The Users are responsible for ensuring that we keep their information current and accurate. The User may update their information by contacting us at email@example.com and we will use reasonable efforts to process any change the User makes; provided, however, that requests to delete information are subject to Millionhere Play’s internal reporting, processing and retention policies and all applicable legal obligations and existing legislations.
Your Privacy: Our Commitment
At Millionhere Play, we are extremely proud of our commitment to protect your privacy and recognise that you have a right to know about the information we access or collect about you, how your information is being used by us and what we do to protect your information. Please read the following policy to understand how your personal information shall be treated by Millionhere Play.
Our commitment towards privacy and protection of User data is based on the principles of lawfulness, transparency, fairness, accuracy, data minimisation, integrity and confidentiality.
- Any questions, comments or complaints that you might have should be emailed to firstname.lastname@example.org.
- Information Collected from the Users
- In addition to the above, we may need to verify your identity in order for you to use some aspects of the Site/Service. For purposes of verification, we may also collect the following personal information from you:
- Passport information;
- Aadhar Card information and details;
- PAN Card information;
- Government-issued residence proof;
- User's bank account details and proof of the same;
- Tax-related information; and
- Other information as may be required to verify you in accordance with applicable laws and regulations.
- Any information provided by the User through your posts or your comments, opinions and feedback on uploaded the Public Forum of the Millionhere Play Site.
- We may require you to furnish information about the payment methods such as credit/debit cards, e-wallets and other online payment methods. We may also require you to furnish additional information about the same including but not limited to billing address, card type, number, expiration date, card security code etc. If you choose to access the Site and/or any Service of Millionhere Play which requires payments, you may be required to furnish the above stated details.
- When you use our mobile app, you hereby consent to us accessing the features of your mobile device such as the phone number, your contacts, IMEI number of your device, whether a phone call is active, the number that the phone call is connected to and the like. The access to your mobile phone device features is used to stop the radio commentary and terminate the internet access when you make or receive a call without any disruption.
- When you use our mobile app, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device (such as IDFA or an Android Ad ID), device information, default device language, the location of your device (at a GPS level), and app usage information. This data also may be linked to your other information, including your location data.
- In addition, if you choose to log in, access or otherwise connect to Millionhere Play, or contact Millionhere Play, through a social networking service or any third party service (such as Facebook, Twitter, Google etc), we may collect your user ID and user name associated with that social networking service or third party service, as well as any information you make public using that social networking service or third party service. We may also collect information you have authorized the social networking service or third-party service to share with us (such as your user ID, public profile information, email address, birthday, friends list, and pages you have "liked" or tweeted).
- We may collect and process the information such as names, photos, contact details, the User’s activity during the tournament games, posts and comments pertaining to Millionhere Play.
- Cookies: When you visit the Millionhere Play Site, we may send one or more cookies - small files - to your computer or other device, which may enable us or others to uniquely identify your browser. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
Millionhere Play may use both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser help file directions. Session cookies are temporary and typically disappear after you close your browser. You may be able to reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Site or Service may not function properly if the ability to accept cookies is disabled.
We use the session cookies to keep track of you whilst you navigate the Site/Service to prevent frauds and increase website security. We use the persistent cookies to enable our Site to recognize you when you visit and keep track of your preferences in relation to your usage of our website.
- Log File Information: When you use our Site/Service, our servers may automatically record certain information that your device sends whenever you visit any website and use certain apps. These server logs may include information such as your web or app request, Internet Protocol ("IP") address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, the actions you take on a page and one or more cookies that may uniquely identify your browser.
- Clear GIFs Information: When you use our Site/Service, we may employ technology such as "clear GIFs" (a.k.a. Web Beacons) which are used to track the online usage patterns of our users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by specific users.
- Third Party Sites & The User
- Millionhere Play refuses to acknowledge or represent the accuracy, completeness, reliability or adequacy of the Site's third-party content. The content, materials, information, services and products in the Site including text, graphics and links, are provided "AS IS" and without warranties of any kind, whether expressed or implied. Millionhere Play is in no way responsible for any content of any linked site or any link contained in a linked site.
