PRIVACY POLICY

Effective Date: [Insert Date]

We, at Funto, arecommitted to protecting the privacy of individuals who visit or use the Platform as per this privacy policy (“Privacy Policy”). This Privacy Policy is incorporated into Our Terms and applies only to personal information collected through the Platform from any User accessing the Platform. Terms not defined in this Privacy Policy shall have the meaning assigned to them under the Terms.

By accessing and/or using the Platform, You consent to the collection and use of the personally identifiable information and other information in accordance with the Terms and this Privacy Policy. If You do not agree to any or all of the terms contained herein, do not use the Platform or participate in any Game. Should You continue to access and use the Platform and provide Your Personal Information, such act would constitute Your consent the terms of this Privacy Policy.

1. General Anonymity

Individual users who visit the Platform will remain anonymous unless they voluntarily tell us who they are. However, we may track the internet domain address from which visitors who visit the Platform and analyse the data for trends and statistics. You will be required to create an Account to use any Services or play any Game/s on the Platform.

2. Information We Collect

We are committed to transparency in Our data collection practices. We collect the following categories of information from Users who interact with the Platform or avail any Services:

a) Personal Information: Personal Information refers to data that identifies or can be used to identify an individual. You may voluntarily provide us with personal information when You register, play, make in-game purchases, or interact with the Platform, Services or the Games. This information may include, but is not limited to, the following:

When You create an account or play the Game:

• Mobile number;

When You make payments or conduct financial transactions:

• Payment method details (e.g., UPI ID, masked card details, wallet ID) as collected by Our integrated payment gateways;
• Transaction reference number or ID;
• Transaction status and timestamps;
• Billing-related details (if applicable);
• Any other information required to complete Your payment securely.

When You complete KYC verification (if required):

• Full name as per government ID;
• Date of birth;
• Government-issued identification details (e.g., PAN, Aadhaar, or other documents);
• Address proof;
• Selfie or live photo (if applicable);
• KYC verification status and date.

When You interact with Our support, grievance, or promotional features:

• The nature and content of Your message or inquiry;
• Voice Communication records;
• Any other details You voluntarily provide during support or promotional activities.

You must ensure to provide Us with the correct or up-to-date information at the time of creation of Your Account, Your Profile and anytime during Your use of the Platform.

We collect and process this personal information to enable Games, gameplay, verify Your identity (if required as per applicable laws or industry practices), facilitate payments, respond to Your queries, provide the Services and the Platform, improve the Platform, the Games and Services including its features and functionalities and ensure a safe and compliant gaming environment as further detailed in the below sections.

b) Non-Personal Information: When You access or play Our Games, certain technical and analytical data may be collected automatically through cookies, device identifiers, and other tracking technologies. This "Non-Personal Information" does not directly identify You but helps us enhance Your experience and understand user behavior, and it outside the purview of this Privacy Policy. Such information may include:

• Browser and device information: Type of device, model, operating system, OS version, screen size, and device language;
• IP address: A numerical label that may indicate Your approximate location;
• Time zone settings and locale preferences;
• Device type: Mobile, tablet, or other platforms used to access the Game;
• Referral source: How You arrived at the Game (e.g., website, ad campaign, referral link);
• Game usage analytics: User actions, in-game behavior, gameplay duration, game progress, crash logs, and error reports;
• Cookies or similar technologies: These help us remember user preferences, maintain session data, analyze performance, and deliver a more personalized experience. You may disable these via Your device settings, though certain features may be affected.

3. Use of Personal Information

We collect and use Your personal information in accordance with applicable Indian laws, industry practices, and for legitimate business purposes. The purpose of this collection is to ensure a seamless, secure, and personalized experience on the Platform.

a) AccountSetup and Management

Personal information voluntarily submitted by You during registration or account setup, including Your name, username, contact details, and gameplay preferences, is used to create and manage Your Account. This enables participation in multiplayer Games, access to leaderboards, communication between Players (where permitted), and personalization of Your gameplay experience.

b) Offering and improving Our Services.

c) PaymentProcessing and Wallet Services

For transactions involving in-app purchases, wallet recharges, contest entry fees, platform fee, or prize withdrawals, We collect payment-related information including transaction IDs, payment details and billing logs. These are securely processed via PCI-DSS-compliant third-party gateways to ensure payment accuracy, transaction reconciliation, and fraud prevention.

