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DRAFT — PRE-LAUNCH LEGAL AND PRODUCT REVIEW

Vikven Entertainment Private Limited

 

1. Introduction and Applicability

This Privacy Policy explains how Vikven Entertainment Private Limited (VEPL, we, us, our), a company incorporated under the Companies Act, 2013 and having its registered office in Bengaluru, Karnataka, collects, uses, discloses, stores, and protects personal data in connection with the TAG Poker mobile application and any related websites (together, the Platform). This Policy is framed to meet the requirements of the Digital Personal Data Protection Act, 2023 (DPDP Act), and should be read together with our Terms and Conditions.

This Policy applies to every person who downloads, registers on, or otherwise uses the Platform (User). By using the Platform, you acknowledge that you have read and understood this Policy. Where the DPDP Act or another law requires your separate, specific consent for a particular processing activity, that consent is sought at the relevant point of use, as described in our accompanying User Consent Framework, and is not implied merely by continued use of the Platform.

 

2. Key Definitions

Personal Data means any data about an individual who is identifiable by or in relation to such data.

Data Principal means the individual to whom the personal data relates — that is, you, the User.

Data Fiduciary means VEPL, as the entity that determines the purpose and means of processing your personal data.

Processing means any operation performed on personal data, including collection, storage, use, sharing, disclosure, and erasure.

Consent has the meaning given to it under Section 6 of the DPDP Act — free, specific, informed, unconditional, unambiguous, and given through clear affirmative action.

 

3. Personal Data We Collect

We collect the following categories of personal data, only to the extent reasonably necessary for the purposes described at Section 4:

3.1 Account and registration data: Name or chosen username; email address; mobile number for OTP-based authentication; date of birth or age declaration; account credentials where you register directly rather than through Google or Apple sign-in; profile information you choose to add, including avatar selection and profile photo.

3.2 Payment and transaction data: Purchase history for VIP passes, T-Diamond, and cosmetic Store items; payment method metadata processed through our payment gateway partner (we do not store full card numbers); transaction identifiers, amounts, and timestamps.

3.3 Gameplay and platform activity data: Hands played, tables joined, session duration and frequency; chip balances and chip activity within the session-scoped allocation described in our Terms and Conditions; club membership, roles, and activity; in-app communications limited to club notices and administrative messaging. The Platform does not presently support direct player-to-player chat.

3.4 Device and technical data: Device identifiers, device model, and operating system version; IP address and approximate location derived from it; precise GPS location only where used as an operational safeguard for table configuration and only with the permission you grant through device settings; app usage diagnostics and crash logs.

3.5 Data we do not intend to collect: We do not knowingly collect personal data from individuals under 18. We do not request or store government identity document numbers, biometric data, or financial account numbers beyond what our payment gateway partner requires and retains independently under its own regulatory obligations.

 

4. How We Use Personal Data

We process personal data for the following disclosed purposes: (1) creating and administering your account, including age eligibility; (2) operating matchmaking, table configuration, club administration, and session-scoped chip allocation; (3) processing payments for VIP passes, T-Diamond, and Store items and maintaining transaction records; (4) detecting and preventing fraud, cheating, collusion, multiple accounting, and prohibited conduct; (5) responding to support requests and grievances; (6) complying with applicable law and lawful requests; (7) sending required account, security, and transaction notices, and sending marketing only with separate opt-in consent that you may withdraw; and (8) maintaining Platform security and integrity. We do not use personal data for purposes beyond those described here or separately disclosed at collection.

 

5. Consent

Where the DPDP Act requires consent before processing, we request it through a clear, specific, affirmative action, such as an unticked checkbox you actively select, with notice in English or your chosen language describing the data and purpose. Consent bundled with acceptance of Terms is not treated as valid consent for a distinct processing purpose. Continued use after a policy change does not itself constitute consent to materially different processing; we will seek fresh consent where required.