- Millionhere Play disclaims all warranties, expressed and implied with regards to the merchantability and fitness of the Site and/or such third-party sites for a particular purpose. Millionhere Play also does not guarantee that users shall be able to use the Site and/or such third-party websites without any interruption, which may lead to loss in continuity.
- Although, Millionhere Play shall make reasonable efforts to ensure that the Site remains free of viruses or other harmful components, however, Millionhere Play does not in any way represent or warrant that the Site or the server that makes the Site available shall be free of such harmful components. Use of the services of this Site is at User's own risk and Millionhere Play shall not be responsible for any servicing costs, repair or correction of the User’s systems.
- Millionhere Play does not, in any manner whether express or implied, endorse the advertisements hosted on its Site and the Users responding to such advertisements and/or purchasing any products advertised on Millionhere Play hereby warrant and accept that they shall do so at their own risk.
- Millionhere Play reserves all rights to the assets, content, services, information and products and graphics in the Site except any third-party content.
- Use of Information by Millionhere Play
- We may use your personal information to operate and maintain the Site/Service. The information may also be used to provide to you the features and functionality of the Site/Service, including but not limited to the following:
- administering the Site/Service and enabling its use for the User;
- providing you with our products, services, games including their updates;
- processing and responding to your enquiries or feedback;
- personalizing your use of the Site/Service,
- alerting you to new features, special events, products and services, or certain third-party products or services in which we think you will be interested;
- sending statements and invoices to you and collecting payments from you;
- enforcing the legal terms and conditions that govern your use of the Site/Service;
- investigating and protecting the integrity of Millionhere Play’s Games and/or Tournaments and/or Leagues and/or Challenges and keeping the Site/Service secure;
- dealing with customer inputs, complaints and suggestions; and
- contacting you about your account or profile.
- We may use your information (both personal and non-personal information) to send you marketing and advertising content, including sending you advertising through multiple channels, such as direct mail, email, push notifications and display media. We may send you advertising or content regarding our products and services, or products and services that we market on behalf of another company or any other entity.
- We may use your information to communicate with you about:
- our products and services in which you may be interested provided that you have not requested otherwise;
- newsletters and information for which you have signed up; and
- non-marketing or administrative purposes (such as notifying you of major changes to the Site/Service or for customer service purposes).
- We use your information to improve the quality and design of our Site/Service and to create new features, promotions, functionality, and services such as by storing, tracking, and analyzing user preferences and trends.
- We may use the information collected from you in order to process payments and/or fees.
- We may use your information in order to implement sufficient credit fraud protection and risk reduction measures.
- We may anonymize, de-identify, or aggregate your information for any legitimate business purposes, including for reporting and research, or advertising. Such anonymized and/or aggregated data does not personally identify you. Sometimes, this information may be used to target more relevant content or offers to you across different devices – for instance, we may provide you with offers and content on your mobile device, based on your web-based activity.
- We may disclose the information provided to us by the User for any other reason the User provided us with the said information.
- When Millionhere Play Discloses Information
- We may disclose the information we collect or receive from you to our subsidiaries, affiliated companies, agents, or other businesses, or service providers who process your information on our behalf in order to provide or operate the Site/Service. For instance, these entities may have access to your information for purposes including (but not limited to) billing and accounting, hosting, marketing, promotional and email services, customer and technical support, and for the purpose of accepting deposits and paying withdrawals and processing such information on our behalf, and in each case, may use the information to make improvements to the services they provide to us. Our agreements with these service providers limit the kinds of information they can use or process and require them to use reasonable efforts to keep your personal information secure.
- When you choose to share information with social media services about your activities on Millionhere Play by, for example, connecting your social media account to our Site/Service, then Millionhere Play may share your personal information and information about your use of the Site/Service with such social media sites. Please make sure to read the terms and privacy statements of such sites prior to connecting to our Site/Service in this way.
- In the event that you win a prize we may contact using your personal information (such as your name and photo) in connection with publicity purposes.
- In the event that you win a promotion run by us we may be required to either publish or make available upon request: your name, photo and county in accordance with applicable legislation.
