Privacy Policy
A. GENERAL TERMS
- GameVault Media Pvt. Ltd, a company incorporated under the laws of India and bearing the
Corporate Identification Number (CIN) U72900DL2022PTC405782 (“Googly”, “we”, “us”
or “our”), recognizes the value of the Personal Information of its users (“User”, “you”,
“your”). This Privacy Policy (“Policy”) governs the collection and processing of the
information that our Users share with us while using our website (www.googly.gg) and
mobile application(s) (“Platform”). This Policy explains what information we collect about
you while you access and use the Platform; why we collect this information; how we use your
information; how we protect and share your information; the choices we offer you, including
your ability to access and update your information and make certain choices about how your
information is used.
- Please read and understand this Policy carefully to understand our privacy practices and their
application to your access and use of the Platform. By using our Platform, submitting
information to us, interacting with us, or signing up for any promotions or services offered by
us, you agree and consent to us, as well as our respective representatives, collecting,
receiving, processing, storing, transmitting, using, and sharing amongst ourselves your
Personal Information, and disclosing such Personal Information to Googly’s service providers
and other relevant third parties in the manner set forth in this Policy. If you are under the age
of Thirteen (13) years, you cannot access our Platform. If you are above Thirteen (13) years
of age and below Eighteen (18) years of age, you may not access or use our Platform unless
your parent or legal guardian consents to your access and use of the Platform. For further
details regarding our treatment of children’s Personal Information, please refer to Article E of
this Policy.
- Please note that certain features of the Platform and the services we offer require the
provision of your Personal Information, and where you do not provide such requested
information, we may not be able to provide you with the access and use of our Platform and
our services, wholly or partly. If you disagree with the terms of this Policy, we recommend
you not to accept the Terms, or use or access our Platform or our services.
- You may contact our Grievance Redressal Officer, through the contact information provided
herein, in case of any queries regarding how we collect, manage, store or process your
information.
- This Policy forms part of the Beta Participation Terms which can be accessed at
www.googly.gg (“Terms”). In the event that you are under the age of Eighteen (18) years,
your parent/legal guardian must consent to these Terms. All capitalized terms used, but not
otherwise defined herein, will have the meaning ascribed to them in the Terms. In the event of
any conflict, inconsistency or conflict between this Policy and the Terms, the terms set forth
in this Policy will prevail specifically in relation to the matters stated herein.
B. INFORMATION WE MAY COLLECT
- Information you provide. Personal information means any information that relates, directly or
indirectly, to an individual, who is identified or identifiable from that information or from
such information in combination with other information in the possession of Googly or any
third parties engaged by Googly, and may include sensitive personal information (“Personal
Information”). We may ask you to provide only such Personal Information which is required
and necessary for lawful purposes in connection with your use of the Platform and our
services. We do not use your Personal Information, including your sensitive personal
information, for any purposes other than those provided for under this Policy. Such Personal
Information may include:
- Your full name, username/avatar name, password, e-mail address, contact/mobile number,
gender, occupation, employment status, marital status, parental status, date of birth, place of
birth, city and state in which you reside in India, postal address, and details in relation to your
national identity card such as AADHAAR/PAN Card;
- Your hardware configuration, console ID, software products played, survey data, purchases,
Internet Protocol address (“IP Address”), type of browser used, details regarding the
systems/devices you have accessed or used the Platform and/or our services on, and geo-
location details including region, country, state and city; and
- Your financial information, such as credit or debit card details, bank account number and
IFSC code.
During the course of your access or use of the Platform, we may request you to provide
additional Personal Information in order to verify your identity and/or in order to disburse
prize money.
- Information we collect. We may collect information that either you provide to us by
registering or creating an account on, and accessing or using, the Platform and/or our services,
or that we automatically collect when you interact with, visit, access or use the Platform.
Some of the information we collect in the said manner may qualify as Personal Information.