 

6. Withdrawal of Consent

You may withdraw consent at any time, to the same extent it was given, through in-app privacy settings or by contacting us using Section 13. Withdrawal does not affect processing carried out before withdrawal. We may retain data required by law, including transaction records for tax and audit. If withdrawal prevents a dependent feature from working, we will explain the consequence before you confirm.

 

7. Age Restriction and Children’s Data

The Platform is intended solely for people aged 18 or older. We require an affirmative age declaration at registration and do not knowingly permit gameplay without it. We do not seek parental consent for minors; access is not extended to declared minors. If we learn a User is under 18, we will suspend the account and delete associated personal data except where retention is required by law.

 

8. Disclosure of Personal Data to Third Parties

We share personal data only as necessary and do not sell it. Recipients may include payment gateway and aggregator partners for purchases; cloud hosting providers; analytics and crash-reporting providers, using aggregated or pseudonymised data where feasible; club owners and administrators for necessary membership, role, and activity information, never payment credentials; law enforcement, courts, or regulators where legally required; and a successor entity after merger, acquisition, or asset sale, subject to equivalent protections. We require third parties to protect the data under contractual terms and restrict unrelated onward use.

 

9. Cross-Border Transfer

Some service providers may process data outside India. We take reasonable steps to ensure transfers comply with the DPDP Act and any Central Government restrictions. We will update this Policy and vendor arrangements if relevant restrictions are notified.

 

10. Data Retention

We retain personal data only as long as necessary for the purposes in this Policy or as required by law, including tax, accounting, and consumer-protection periods. Gameplay and chip activity used for fraud detection is retained for a limited monitoring window. On account deletion, we erase or irreversibly anonymise data within a reasonable period, except where retention is legally required or needed for a legal claim.

 

11. Data Security

We use reasonable technical and organisational safeguards, including encryption in transit, need-to-know internal access controls, and monitoring for unauthorised access. If a personal data breach is likely to affect you, we will notify you and the Data Protection Board of India as required by the DPDP Act and take reasonable steps to mitigate its impact.

 

12. Your Rights as a Data Principal

You may request a summary of the personal data we hold and how it is processed; correction, completion, updating, and erasure; grievance redressal and escalation; nomination of another person to exercise rights after death or incapacity; and withdrawal of consent. Contact us using Section 13. We will respond to verified requests within prescribed time limits. Where an exemption applies, we may decline a request in whole or part and state the reasons.

 

13. Grievance Redressal and Contact

Questions, requests, and grievances may be addressed to our Grievance Officer:

Grievance Officer: [Name to be appointed and inserted before publication]

Email: [grievance@tagpoker.example — to be finalised]

Postal address: Vikven Entertainment Private Limited, [registered office address], Bengaluru, Karnataka.

We will acknowledge a grievance within 24 hours and endeavour to resolve it within 15 days, consistent with the timelines described in the draft Policy.

 

14. Device Permissions

Location (GPS) is used only as an operational safeguard in table configuration when a host enables it, not for advertising or profiling. Notifications are used for account, security, and separately opted-in promotional communications. Storage or media access is used only if you upload a custom profile photo. Each permission is explained when first requested and may be declined or revoked through device settings, subject to the corresponding feature becoming unavailable.

 

15. Cookies and Similar Technologies

Our website, if operated, uses cookies and similar technologies for essential functionality, analytics, and, only with consent, marketing purposes. It provides a cookie-preference control consistent with this Policy.

 

16. Third-Party Links

The Platform may link to third-party sites or services, including payment checkout pages. We are not responsible for third-party privacy practices and encourage you to review their policies.

 

17. Changes to this Policy

We may update this Policy. We will notify you of material changes through the Platform or by email before they take effect and seek fresh consent for a new or materially different processing purpose where required.

 

18. Governing Law and Jurisdiction

This Policy is governed by the laws of India. Disputes are subject to the dispute resolution mechanism in our Terms and Conditions.

 

19. Contact Us

For questions about this Policy, use the details in Section 13.