- We may publish a profile page that includes your username, the date you became a member, your stats from previous games and, if you uploaded one, your profile picture. Where you post personal information about yourself through our Site/Service to public areas of our Site/Service, you acknowledge and agree that this personal information will be publicly available.
- When you participate in a contest, we may publish your username on a list of the contest participants, along with a link to your profile page.
- Where you have provided your consent, we may share your personal information with selected third parties for their commercial or marketing use in conjunction with your relationship with Millionhere Play or as part of a specific program or feature.
- In addition, we may disclose to third parties various types of your information for targeted online or mobile advertising, as further described in the Section titled “Third Party, Sharing Advertising and Analytics.”
- We also may share personal information in other situations with your consent.
- If you elect to participate in any promotions, surveys, questionnaires, or other events during your usage of Millionhere Play, the rules or terms and conditions for those events may indicate that your information will be shared with third parties with your consent. You are advised to review the applicable rules and/or terms and conditions for any promotions, surveys, questionnaires or events.
- In the event that Millionhere Play is involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, or other change of control, there may be a disclosure of your personal information to another entity related to such event.
- Monitoring of Transactions & Customer Support
- All gaming and account transactions are recorded on our computer system. We also carry out routine monitoring of all transactions as they take place, to assist us in improving the service that we provide to you.
- All telephone conversations from the Users to our Customer Support Centre may be recorded both to assist us in training and in quality management, and to allow for the speedy resolution of the queries.
- All communications with Millionhere Play and its Customer Support shall be conducted in parliamentary language (language which is not offensive and/or abusive). Millionhere Play prevents and prohibits any such use of offensive and/or abusive language and strictest of actions shall be taken against the User who uses such offensive and/or abusive language including but not limited to suspension and/or termination of the User Account.
- User’s Choices
- You can access and update certain personal information Millionhere Play holds about you at any time by logging into your account via the Site/Service. You can update your marketing preferences and whether or not you would like us to send you newsletters in your account. You can also unsubscribe to marketing emails and newsletters by using the 'unsubscribe' feature in the communication.
- We may occasionally send display media to you, in a targeted way, whether through web or mobile browsers or mobile applications. You may opt out of many third parties that support and send this type of targeting advertising and you may learn more about this type of advertising in the below Section titled “Third Party Advertising and Analytics.” You may opt out of tracking for mobile advertising through the settings on most smartphones, and you may learn more about these settings through those mobile device platforms, i.e., Google (https://support.google.com/ads/answer/2662922?hl=en) and Apple (https://support.apple.com/en-in/ht202074). [Please note that these companies may either change the way these settings operate, the content or the availability of these pages].
- We may occasionally send you push notifications to your mobile device. You can turn off certain push notifications in the account settings of your Millionhere Play Account. You can also turn off push notifications specific to our Service in the settings on your mobile device.
- Third Party Sharing, Advertising and Analytics
- Millionhere Play and/or Jengatron may disclose the information it collects about the User to:
- to its service providers, to its affiliates, sponsors, suppliers and others who help provide the platform to the User;
- to licensors, activity and event partners and other third parties for their own marketing purposes, such as to provide information to the User about their new developments, special events, programs, services, activities, products, attractions, promotions and other important information;
- third parties to provide analytics or to confirm/update information provided by the User;
- third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of Jengatron Gaming Private Limited’s [owner and operator of Millionhere Play] business or other operations (including without limitation in connection with bankruptcy or any similar proceedings); and
- or as otherwise authorized by the User.
- We may also share the User’s personal information in response to a legal order or official request; when we believe the User have acted in violation of the Terms & Conditions of Millionhere Play; to investigate, prevent or take any action regarding suspected illegal activities, fraud or potential threats; to exercise legal rights or defend against claims; or as otherwise permitted or required by law.
- We also may use, share or sell non-personally identifiable information with third parties. Additionally, we may take personally identifiable information and de-identify it and share it in a de-identified form with advertisers, business partners, and/or third parties in order to analyze usage of the services in order to improve our services and the User experience or for any similar purposes. Such data shall not be re-identified and the contracting parties would be asked to agree to keep the data in its de-identified form after such use.