d) KYC and Identity Verification

To comply with legal requirements and for withdrawal, fraud prevention, or age verification, we may collect Know Your Customer (KYC) documentation such as PAN, Aadhaar, and bank account details. This data is used strictly for identity verification, processed securely, and accessed only by authorized personnel or trusted service providers in accordance with Indian laws.

e) CustomerSupport and User Queries

When You reach out through the “Contact Us” form or email, we use the provided information (name, email, phone number, and message) to respond to Your inquiries, assist with gameplay or account issues, and improve our support services. These communications may be recorded to help enhance Our service quality.

f) Communication and Notifications

We may use Your contact information to send essential service-related messages (e.g., changes to terms, account updates), as well as optional communications such as promotional offers, surveys, event notifications, and referral rewards. You can opt out of promotional content, but service-related messages will continue to ensure Your Account’s functionality.

g) Legal andRegulatory Compliance

Your personal information may be used and retained to meet obligations under Indian laws, including but not limited to the Information Technology Act, anti-money laundering rules, taxation laws, and gaming regulations. This may involve disclosing data to government, authorities, law enforcement, or courts, where required by law.

h) Security, Risk Management, and Fraud Prevention

We process personal data to detect and prevent fraud, hacking, unfair gameplay, or unauthorized Platform use and enforce Our policies. This includes monitoring user behaviour to ensure compliance with Our Terms, protect intellectual property, and maintain Platform’s integrity for all Users.

i) ServiceImprovement and Product Development

To develop new features, functionalities, Games, contests, game modes, or user experiences based on emerging trends. It also helps Us refine existing gameplay mechanics and content for greater engagement and satisfaction.

j) Personalization and Regional Customization

Where applicable, We may use Your location or language preferences to offer localized content, language-specific support, and region-based offers, enhancing Your overall experience on the Platform in line with India’s diverse user base.

k) ResponsibleGaming and Age Controls

We may implement features such as session limits, spending caps, or self-exclusion mechanisms to promote responsible gaming behaviour. These measures are especially important for real-money games and are based on user behaviour analysis and legal guidelines.

l) Analytics , Reporting, and Business Operations

Your personal information may be used to generate internal reports, monitor the Platform, the Games, Your and Our performance, evaluate marketing effectiveness, and support strategic decisions. This includes ensuring business continuity during updates, audits, or structural changes such as mergers or acquisitions.

m) Third-Party Integrations

To enhance Your experience, we may integrate with third-party tools or partners (e.g., analytics services, payment gateways, social logins). Information shared with these partners is limited to what is necessary, and handled securely in compliance with applicable data protection standards.

4. Disclosure of Information

We are committed to maintaining the confidentiality, integrity, and security of Your personal information. We do not sell, trade, or rent Your personal data to third parties for marketing or commercial purposes.

We may share or disclose Your personal in limited circumstances as outlined below, strictly in accordance with applicable laws, including the Information Technology Act, 2000, the rules framed thereunder, and the Digital Personal Data Protection Act, 2023.

a) Internal Access by Authorized Personnel: Your personal data, including information submitted during registration, gameplay, payments, or KYC verification, may be accessed by authorized personnel of the Company on a strict need-to-know basis. This includes employees, advisors and/ or consultants who are involved in customer support, technical operations, fraud prevention, regulatory, legal and other compliances. All such personnel are bound by confidentiality obligations and are required to process Your information with care, professionalism, and in compliance with this Privacy Policy and internal data handling protocols.

b) Disclosure to Third-Party Partners, Vendors and Service Providers : We may share limited personal information with trusted third-party service providers for providing the Games, the Services and the Platform. This includes but is not limited to payment gateway providers, KYC verification vendors, cloud storage providers, IT security consultants, and data analytics partners, etc. These service providers are contractually bound to use Your personal data solely for the purpose of rendering their services to Us, maintain its confidentiality, and implement appropriate security safeguards in compliance with Indian data protection laws. They are not permitted to use Your personal information for any unrelated or unauthorized purposes. We may store and process Your personal data using third-party cloud hosting services and software located within or outside India.