The information we may collect from you includes the following:
- Registration and Profile Information. You are required to provide certain information at the
time of registration, and creation of your account, on the Platform, which may include without
limitation username/avatar name, e-mail address, password, place of residence, date of birth,
first name, middle name, last name, contact number(s), details of your national identity and
your Discord profile information. Upon creation of your account, you may choose to provide
additional information to your profile by using your User Account/Profile settings, such as
your full address, avatar picture, Google profile, YouTube profile, Twitter profile, Twitch
account, gaming preferences, game genre(s), preferred type of content, short description about
you, marital status, and parental status.
- Usage Information. Googly and third-party providers engaged by Googly use a variety of
technologies that automatically collect certain information whenever you visit or interact with
the Platform (“Usage Information”). This Usage Information may include, without limitation,
your IP Address; information in relation to the browser that you are using such as its type and language; the domain name and Uniform Resource Locator (“URL”) that referred you to our
Platform; date and time of your requests; search terms; domain name, date and time for each
page you view; all of the areas within our Platform that you frequently visit, use and/or
interact with, and the day of the week/month thereof. We also collect the name of and
information about any advertisement or other link that brought you to us and such information
does not personally identify you.
- Geo-location. We may use your IP Address to gather broad demographic information, such as
your general geographic location, including region, country, state and city, and internet
service provider. IP Addresses are also used to help determine the number of our Users, to
maintain efficient administration of the Platform and our services, to optimize user experience
and to help us analyze aggregate usage behavior.
- Device Information. With respect to the computer, mobile phone or other device used by you
to access the Platform and our services (“Device”), we collect their corresponding IP Address
and/or other unique identifiers (“Device Identifier”). A Device Identifier is a number that is
automatically assigned to your Device used to access the Platform and our services, and our
computer networks identify your Device by its Device Identifier.
- Third-party websites. This Policy does not apply to any third-party website(s) and mobile
application(s), even if such websites/applications are linked to our Platform. If you access our
services through other platforms, or our Platform leads you to third-party
websites/applications, their privacy practices may differ from those set out under this Policy.
Googly has no control over the policies, actions or omissions of third-party websites and is
not responsible or liable for any such policies, acts or omissions. If you submit personal
information to any of those websites, your information is governed by the applicable third-
party privacy policies and not by this Policy. We recommended that you review the privacy
policies of such third parties before availing their services.
- Gaming and Tournament Information. We we may collect information in respect of each
game that you link with your account on our Platform, which includes without limitation
username/avatar name, list of friends, any form of identification within such game(s),
rank/skill level which is based on your previous performance in such game(s), profile
statistics, etc. We may also collect certain information with respect to your in-game actions or
omissions when you play a game that has been linked with the Platform. Such information
includes without limitation match statistics, match results, match replays, event logs, and anti-
cheat logs, if any. When registration pages are set up by any User in relation to any
tournament for a particular game (“Tournament Organiser”), additional information may be
required to be provided by a User attempting to register for the said tournament. We may
share such information with the Tournament Organiser.
- Payment Information. You will be asked to submit information to our payment processors
including without limitation your first name and last name, e-mail address, date of birth (if
required), and financial and billing information that is necessary for any payment within the
Platform to be successfully carried out.
- Mailing List. In the even to the User signing up to our mailing list, we may require certain
contact information such as your full name and your e-mail, as required for providing you the
services in connection with the mailing list.
- Analytics. We may collect information about your use of the Platform and our services,
including without limitation, how many times you visit and use the Platform; which pages
you go to; traffic-related data; your IP Address; information regarding your internet service
provider; your console ID; information regarding your Device’s operating system and
version; your Device’s brand name and model; game-play attempts, progression and results;
timestamps with respect to the start and end of any period/session during which the Platform
and/or our services are accessed and used, and the duration of such period/session; and the
identification of any crashes of, and defects in, the Platform.
