile device, for example we may collect your unique device identifier, your device’s operating system, mobile carrier, or your location when you opt in for us to do so. However the degree to which your location can be identified depends on the device you are using (e.g. laptop, smart phone, tablet) and how you are connected to the internet (e.g. via cable broadband connection, Wi-Fi, etc.). If you enable location services for the Services we may collect your regional location data periodically as you use or leave open the Services. We may also collect your location information from your IP address.
We may also use location data internally or in conjunction with our third party service providers to customize your experience and provide offers that may be relevant to you. Depending on the device you use to access the Services (e.g. Apple™ iOS, Google™ Android, Windows, etc.) you may be able to control whether location data is collected from the settings on your wireless device.

Retention period
We retain your personal information as long as it is necessary and expedient for our operations. Besides, we may retain personal information from closed accounts to comply with national laws, prevent fraud, collect any payment owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our terms of use and take other actions permitted or required by applicable Indian laws. In the event it is no longer required for us to retain your personal information, we dispose-off in a secure manner according to our relevant policies.

We shall not be responsible for any communication, if addressed, to any non-designated person in this regard.

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