This privacy policy (“Privacy Policy”) is issued by Aroha (hereinafter referred to as “Company”, “We”, “Us” or “Our”) and governs the collection, use, processing, disclosure and transfer of information capable of identifying a person (“Personal Information”) accessed or shared with Us by virtue of use or access of Our mobile application(s) and/or associated websites (collectively, “Platform”). This Privacy Policy forms a legally binding agreement between You and Us and by agreeing to this Privacy Policy, or by accessing, or by using the Services (defined below) through the Platform, you ( “You”, “Your” or “User”) consent to the collection, processing, transfer, adaptation, alteration, storage, disclosure, and other uses of Your Personal Information by Us, as described in this Privacy Policy. If You have any concerns about providing Your Personal Information, or having it used in any manner permitted by this Privacy Policy, You should not use the Services nor access the Platform.
Unless specified otherwise, this Privacy Policy applies only to the Platform and the Services, and features, software, and functionalities offered by Us, via the Platform.
For the purposes of this Privacy Policy, “Sensitive Personal Data or Information” or “Personal Data” shall have the meaning ascribed to them under applicable laws.
THIS PRIVACY POLICY IS PART OF OUR TERMS OF USE AND SHALL BE SUBJECT TO AND READ ALONG WITH OUR TERMS OF USE (“Terms”). ALL CAPITALIZED TERMS USED AND NOT DEFINED HEREIN SHALL HAVE THE MEANING ASCRIBED TO THEM UNDER THE TERMS OF USE. IT IS VITAL THAT YOU READ, UNDERSTAND, ACKNOWLEDGE AND UNCONDITIONALLY AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY OR ANY PART THEREOF, PLEASE DO NOT USE/ ACCESS/ DOWNLOAD/ INSTALL THE PLATFORM OR ANY PART THEREOF.
We retain an unconditional right to modify or amend the Privacy Policy. Once posted, any amendments to this Privacy Policy are effective immediately, unless stated otherwise. We encourage You to periodically review this page for the latest information on Our privacy practices. Continued access or use of the Services or the Platform constitute Your acceptance of the changes and the amended Privacy Policy as it stands on the date of such access or use, as the case may be.
The Company develops and operates software & technology products/ platforms and associated services (“Services”). By accessing Our Platform, Users can access Our Services, which include the access to the Platform. As set out in the Terms relating to the Services, You must be at least 18 years old to access and/or use the Services. The Services are not directed to persons under the legal age of majority or any such persons residing outside India. We do not knowingly collect any Personal Information from children under the legal age of majority. If We become aware that a child under legal age of majority has provided Personal Information, steps will be taken to remove such information and terminate such an account. If You become aware that any Personal Information of a child/minor has been or is being provided, please contact Our Grievance Officer (given below).
THIS PRIVACY POLICY DOES NOT APPLY TO MOBILE APPLICATIONS OR WEBSITES WHICH ARE NOT OWNED OR CONTROLLED BY THE COMPANY, INCLUDING THIRD PARTY LINKS AND APPLICATIONS WITH WHICH YOU MAY INTERACT WHILE USING THE PLATFORM. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION OR DATA (INCLUDING PERSONAL INFORMATION AND SENSITIVE INFORMATION) THAT YOU PROVIDE TO A THIRD-PARTY WITH WHOM YOU INTERACT THROUGH OUR PLATFORM. YOU MUST READ AND UNDERSTAND THE PRIVACY PRACTICES AND POLICIES OF SUCH THIRD PARTIES CAREFULLY BEFORE AVAILING THEIR SERVICE. WE WILL NOT ASSUME ANY LIABILITY FOR ANY HARM CAUSED TO YOU BY ACCESSING ANY THIRD-PARTY WEBSITES OR LINKS ADVERTISED ON THE PLATFORM OR BY YOU PROVIDING ANY INFORMATION OR DATA (INCLUDING PERSONAL INFORMATION AND SENSITIVE INFORMATION) TO ANY THIRD PARTIES WITH WHOM YOU INTERACT THROUGH OUR PLATFORM. YOUR ACCESS AND USAGE OF ANY THIRD-PARTY WEBSITES OR APPS IS ENTIRELY AT YOUR OWN RISK. THE COMPANY SHALL NOT BE A PARTY TO ANY TRANSACTION BETWEEN YOU AND A THIRD-PARTY SERVICE.
