Effective date: 2023-02-11

1. INTRODUCTION

Welcome to JCDC Sports Private Limited.
JCDC Sports Private Limited (“us”, “we”, or “our”) operates as tradefantasygame.com (hereinafter referred to as “Service Provider”).
Our Privacy Policy governs your visit to tradefantasygame.com, and explains how we collect, safeguard and disclose information that results from your use of our Service.
We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitute your agreement with us (“Agreement”).


2. DEFINITIONS

• SERVICE means the tradefantasygame.com website operated by JCDC Sports Private Limited.
• PERSONAL DATA means data about a living individual who can be identified from that data (or from those and other information either in our possession or likely to come into our possession).
• USAGE DATA is data collected automatically either generated by the use of Service or from the Service infrastructure itself (for example, the duration of a page visit).
  COOKIES are small files stored on your device (computer or mobile device).
• DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.
• DATA PROCESSORS (OR SERVICE PROVIDERS) mean any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
  DATA SUBJECT is any living individual who is the subject of Personal Data.
• THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data

3. INFORMATION COLLECTION AND USE

We collect several different types of information for various purposes to provide and improve our Service to you.


4. TYPES OF DATA COLLECTED

1. Personal Data
   • We collect personal data from you when you contact us, use our website or apps, when you make purchases in our shop, and when you provide us with your personal data directly.
   • We have legal obligations to you to inform you of:
     1. The personal data which we collect from you
        How we use your personal data
     2. The purposes for which we process your personal data
     3. The legal basis for processing your personal data
     4. Who we share your personal data with
     5. Where we store your personal data, and what protections we have in place for it
     6. Where we send your personal data, and
        where applicable the existence of automated decision-making and profiling (the logic, the significance and the envisaged consequences)
   • whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;
   • whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract,
     1. the periods for which we retain your personal data
     2. your rights under the General Data Protection Regulation
   • How we process your Personal Data
     • 2.1.Personal data is information that identifies you as a person, either directly or indirectly.
     • 2.2.It includes personal data
       • that has been submitted to our system by you (such as name and e-mail when signing up,
       • about you contained in messages sent through our contact forms or to our e-mail accounts), and
       • data that has been created or logged automatically by our systems (by registering the IP address, app version or browser signature you use during your visits to our site and app.
   • 2.3.When we process your personal data, we:
     • do so lawfully, fairly and in a transparent manner
     • collect it for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
     • limit our collection to what is adequate and relevant to what is necessary in relation to the purposes for which they are processed
     • take reasonable steps to keep it accurate and up to date having regard to the purposes for which they are processed
     • keep it in a form where we can identify you for no longer than is necessary, for the purposes for which it is processed
     • Process it in a manner that ensures appropriate security of the personal data. This includes protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. We use appropriate technical or organisational measures to do so
   • 2.3 PERSONAL DATA COLLECTED
     • 1 The types of personal data we may collect from you when you contact us, register and use our game and apps, or visit our website includes:
     • Category of Personal Data
     • Personal Data
     • Reason for Collection/Retention Period
     • Registration Data
     • Email address, country of residence, login name, age as at registration, alias and password.
     • This data is required to open and maintain an account. It is always retained, also if your account turns inactive, to facilitate a new team application under the same account in the future. It will be erased if you explicitly withdraw your consent.
     • User Profile
     • Your manager presentation text, favourite football team, team logo.
     • This data is optional. It is also stored until you withdraw your consent.
     • Purchase Data
     • Credit card number, address, bank account identifiers and PayPal payment details are passed directly to our payment processors when using our app. This data is required to make any purchase. We do not actually receive them.
     • This data is required to make any purchase. We do not store credit card information ourselves, but we do keep transaction data on file (type of order placed, amount spent, refunds) for a period of at least 10 years for legal and accounting reasons.
     • Information automatically logged
     • IP address, login times, app version, browser signature, Supporter status.
     • This data is necessary for us to maintain legitimate business interests such as to serve ads, perform website analytics, and carry out fraud prevention. It is automatically deleted after ________ days.
     • WHY WE COLLECT PERSONAL DATA
     • We need to collect personal data from you to communicate with you, to be able to offer you the services you request, and to be able to verify your age.
     • Without your personal data
     • our website would not function properly;
     • we could not provide you with our game;
     • we could not respond to you if you have any questions;
     • we could not comply with our legal obligations;
     • we could not maintain our legitimate business operations;