- E-mail, feedback and comments. We may store copies of any e-mail or similar
communications between you and us, which can result in the collection of your e-mail address
or other Personal Information contained in the text, addresses, or other fields of your e-mail or
other communication, as well as the collection of your IP Address or other routing of your
communication, and the date and time of your e-mail or other communication. All
transmissions between you and us, including e-mails, URLs, cookie identification numbers,
usage paths, and any personally identifiable information they might contain, pass through
many third party machines, operating systems, programs, browsers, web servers, networks,
routers, ethernet switches, Internet Service Providers, proxy servers, intranets, the public
telephone systems, or other devices, any of which may create activity logs containing such
transmissions, and many of which we cannot control. We do not send e-mails asking for a
User’s username/avatar name and password or any other username or password. We may
retain any email, feedback, comments or other communication you send to us in order to
process your inquiries, respond to your requests, improve the Platform or our services, and
may disclose, publish or use such communications without any obligation to you.
- Cookies. Cookies are small data files sent from the Platform and stored in the User’s web
browser, mobile phone, or other device while the User is visiting parts of the Platform and/or
using certain features of the Platform. We use cookies and other online tracking technologies,
such as flash cookies, pixel tags, web bugs, web beacons and web storage, (“Cookies”) to
collect your information, including without limitation your Usage Information, in order to
monitor and improve the Platform and our services. Your web browser allows you to enable,
limit or disable the use of Cookies. If you choose to disable Cookies on your Device, some
features of the services we offer may not function properly or we may not be able to
customize the delivery of our to you. Googly cannot control the use of cookies and other such
tracking files/technologies, or their resulting information, by third parties. The use of third-
party cookies and other such tracking files/technologies is not covered by this Policy.
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Information shared by third parties.
- Referrals. If you are invited to the Platform by another User, such User can submit personal
information about you such as your e-mail address, your social media handle or other contact
information. If you have provided Googly with Personal Information of a third party, please
ensure that you have obtained such third party’s consent in relation to the processing and
disclosure of their Personal Information and that this Policy is brought to the attention of such
third party.
- Third-party services. If you link, connect, or login to the Platform with a third-party service
(such as Google, Twitter, Facebook, WhatsApp, Twitch, Discord), you direct such a third-
party service to send us information such as your profile information, registration details and
contacts list, as available with such service or as authorized by you through your privacy
settings with such third-party.
We may, from time to time, collect such relevant information about you as may be necessary
from other third parties on a need-to-know basis. We may combine the information you
submit under your account, or we collect during your usage of the Platform or our services,
with information from such third parties in order to improve your experience on the Platform
and the quality of our services.
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Information collected by mobile applications.
- If you are using our mobile application(s), we may collect and use technical data and related
information, including but not limited to, technical information about your Device, system
and application software, and peripherals, which are gathered periodically to facilitate the
provision of software updates, product support and other services to you (if any) related to
such mobile applications.
- The mobile application may automatically collect and store some or all of the following
information from your mobile device (“Mobile Device Information”), in addition to the
Device Information, including without limitation: (i) your preferred language and location;
(ii) the brand name and model of your mobile device; (iii) your mobile operating system; (iv)
the type of mobile internet browser(s) you are using; (v) your geo-location; (vi) information
about how you interact with the mobile application and any of our websites to which the
mobile application links, such as how many times you use a specific part of the mobile
application over a given time period, the amount of time you spend using the mobile
application, how often you use the mobile application, actions you take in the mobile
application and how you engage with the mobile application; and (vii) information to allow us
to personalize the services and content available through the mobile application.
- Permissions required upon the installation of the mobile application for its effective
functioning include access to your SMS, contacts, location, microphone, identity, device and
caller ID, Wi–fi information, photo, media or file gallery, and notifications.