You hereby expressly consent to providing Your Personal Information to the Company for the purposes specified under this Privacy Policy, which is required in relation to the Services being rendered on the Platform by Us. You acknowledge that We shall collect Your Personal Information detailed under this Privacy Policy to facilitate Our Services including the transactions undertaken by Users, either by ourselves or by partnering with the relevant third-party service providers. We will only be using Your Personal Information for the purposes specified under this Privacy Policy in providing the Services to You.
You also specifically agree and consent to Us collecting, storing, processing, transferring, and sharing information related to You (including Your Personal Information) with Our partners or service providers to customize and provide the Services to You.
Personal Information collected: We may collect and receive information from You, including Your Personal Information, and You hereby consent to provide Your Personal Information at the time of registration or from third-party service providers You interact with or engaged by us. We may also obtain Personal Information from third parties to whom you have consented to share your Personal Information with and have agreed to their respective privacy policies. Such Personal Information includes:
For registration on the Platform: To access the Platform, You may be required to create an account. The personal information which may be sought while creating an account shall include, but not be limited to, Your phone number, email ID, full name, location, address, social media profile information (if You sign up via a social media account), date of birth, gender, IP address and location data, device information such as device ID, browser type, operating system, and any other details required on the Platform during registration
Customer support correspondence: When you ask for assistance from Our customer
support, the contact information You provide will be collected, as well as information about Your
session or activity on the Service/Platform, Your user ID number, chat or communication history (if
applicable), Your financial and payment information (if applicable and if required), and previous
correspondence, if any.
For availing the Services: If available through the Services, You may provide Us
with certain profile information which You consent to make public, such as a short biography,
location, website, phone number, a profile picture, information to customize your account, etc. Such
contact information may be used to send you information about the Services or related
information.
Non-Personal / Aggregated and/or Anonymised Information : We may use data
management services to access device information; metadata of incoming and outgoing calls and
messages, device storage, device identifiers, call related information and records, application
history, etc. These permissions are collected to better understand how Users access and use Our
Services, both on an aggregated and individualized (anonymised) basis, in order to improve Our
Platform, analyse player traffic and activity, respond to User desires and preferences, and for
other research and analytical purposes.
Ads: Advertisers on mobile devices sometimes use advertising identifiers to enable
and optimize their advertising, to deliver tailored ads related to Your interests (Interest-Based
Advertising or IBA). These identifiers are non-permanent, non-personal, device identifiers. We
and/or third parties may use Your device’s advertising identifier and other information associated
with it, to deliver ads that relate to Your interests and to improve and measure the effectiveness
of ad campaigns.
Location Services: We and/or third parties may use and store information about Your
location to provide special features, to deliver ads that relate to Your interests and/or to improve
and customize the Services and to ensure that You are not accessing the Platform from restricted
states in India or outside the territorial limits of the Republic of India
Links: We may keep track of how You interact with links across the Services,
including email notifications, third-party services, and client applications, by redirecting clicks
or through other means.
Log Data Services: Our backend servers automatically record information created by
Your use of the Services. This data may include information such as Your IP address, browser type,
operating system, the referring web page, pages visited, location, Your mobile carrier, device and
application IDs, search terms, and cookie information. Log data is received when You interact with
the Services. This data is used to provide the Services and to measure, customize, and improve
them.
Third-party services: We use a variety of third-party services to help the
provision of the Services, such as hosting and other services. These third-party service providers
may collect information sent by your browser as part of a web page request, such as cookies or Your
IP address, location and devices’ unique identifiers. Also, third-party ad partners may share
information to measure ad quality and tailor ads, for example, to display ads about things You may
have already shown interest in.