- If the User elects to participate in any promotions, surveys, questionnaires, or other events during his/her visit to Millionhere Play, the rules or terms and conditions for those events may indicate that the User’s information will be shared with third parties with his/her consent. The Users are advised to review the applicable rules and/or terms and conditions for any promotions, surveys, questionnaires or events.
- Right to withdraw consent
- The User shall have the right to withdraw his or her consent at any time with respect to the processing and disclosure of the personal data/information provided to Millionhere Play.
- Such withdrawal of consent shall not affect the lawfulness of any processing/disclosure based on User consent carried on by Millionhere Play before its withdrawal.
- Right to Transparency and Communication
- Millionhere Play shall facilitate the exercise of User’s rights under this Clause 9 and offer full co-operation and support towards the same.
- Millionhere Play shall provide information on action taken on a request under this Clause 9 to the User without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. Millionhere Play shall inform the User of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the User makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the User.
- If Millionhere Play does not take action on the request of the User, Millionhere Play shall inform the User without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
- charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
- refuse to act on the request. Millionhere Play shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.
- Without prejudice to this Clause, where Millionhere Play has reasonable doubts concerning the identity of the natural person making the request referred to herein, Millionhere Play may request the provision of additional information necessary to confirm the identity of the User.
- Right to information
- Where personal data relating to a User are collected from the User, Millionhere Play shall, at the time when personal data are obtained, provide the User with all of the following information:
- the identity and the contact details of Millionhere Play and, where applicable, of the Millionhere Play's representative;
- the purposes of the processing for which the personal data are intended;
- the recipients or categories of recipients of the personal data, if any;
- categories of personal data concerned;
- where applicable, the fact that Millionhere Play intends to transfer personal data to a third party, third country or international organization.
- In addition to the information referred to in Clause 9.3.1, Millionhere Play shall, at the time when personal data are obtained, provide the User with the following further information necessary to ensure fair and transparent processing:
- the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
- where the processing is based or would be carried out;
- the existence of the User’s right to request from Millionhere Play access to and rectification or erasure of personal data or restriction of processing concerning the User or to object to processing;
- the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
- whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the User is obliged to provide the personal data and of the possible consequences of failure to provide such data.
- Where Millionhere Play intends to further process the personal data for a purpose other than that for which the personal data were collected, Millionhere Play shall provide the User prior to that further processing with information on that other purpose and with any relevant further information as referred to in Clause 9.3.2.
- The abovestated provisions under Clauses 9.3.1, 9.3.2 and 9.3.3 shall also apply where Millionhere Play intends to collect information from the User.
- Right to access to data
- The User shall have the right to obtain from Millionhere Play confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from Millionhere Play rectification or erasure of personal data or restriction of processing of personal data concerning the User or to object to such processing;
- where the personal data are not collected from the User, any available information as to their source;
- Where personal data are transferred to a third party, third country or to an international organisation, the User shall have the right to be informed of the appropriate safeguards implemented by Millionhere Play.
- Upon request by the User, Millionhere Play shall provide a copy of the personal data undergoing processing. For any further copies requested by the User, Millionhere Play may charge a reasonable fee based on administrative costs. Where the User makes the request by electronic means, and unless otherwise requested by the User, the information shall be provided in a commonly used electronic form.
- Right to rectification
The User shall have the right to obtain from Millionhere Play without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the User shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- Right to erasure (Right to be forgotten)
- The User shall have the right to obtain from Millionhere Play the erasure of personal data concerning him or her without undue delay and Millionhere Play shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the User withdraws consent on which the processing is based and where there is no other legal ground for the processing;
- the User objects to the processing pursuant to Clause 9.9 and there are no overriding legitimate grounds for the processing;
- the personal data has been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation under any law to which Millionhere Play is subject.
- Where Millionhere Play has made the personal data public and is obliged pursuant to Clause 9.6.1 to erase the personal data, Millionhere Play, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform entities which are processing the personal data that the User has requested the erasure by such entities of any links to, or copy or replication of, those personal data.