C. USE AND DISCLOSURE OF THE INFORMATION WE COLLECT
We use and share the information we collect about you with certain third parties, including
without limitation our service providers, contractors, vendors, partners, related entities, only
in accordance with applicable laws, and subject to the terms of this Policy and as set forth
below:
- To facilitate your use of the Platform. We, or any third party acting on our behalf, may use the
we collect about you information for the purposes set forth below:
- To verify your identity;
- To provide, maintain, develop and improve our services;
- To provide updates and upgrades of the Platform;
- To personalize your use of our services;
- To process transactions and billing, for identification and authentication purposes;
- To identify, monitor and remedy any technical issues in the Platform and any attempted
circumvention of device security;
- To communicate with you in relation to transactions, security, privacy, and administrative
issues in connection with your use of the services;
- To respond to your enquiries, feedback and comments;
- To tell you about certain services we offer that we think you may be interested in;
- To comply with applicable laws;
- To enforce our policies;
- To resolve disputes with other Users;
- To enforce agreements with any third parties; and
- For the administration of, and troubleshooting regarding, our services. Third parties who
provide technical support for the operation of our services, such as web, hosting, inventory
management, content optimization, connection checking, remote customer support and
account management purposes, may need to access such information from time to time, but
are not permitted to disclose such information to others.
- To display on your public profile. You may make certain information, including your
Personal Information, publicly visible to others which may include without limitation your
profile picture, your username/avatar name and the short description about you to other Users.
We may display parts of your public profile and other content you make available to the
public like listing details on third-party websites, platforms and applications. Information you
share publicly on the Platform may be indexed through third-party search engines. In some
cases, you may opt-out of this feature in your account settings. We will not publicly display
any sensitive personal information that you provide to us.
- To share information with third parties. It may be necessary or appropriate for us to provide
access to your Personal Information to third parties such as our service providers, contractors,
vendors, partners and affiliates, in order to operate the Platform, our services and our
business. Where practical, we will seek to:
- Obtain confidentiality agreements consistent with this Policy and that will limit others’ use or
disclosure of the Personal Information you have shared; and
- Require such third parties to protect your Personal Information and meet our data security
standards, including ensuring they are bound by legally enforceable obligations to comply
with all applicable personal data protection requirements, while such Personal Information
remains in its possession or under its control.
We may choose to anonymize your Personal Information before sharing it with any third
party.
- To enforce our legal obligations. We may also share your Personal Information if we are
required to do so by law or we in good faith believe that such action is necessary to: (i)
comply with the law or with legal process (such as pursuant to court order, or instructions by
governmental authority, or a request by law enforcement officials); (ii) to protect, enforce,
and defend our Terms, rights (including intellectual property rights) and property, and the
terms of agreements we are party to; (iii) protect against the misuse or unauthorized use of the
Platform or our services; or (iv) protect the personal safety or property of our Users or the
public (among other things, this means that if you provide false information or attempt to
pose as someone else, information about you may be disclosed as part of any investigation
into your actions).
- To carry out advertising and marketing. We may use the information you share with us to
send you promotional messages and e-mails, marketing, advertising, and other information
based on your preferences and carry out social media advertising through social media
platforms, personalize, measure, and improve our advertising, administer referral programs,
rewards, surveys, contests, or other promotional activities or events sponsored or managed by
Googly or its third-party service providers, contractors, vendors, partners or affiliates, and
invite you to events and relevant opportunities.
We may also disclose or share information that does not personally identify any individual
User, including anonymized information or Aggregated Information, with third parties, such
as usage statistics of the Platform and/or our services, or IP Addresses. Aggregated
information is information recorded about Users and collected into groups so that it no longer
reflects or references an individually identifiable User (“Aggregated Information”). Such third
parties may collect information when Users use the Platform and/or our services. Such third
parties may use this aggregated information about your visits to the Platform and other
websites/applications in order to provide advertisements on the other websites/applications
and other forms of media about goods and services of interest to you.
- Business transfers. In the event Googly undertakes or becomes involved in a merger,
acquisition, reorganization, any form of sale of some or all of our assets, bankruptcy, or an
insolvency event, then we will provide notice to you if such a transaction results in your
information being subject to a different policy.
- Companies in the group. We may share your Personal Information with our group companies
or associate entities in order to improve personalization and efficiency of the Platform and/or
our services. This will enable us to provide you with information about various products and
services or help us address your questions and requests in connection with the Platform and/or
our services.