Device Management Services: The Device Management Services access device
information; data, metadata of incoming and outgoing calls and messages; device storage, device
identifiers, call related information and records, application history, etc. These permissions are
collected to better understand how Users access and use Our Services, both on an aggregated and
individualized basis, in order to improve Our Services, analyze player traffic and activity, respond
to user desires and preferences, and for other research and analytical purposes.
Cookies: We may monitor the use of the Platform through the use of cookies and
similar tracking devices. To illustrate, We may monitor the number of times You visit the Platform
or which pages You viewed. This information helps Us to build your user account and render better
Services to You. Some of this data will be aggregated or statistical, which means that We will not
be able to identify You individually.
Sensitive Personal Data or Information Collected: Please note that We shall always
take Your express consent before collecting any Sensitive Personal Data or Information.
We are committed to keeping all such Sensitive Personal Data or Information safe at all times and
ensure that such data/information is only transacted provided the highest possible degree of care
available under the technology presently in use. The Company will not process Your Sensitive
Personal Data or Information for any purpose other than for such specific purposes as You have
expressly consented to its use.
Using wallet, payment functions: When You use wallet and payment functionalities on
the Platform, we may collect bank account details, payment method information, (including Your UPI
handle or Virtual Payment Address (“VPA”) associated with Your registered mobile number), KYC data
and/or identification proof documents in accordance with our AML/KYC policies. Please note that We
do not collect Your Aadhaar information.
If You opt for the paid functions on the Platform, We may collect the billing and financial
information necessary to process the charges, including bank account details; and/or do so on behalf
of the relevant payment service providers. Purchases of third-party services are subject to the
policies applicable to such providers. Any payment data may need to be retained only within India to
comply with directives of the Reserve Bank of India that apply to the payment service providers We
engage to provide such payment related services.
Where We permit any third parties to collect and use Your Sensitive Personal Information, We, to the
best of Our knowledge, (i) ensure that such third parties maintain the same security standards that
are adhered to by us and prescribed under applicable data protection laws for the protection of Your
Sensitive Personal Information and (ii) take reasonable measures to ensure that the third parties do
not disclose the Sensitive Personal Information unless such disclosure has been expressly consented
to by you.
When You deposit money to Your wallet on the Platform by using Your VPA of the Unified Payments
Interface (“UPI”) payment method, We may store such VPA to facilitate seamless and swift deposit
transactions for You in the future and for enhancing Your payment experience. You understand, agree
and consent to such storing of the VPA by the Platform.
The Platform may also, from time to time, through the Payment System Providers, fetch other VPAs
associated with Your mobile number registered with the Platform. These VPAs will be used to
facilitate seamless and swift deposit transactions for You and for enhancing Your overall payment
experience. You understand, agree and consent to the Platform obtaining such VPAs from relevant
Payment System Providers and storing and displaying such VPAs to You on the Platform.
Disbursal Information Services: If You make a purchase in the Services, We may
collect the billing, payments, and financial information necessary to process the charges/payments;
and/or do so on behalf of the relevant payment service providers. Purchases of third-party services
are subject to the policies applicable to such providers.
Purpose of collecting Your Personal Information:
Some of the Personal Information, for example, Your name and/or username, may be listed publicly on the Services, including on Your profile page and in search results. You agree that We and/or third parties on Our behalf and/or Our partners may use and store the Personal Information for purposes such as contacting You as part of customer support; sending You updates or information about the Services; managing Your account and relationship with the Service, improving the in-app experience, facilitating seamless transactions, improving the Services, conducting research, surveying, and engaging with You. This may include sending You communications, marketing and promotional content about the Services or other products; as well as personalizing and optimizing the Services and/or advertising. Additionally, We may create reports or analysis for purposes of research or business intelligence.
We may use the Personal Information and non-personal information collected from You for the following intended purposes as detailed below.
We may use Your Personal Information to send You promotional emails and messages. However, We will provide You the ability to opt-out of receiving such emails and messages from Us. If You opt out, We may still send You non-promotional emails and messages, such as emails and messages about the Services and Your profile on the Platform.