- Sub-clauses 9.6.1 and 9.6.2 shall not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by any law to which Millionhere Play is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in Millionhere Play;
- for the establishment, exercise or defence of legal claims.
- Right to restriction of processing
- The User shall have the right to obtain from Millionhere Play restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by the User, for a period enabling Millionhere Play to verify the accuracy of the personal data;
- the processing is unlawful and the User opposes the erasure of the personal data and requests the restriction of their use instead;
- Millionhere Play no longer needs the personal data for the purposes of the processing, but they are required by the User for the establishment, exercise or defence of legal claims;
- the User has objected to processing pursuant to Clause 9.9 pending the verification whether the legitimate grounds of Millionhere Play override those of the User.
- Where processing has been restricted under Sub Clause 9.7.1, such personal data shall, with the exception of storage, only be processed with the User's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights.
- Right to data portability
The User shall have the right to receive the personal data concerning him or her, which he or she has provided to Millionhere Play, in a structured, commonly used and machine-readable format and have the right to transmit those data to another entity/body without hindrance from Millionhere Play.
- Right to object
- The User shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her including profiling. Millionhere Play shall no longer process the personal data unless Millionhere Play demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the User or for the establishment, exercise or defence of legal claims.
- Where personal data are processed for direct marketing purposes, the User shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Where the User objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
- Users from Excluded Locations
- The Excluded Location shall be defined as the Countries/regions other than Republic of India and Excluded States in India where the services of Millionhere Play shall not be offered and accessed and/or are prohibited to be offered and accessed by the users. Users are requested to peruse the Millionhere Play Terms & Conditions to see the meaning of ‘Excluded States’.
- Information Security
- We are committed to protecting the security of your personal information. Protection of the User Information, including the registration details or any other payment information the User provides to us, is a priority for us. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.
- Any personal information which identifies the User will be encrypted at all times whilst in transit over the internet. The technology used by us encrypts any information sent by the User on secured pages. Our server then reads the information using a private key. This means that your information, be it any payment information provided to us or any other personal details, is turned into a code that can only be decoded with the private key or password.
- Whilst neither we, nor any other organization, can guarantee the security of information processed online, we do have appropriate security measures in place to protect your personal information. For example, we store the personal information you provide on computer systems with limited access that are located in facilities to which access is limited.
- To further protect your privacy and security, we reserve the right to take reasonable steps (such as requesting your password) to verify your identity before granting you profile access or making corrections.
- Additionally, you should ensure your password is kept secret at all times. You will be responsible for maintaining the secrecy of your password and account information.
- Unsubscribing to Communications
- If the User does not want to receive any e-mails from us in the future, they are required to let us know by dropping an email to us. We will use our reasonable endeavours to remove the User’s name from the related mailing list within 14 working days of his/her request. The User may also change his/her preferences at any time by revising his/her account profile by un-ticking the boxes for the previously opted communications.
- The User may also click the “unsubscribe” link (if present) at the bottom of any emails he/she may receive from us and follow the necessary instructions provided.
- Privacy Measures for Minors
- Millionhere Play is intended for persons who are 18 years of age or above. If the User is under 18 years of age, he/she shall not be permitted to use the platform ‘Millionhere Play’.
- If the User is a parent and/or guardian and believe that we may have inadvertently collected personal information from their child, they can notify us immediately by sending an email to email@example.com.
- Changes and Updates for Information
- The User is responsible for keeping his/her information current. The User may update his/her information by contacting us at firstname.lastname@example.org and we will use reasonable efforts to process any change the User makes; provided, however, that requests to delete information are subject to our internal reporting, processing and retention policies and all applicable legal obligations.
- Applicable Law & Jurisdiction
All communications between the User and Millionhere Play, Jengatron and/or any other entity of Jengatron shall be communicated in written form vide Electronic Mail (E-Mail) and in either English or Hindi language. Further, all communications between the User and the Customer Support shall also be conducted in either English or Hindi language.