c) Legal and Regulatory Compliance: We may disclose Your personal information to government bodies, statutory bodies, regulatory authorities,, law enforcement agencies, regulators, or other competent bodies when such disclosure is required by applicable law, judicial proceedings, or a valid legal process. This may include disclosures made in the interest of national security, to respond to notices, court orders, tax or regulatory investigations, or to protect Our rights, Users, or the public at large. Any such disclosure will be made in good faith and in accordance with the legal principles of necessity and proportionality.

d) Business Transfers: In the event of a merger, acquisition, restructuring, investment transaction, or sale of all or part of Our business or assets or the Platform, Your personal information may be transferred to the relevant successor entity, legal representatives, or advisors. Such transfers will be subject to appropriate confidentiality and data protection obligations, and the successor entity will be required to honour the commitments under this Privacy Policy or another policy that provides comparable safeguards.

e) Consent-Based Disclosures:In situations where You have expressly consented to the sharing of Your information, whether verbally or as part of the specific terms and conditions of the Game, tournament, contest or offer, such as social media integrations, public leaderboards, or referral programs, We will disclose Your information to the relevant parties as accordingly.

5. Data Retention

We are committed to ensuring that Your personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, or to comply with applicable legal, regulatory, contractual, or statutory obligations under Indian law, including gaming laws, taxation regulations, and other industry-specific requirements.

a) General Retention: We maintain data retention protocols to ensure personal data is not stored indefinitely. We retain Your personal information only as long as it is required to provide You with the Our Services, respond to Your inquiries, process payments, verify KYC details, or fulfill other legitimate business needs related to Your interaction with the Platform. Once these purposes are fulfilled, We will securely delete or anonymize the data unless a longer retention period is required or permitted by law.

b) Retention of KYC and Payment Data: In compliance with regulatory and anti-money laundering laws, We retain KYC (Know Your Customer) data and payment information for the duration necessary to meet legal obligations, such as verifying identity and processing in-game purchases or rewards. This data will typically be retained for a period of up to five (5) years from the date of collection, or such longer period as required by applicable laws. If You request the deletion of Your KYC or payment data earlier, We will comply, except where retention is mandated by law.

c) Retention of User Data for Game-Related Purposes: We may retain Your gameplay data, including game statistics, transaction history, and user interactions within the game, for as long as You maintain an active account or use the Platform. This data is necessary for providing a seamless gaming experience, tracking user activity, and resolving any issues related to the gameplay. If You decide to stop using the game or delete Your account, We will retain this data for a period of up to one (1) year to ensure proper management of account status or such longer period as required under applicable laws.

d) Legal or Regulatory Retention Requirements: In certain circumstances, such as ongoing investigations, litigation, or audits related to Your use of the Platform, We may need to retain Your personal information for a longer duration. This includes data related to transactions, KYC, or game-related issues that could be involved in legal or regulatory processes. In these cases, Your data will be securely stored and its use will be restricted to compliance with legal obligations.

e) Secure Disposal: Once the applicable retention period has expired or upon Your valid request for erasure not prohibited by any applicable laws, We will ensure that Your personal data is securely deleted or anonymized. We will apply industry-standard measures, including encryption and secure disposal methods, to ensure that Your personal data is not accessible or misused in any way.

6. Cookies and Tracking

We may use cookies and other similar tracking technologies (such as web beacons, pixel tags, or local storage) to enhance the functionality, performance, and user experience of Our Services and associated Platform. These technologies help us understand how players interact with the game, analyze in-game behavior, monitor game performance, maintain security, and personalize content to better suit Your preferences and gaming experience.

Cookies are small data files placed on Your device (such as a computer, tablet, smartphone, etc.) when You access the Games through Our Website. Depending on the type of cookies used, they may store user preferences, enable core game features, assist in gameplay analytics, or help us troubleshoot issues to continually improve the gaming experience.

Types of Cookies We Use:

a) Essential Cookies: These cookies are necessary for the basic functionality of the Website, such as logging into Your account, saving Your game progress, and ensuring smooth gameplay.

b) Performance and Analytics Cookies: These cookies help us gather information on how You interact with the game, track Your gaming sessions, and analyze game performance. This data helps us improve the features and overall user experience of the Platform.

c) Functionality Cookies: These cookies enable us to remember Your preferences (e.g., language settings, game customizations) so that You can enjoy a personalized experience each time You play.