By using the Platform, including any sub-domains of the Platform, or related top-level domains including mobile sites, apps, APIs and widgets and/or registering yourself with us, you authorize us or our representatives to contact you via email or phone call or SMS including third party messaging apps to offer you our services including but not limited to impart product knowledge, offer/explain any promotional offers running on the Platform and offers offered by third parties, for which reasons, personally identifiable information may be collected. Irrespective of the fact that you have registered yourself under DND or DNC or NCPR service, you still authorize us or our representatives to contact you by any means aforementioned for the above-mentioned purposes or any other related purpose till the time you are registered with us or even after cessation of registration.
Not withstanding anything contained herein, We may, in compliance with applicable laws in India, process Your Personal Information without obtaining Your consent in the following circumstances:
Responsibility for Accuracy and Completeness of Information:
We may disclose Your Personal Information in the circumstances set out below and You hereby consent to the same:
Provision of Services: Any third-party service provider to whom disclosure is necessary to enable Us to provide You with the Services which You wish to access on or through the Platform, for example, to process a disbursal instruction, Your Information has to be provided to the payment processors. Such companies shall be granted access to the Personal Information needed to perform their functions and include (but are not limited to) the following:
| Third-Party Data Recipient Entity Name | Service/Function |
|---|---|
| Payment gateways and payment aggregators | For making transactions and depositing and withdrawing money with us |
| Juspay Technologies Private Limited (or any other agency notified to You, who would be aiding Our card-on-file tokenization efforts) | Disclosure of card details for obtaining tokenization and technology services as per applicable RBI guidelines |
| SMS OTP providers | For the generation of OTP |
| IP Reverse Geolocation Providers | To ascertain and act against Users from restricted jurisdictions |
| Analytical and data management service providers | To obtain services for smooth functioning of the Platform and customizing the Platform for the needs of the Users, sharing such data with data analytics services and tools. |
| Third-party service providers | For providing better Services and better in-app experience |
Any disclosure to third parties is subject to the following:
Retention: We do not keep Your Personal Information for longer than is necessary unless We are required to do so under applicable laws. We will use Your Personal Information only for so long as is necessary:
Withdrawal of consent: You acknowledge that the Platform has duly collected Your Personal Information and other information with Your free, specific, informed, unconditional, unambiguous and explicit consent and You have the option to deny the request to provide consent for the use of any specific information or revoke the consent already given.
You may also choose to withdraw Your consent (including consent provided for processing of Your Personal Information or other information by Us or by any third party on Our behalf) provided to the Platform at any point of time. In order to withdraw Your consent for the use, processing, disclosure, sharing or transferring of any Personal Information, you may raise a request on the Platform or by mailing Us at contact@aroha.appwale.shop. However, You are responsible for the consequences of such withdrawal of consent, and the Platform may be unable to provide further Services to You if any such option to withdraw consent is exercised.
Reporting an issue: You may report any grievance in relation to your Personal
Information or any security incident to the Grievance Officer (details mentioned hereinbelow).
Right to certain information: You have the right to ask Us for (a) a summary of
Your Personal Information being processed by Us and the processing activities undertaken by Us with
respect to such Personal Information; (b) the identities of all other third-party entities with whom
Your Personal Information has been shared by Us, along with a description of the Personal
Information so shared.
Right to correction and erasure: You have the right to request the correction and
deletion or removal of Your Personal Information if the purpose of processing is complete and the
retention is not required for compliance with applicable laws. Such a right of erasure can be
exercised by writing to Us at contact@aroha.appwale.shop . On such a request for erasure, We shall
delete all Your Personal Information stored by Us, as well as ensure that any third-party service
provider processing Your Personal Information on behalf of Us deletes all Your Personal Information,
unless retention of the same is necessary for compliance with any applicable law for the time being
in force. We may, however, continue to retain Your Personal Information in an anonymized form for
analytical and research purposes
You shall at all times ensure that:
The Company maintains appropriate technical and physical safeguards to protect Information against
accidental or unlawful destruction or loss, alteration, unauthorized disclosures or access, and any
other unlawful forms of processing of the data in its possession (“Security Practices”).