5. FROM WHERE DO WE OBTAIN YOUR PERSONAL DATA

We primarily obtain personal data about you directly from you, when you register and through your continued use of the website;
Other users of tradefatasygame may also post information relating to you on our forums, in guestbooks, press announcements, the jcdc messaging system or in the tradefatasygame chat. Such information could contain personal detail


6. USE OF DATA

JCDC Sports Private Limited uses the collected data for various purposes:

• to provide and maintain our Service;
• to notify you about changes to our Service;
• to allow you to participate in interactive features of our Service when you choose to do so;
• to provide customer support;
• to gather analysis or valuable information so that we can improve our Service;
• to monitor the usage of our Service;
• to detect, prevent and address technical issues;
• to fulfill any other purpose for which you provide it;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to provide you with notices about your account and/or subscription, including expiration and renewal notices, email instructions, etc.;
• to provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
• in any other way we may describe when you provide the information;
• for any other purpose with your consent.
• USAGE OF DATA
• We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through any device (“Usage Data”).
• This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
• When you access Service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.
• TRACKING COOKIES DATA
• We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
• Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
• You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
• Examples of Cookies we use:
• 0.1. Session Cookies: We use Session Cookies to operate our Service.
• 0.2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
• 0.3. Security Cookies: We use Security Cookies for security purposes.
• Other Data
• While using our Service, we may also collect the following information: date of birth & gender, details of documents of Pan Card, Aadhar Card & Bank information in order to process the withdrawals of the users.
• RETENTION OF DATA
• We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
• We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.


7. TRANSFER OF DATA

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
JCDC Sports Private Limited will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.


8. DISCLOSURE OF DATA

We may disclose personal information that we collect, or you provide:

• Disclosure for Law Enforcement.
  • Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.
• Business Transaction.
  • If we or our subsidiaries are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred.
• Other cases. We may disclose your information also:
  • to our subsidiaries and affiliates;
  • to contractors, service providers, and other third parties we use to support our business;
  • to fulfill the purpose for which you provide it;
  • for the purpose of including your company’s logo on our website;
  • for any other purpose disclosed by us when you provide the information;
  • with your consent in any other cases;
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or other

9. SECURITY OF DATA

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal information to those employees, agents, contractors and other third parties who need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
9.1 We store all information that you provide to us on secure servers.
9.2 We train employees regarding our data privacy policies and procedures, and permit authorised employees to access information on a need to know basis, as required for their role.
9.3 We use firewalls designed to protect against intruders and test for network vulnerabilities.
9.4 Where you have a password which enables you to use our services you are responsible for keeping this password complex, secure, and confidential. If you would like to update or change your password, you may select the “Forgot your password?” link on the login page. You will be sent an email that allows you to reset your password.
9.5 However, no method of transmission over the internet or method of electronic storage is completely secure.
9.6 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please email us at support@tradefantasygame.com.
In certain circumstances, you have the following data protection rights:
0.1. the right to access, update, or delete the information we have on you;
0.2. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
0.3. The right to object. You have the right to object to our processing of your Personal Data;
0.4. The right of restriction. You have the right to request that we restrict the processing of your personal information;
0.5. The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
0.6. the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;
Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Service without some necessary data.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data.
TO STOP SELLING YOUR PERSONAL INFORMATION
We don’t sell or rent your personal information to any third parties for any purpose. We do not sell your personal information for monetary consideration. However, under some circumstances, if the government agencies may ask we have to provide the users information. You are the only owner of your Personal Data and can request disclosure or deletion at any time.

10. SERVICE PROVIDERS
We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
CI/CD tools
We may use third-party Service Providers to automate the development process of our Service.
Behavioural Remarketing
We may use remarketing services to advertise on third-party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.
Payments
We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Children’s Privacy
Our Services are not intended for use by children under the age of 18 (“Child” or “Children”).
We do not knowingly collect personally identifiable information from children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective, and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us by email: support@tradefantasygame.com.
GOVERNING LAW:

This Privacy Policy shall be governed by the laws of Delhi, India.