You have the option to manage or disable cookies through Your browser or device settings. Most web browsers allow users to control cookie behavior, including accepting, rejecting, or deleting cookies. Please note that disabling certain types of cookies may affect the functionality of Games and may result in a less optimal gaming experience.

By continuing to use Our Services without changing Your browser settings, You consent to Our use of cookies and similar technologies in accordance with this Privacy Policy.

7. Security Measures

We are committed to ensuring the confidentiality, integrity, and protection of Your personal information. We understand the importance of safeguarding Your data and have implemented robust security practices and procedures to protect it from unauthorized access, disclosure, alteration, or destruction. In compliance with applicable laws, including the Information Technology Act, 2000, and other relevant regulations, We make every reasonable effort to maintain the highest standards of security for Our players.

a) Use of Secure Servers and Firewalls: The personal information You provide when interacting with the Platform is stored on secure servers, and We employ industry-standard firewalls and encryption technologies to protect against unauthorized access.

b) Access Control Mechanisms: We employ strict access control mechanisms to limit access to Your personal data within Our internal systems.

c) Continuous Monitoring and Risk Management: To further enhance security, We regularly monitor Our systems for any potential vulnerabilities or unauthorized access attempts. In addition, We perform security assessments and audits to ensure that Our security protocols remain effective and up-to-date. Any suspicious activities or potential risks are promptly addressed to prevent any data breaches or security incidents.

d) Limitations and Acknowledgment of Risk: Despite implementing advanced security measures, it is important to acknowledge that no method of electronic transmission or storage of data can be guaranteed to be 100% secure. While We strive to protect Your information using the best available technologies, the internet is an inherently insecure environment, and risks remain in transmitting data over the web. As such, We cannot guarantee the absolute security of any personal information You transmit to Us through the Platform or store within Our systems. By using Our Services, You acknowledge and accept this inherent risk and agree to hold Us harmless for any security breaches that may occur.

8. No Access

We are committed to safeguarding the privacy of Our Users and strictly prohibit the use of the Platform by individuals under the age of 18 years. We do not knowingly collect, solicit, or process personal information from minors. If You are under 18 years of age, You are not permitted to use the Platform, and We request that You do not submit any personal information. In the event that We become aware of any personal information inadvertently collected from a minor without proper consent, We will promptly delete such information from Our records.

9. Third-Party Links and External Websites

The Platform or Services may include links to third-party websites, platforms, or services that are not operated or controlled by Us. These external websites are governed by their own privacy policies and terms of use, and We do not have any control over how they collect, use, or protect Your personal information.

We make no representations or warranties regarding the privacy practices, security measures, content, or data processing activities of such third-party websites. We strongly encourage You to review the privacy policies and terms of use of these external websites before providing any personal data or interacting with their services.

By accessing third-party websites or application, You do so at Your own risk. Your interactions and transactions with these third parties, including the submission of personal data, are solely between You and the third party concerned. We are not responsible for any privacy or security issues that may arise from Your engagement with these external websites.

10. Updates to This Privacy Policy

We reserve the right to revise, modify, or update this Privacy Policy from time to time to reflect changes in legal requirements, business practices, technological advancements, or Our data handling processes.

We encourage You to periodically review this Privacy Policy to stay informed about how We collect, use, and protect Your personal information. Your continued use of the Platform following the publication of any updates or modifications will constitute Your acceptance of the revised Privacy Policy.

If You do not agree to the updated terms of the Privacy Policy, You should discontinue Your use of the Platform or any part thereof .

11. Grievance Redressal

In accordance with the applicable laws and rules made thereunder, We have appointed a Grievance Officer to address any concerns, queries and issues with respect to Your data including any rights available to You with respect to the same, please write to the below address:

Name: Mr. Prashant Bhardwaj

Email: grievance@playfunto.com

Phone: 9953857558

Address: VO-708, WeWork DLF Two Horizon Centre, 5th Floor, DLF Phase 5, Gurugram, Haryana 122002

We will endevour to resolve any such queries and concerns within 30 days.