We store Your Personal Information and other information only to the extent required by Us to carry
out the Services as provided herein, and if there is a legal requirement to retain the same. All
information provided by You is stored and retained on a secure server located in Bhopal, India.
Further, Our Security Practices include, but are not limited to encryption, firewalls, password
protection, limitation of access to specified personnel on a need to know basis, deidentification
and encryption and other physical security measures to guard against unauthorized access to the
server and systems and information residing on such server and systems. The security controls and
practices implemented by Us to protect Your Personal Information under this Privacy Policy are in
accordance with the reasonable security practices and procedures under Section 43A of the
Information Technology Act, 2000.
Further, the security measures We adopt to protect Your Personal Information or other information
include the following:
The Company’s Security Practices are commensurate with the information assets being protected and with the nature of the business. By using the Platform, You accept that the Security Practice and procedures mentioned above, which are designed to protect the information provided by You, are reasonable. Information including Sensitive Personal Data or Information (other than such data that is subject to data localization due to statutory or regulatory obligations) may be transferred to third parties located and/or may be stored at worldwide destinations, outside India or the location from which Your information has been collected which ensure a similar level of protection and security adhered to by Us under applicable Indian laws. However, We do not guarantee that Personal Information cannot be accessed, disclosed, altered or destroyed by breach of any of the abovementioned safeguards. We take all steps reasonably necessary, including providing notice of breach to Users, where required under applicable law, to ensure that Personal Information is treated securely and in accordance with this Privacy Policy. PLEASE UNDERSTAND THAT, WHILE WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION AGAINST POTENTIAL RISKS AND EXPOSURES, THERE IS NO ABSOLUTE SECURITY IN THE ONLINE/ INTERNET SPHERE. THEREFORE, YOU MUST NOT DISCLOSE ANY INFORMATION ON THE PLATFORM THAT IS SENSITIVE PERSONAL DATA OR INFORMATION WHICH IS NOT REQUIRED FOR YOU TO USE OUR SERVICES. YOU UNDERSTAND THAT THE TRANSMISSION OF INFORMATION OVER THE INTERNET IS NOT COMPLETELY SECURE AND THERE ARE RISKS ASSOCIATED WITH IT. ALTHOUGH WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION, WE CANNOT GUARANTEE THE SECURITY OF THE SAME WHILE IT IS BEING TRANSMITTED TO OUR PLATFORM AND ANY TRANSMISSION IS AT YOUR OWN RISK.
In case of any queries regarding Our information processing activities or to exercise Your rights with respect to Your Personal Information, or for revoking Your consent and requesting deletion of Your Personal Information held with Us, please contact the Grievance Officer. We will respond to Your request as soon as possible, and in any event within 30 (thirty) days or in accordance with the timeframe permitted under applicable law. If any court or other competent authority finds any part of this Privacy Policy to be invalid or unenforceable, the other terms of this Privacy Policy will not be affected. This Privacy Policy is governed by and interpreted in accordance with the laws of the Republic of India. Any dispute arising in connection with this Privacy Policy will be subject to the exclusive jurisdiction of the courts located in the city of Bhopal, India. You consent to the jurisdiction and venue in such courts and waive any objection as to an inconvenient forum.
Grievance Officer
In accordance with requirements under applicable laws, the name and contact details of the Grievance
Officer are provided below for Your reference:
Name: Sumit Yadav
Email address: contact@aroha.appwale.shop
This Privacy Policy is not intended to create, and does not create, any legal rights in your favor or in favor of any other person. Our liability shall be limited to the removal of Sensitive Personal Data from the system of the Website and the removal of personally identifiable elements of the Other Personal Information. Notwithstanding anything to the contrary contained in this policy and elsewhere, our aggregate liability for all claims for damages pursuant to the provisions of services on the Platform, including claims in respect to the violation of this policy, shall be limited to the the amount of platform fee collected from You on the Platform.