RESTRICTION OF LIABILITY
JCDC makes no claims, promises or guarantees about the accuracy, completeness, or adequacy of the contents available through the App and expressly disclaims liability for errors and omissions in the contents available through the App.
No warranty of any kind, implied, expressed or statutory, including but not limited to the warranties of non-infringement of third party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus, is given with respect to the contents available through the App or its links to other internet resources as may be available to Your through the App.
Reference in the App to any specific commercial products, processes, or services, or the use of any trade, firm or corporation name is for the information and convenience of the public, and does not constitute endorsement, recommendation, or favouring by us.
CONFIDENTIALITY
Except as otherwise provided in this Privacy Policy, We will keep Your Personal Information private and will not share it with third parties, unless We believe in good faith that disclosure of Your Personal Information or any other information We collect about You is necessary for Permitted Use or to:
Comply with a court order or other legal process;
Protect the rights, property or safety of Striker or another party;
Enforce the Agreement, including Terms; or
Respond to claims that any posting or other content violates the rights of third-parties
Updating Information:
You will promptly notify TFG if there are any changes, updates or modifications to your information. Further, you may also review, update or modify your information and user preferences by logging into your Profile page on the portal.
User Account and Data Deletion:
Users are entitled to request TFG to delete their User accounts and their personal information by sending an email with their written request to support@tradefantasygame.com. We will do our best to respond promptly and in any event within one month of the following:

Our receipt of your written request; or
Our receipt of any further information we may ask you to provide to enable us to comply with your request, whichever is later.

As an alternative to account deletion, by writing to support@tradefantasygame.com, you also have the option to request either:
(i) the suspension of your account, after which you will not be able to play paid contests on your User account but will continue to have access to other parts of the Portal; or
(ii) Temporary deactivation of your account, where you will no longer be able to log into the Portal but which allows you to request reactivation of your account with all your account data.
If you proceed with permanent deactivation of your account, you will lose access to the Portal and the Services, including any User data and personal information associated with your account. Users may request for account restoration within six (6) months from the date of notification of account deletion by TFG by writing to support@tradefantasygame.com.
When you request deletion of your data, we follow a deletion process that ensures that your data is safely and completely removed from our servers or retained only in anonymised form. We try to ensure that our services protect information from accidental or malicious deletion. Because of this, there may be delays between when you request deletion and when copies are deleted from our active and backup systems.
Conditions of Use:
TFG DOES NOT WARRANT THAT THIS PORTAL, IT’S SERVERS, OR EMAIL SENT BY US OR ON OUR BEHALF ARE VIRUS FREE. TFG WILL NOT BE LIABLE FOR ANY DAMAGES OF ANY KIND ARISING FROM THE USE OF THIS PORTAL, INCLUDING, BUT NOT LIMITED TO COMPENSATORY, DIRECT, INDIRECT, INCIDENTAL, PUNITIVE, SPECIAL AND CONSEQUENTIAL DAMAGES, LOSS OF DATA, GOODWILL, BUSINESS OPPORTUNITY, INCOME OR PROFIT, LOSS OF OR DAMAGE TO PROPERTY AND CLAIMS OF THIRD PARTIES. IN NO EVENT WILL TFG BE LIABLE FOR ANY DAMAGES WHATSOEVER IN AN AMOUNT IN EXCESS OF AN AMOUNT OF INR 100.
Advertising:
When TFG presents information to it’s online advertisers — to help them understand our audience and confirm the value of advertising on the Portal — it is usually in the form of aggregated statistics on traffic to various pages within our site. When you register with TFG, we contact you from time to time about updating your content to provide features which we believe may benefit you.
Several deceptive emails, websites, blogs etc. claiming to be from or associated with TFG may or are circulating on the Internet. These emails, websites, blogs etc. often include our logo, photos, links, content or other information. Some emails, websites, blogs etc. call the user requesting the user to provide login name, password etc. or inform the user that the user has won a prize/ gift or provide a method to commit illegal/ unauthorized act or deed or request detailed personal information or a payment of some kind. The sources and contents of these emails, websites, blogs etc. and accompanying materials are in no way associated with TFG. For your own protection, we strongly recommend not responding to such emails or using these websites, blogs etc. We may use the information provided by you to TFG, including your email address or phone number, to contact you about the Services availed by you or to inform you of our updated Services if any.
Links:
TFG also includes links to other websites. Such websites are governed by their respective privacy policies, which are beyond TFG’s control. Once the User leaves TFG’s servers (the User can tell where he/she is by checking the URL in the location bar on the User’s browser), use of any information provided by the User is governed by the privacy policy of the operator of the site which the User is visiting. That policy may differ from TFG’s own. If the User can’t find the privacy policy of any of these sites via a link from the site’s homepage, the User may contact the site directly for more information. TFG is not responsible for the privacy practices or the content of such websites.
Contact Us:
Any questions or clarifications with respect to this Policy or any complaints, comments, concerns or feedback can be sent to TFG at: support@tradefantasygame.com or by normal/physical mail addressed to: JCDC SPORTS PRIVATE LIMITED17 F/F DDA, HAUZ KHAS SFS D A NEW DELHI, DELHI, South West

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