D. RETENTION OF YOUR PERSONAL INFORMATION
- Unless any applicable law, regulation or governmental/court order permits a longer period of
retention, we will hold your Personal Information on our computer networks for as long as is
necessary for the fulfilment of the purposes outlined in this Policy, or until you request for the
withdrawal of your Personal Information. Please note that even if we delete your Personal
Information, it may persist in backup or archival files for legal, taxation or regulatory
purposes.
E. CHILDREN
- We do not offer or provide our services to knowingly solicit information from, or market to,
children under the age of Eighteen (18) years. Our Terms prohibit Users who have not
attained the age of Eighteen (18) years from accessing the Platform or our services unless
they have obtained consent from their parents or legal guardians. In the event we learn that we
have collected Personal Information from a child under the age of [insert] years, or under the
age of Eighteen (18) years without consent from their parents or legal guardians, we will
delete such Personal Information. If you believe that we might have any Personal Information
from or about a child in contradiction with the abovesaid, please contact us through our
grievance redressal officer, whose contact details are provided below.
F. SECURITY
- The security and confidentiality of your Personal Information is extremely important to us.
We have implemented technical, administrative and physical security measures to protect
your Personal Information from unauthorized access and improper use, and review such
measures from time to time
- If we collect information from your Device, we encrypt it while it’s being transferred to us.
Once your information reaches our servers, as part of our security program, we employ
standard procedures and safeguards, such as maintaining firewalls and having an intrusion
detection system, to protect the confidentiality, security and integrity of the information we
maintain.
- However, as with any information travelling over the internet and kept in servers, we cannot
guarantee absolute security. Consequently, we cannot ensure or warrant the security of any
information you transmit to us and you do so at your own risk. When we work with third
parties, we require that they maintain the confidentiality, security and integrity of the
information and commit that the information is not used for any prohibited purpose.
Additionally, we use commercially reasonable computer security safeguards to protect our
databases and servers against risks of loss, unauthorized access, destruction, misuse,
modification, or inadvertent or improper disclosure of data. These include internal reviews of
our data collection, storage and processing practices and security measures, as well as
physical security measures to guard against unauthorized access to systems where we store
personal data. We restrict access to Personal Information to our employees, service providers,
contractors, vendors, partners, agents and affiliates who need to know that information in
order for us to provide, develop or improve the Platform and our services.
G. ACCESS, CORRECTION AND WITHDRAWAL OF YOUR PERSONAL DATA
- You may seek a copy of, request us to modify or correct, withdraw, your Personal
Information provided directly to us in connection with the Platform and/or our services, by
writing to us at contact@googly.media. We will make reasonable efforts to comply with your
request within 14 working days of receipt of such request.
- Please note that if your Personal Information has been provided to us by a third party, you
must contact such party directly to make queries, feedback, and access and correction requests
to Googly on your behalf.
- Please note that if you withdraw your consent to any or all use of your Personal Information,
depending on the nature of your request, Googly may not be in a position to continue to
provide its services to you or administer any contractual relationship in place.
H. GRIEVANCES AND COMPLAINTS
- If you have any questions, comments, requests, notices or grievances in respect of this Policy
or the usage of your Personal Information, you may reach out to our grievance officer Mr.
Gautham Hegde, who can be contacted at contact@googly.media.
I. UPDATES
- Googly may, at its sole discretion, modify this Policy at any time. Whenever we do so, the
revised Policy will be posted and the ‘Last Updated’ date, will be updated at the top of this
Policy. You are requested to keep yourself updated with the Policy from time to time. Your
continued usage of the Platform will be deemed to be an acceptance of the modifications of
the Policy.
J. GOVERNING LAW AND JURISDICTION
This Policy will be governed in all respects by the laws of India. To the fullest extent
permitted by applicable laws, you hereby expressly agree that any proceeding arising out of or
relating to this Policy will be instituted in courts in New Delhi, India.