Privacy Policy

We value the trust you place in us and recognize the importance of secure access and information privacy. This privacy policy (“Privacy Policy”) is an electronic record in terms of the Information Technology Act, 2000 (as may be amended, modified, re-enacted, consolidated or replaced from time to time) and Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and other rules thereunder pertaining to electronic records in various statutes as applicable and amended from time to time. This Privacy Policy does not require any physical, electronic or digital signature and is a legally binding document between the User and the Association.

This Privacy Policy for https://epwa.in/(“Website”) is intended to provide Users (as defined below) of the Website with a clear and complete information about the data and Information (as defined below) that the Association (as defined below) receives and collates in connection with the Content (as defined below) and/or services available on the Website, and the way such data and Information is stored and used.

This Privacy Policy applies to the information, content and services provided by Esports Players Welfare Association and its affiliates (“the Association” or “We” or “Us” or “Ourselves”), having its registered office at C-1, Basement, West End Colony, New Delhi- 110022. All the content including news updates and other information relating to Esports provided on the Website is general content for informational purpose only (“Content”). We are committed towards protecting the privacy and Information of the users who access the Website and/or provide information (“User” or “Users” or “You” or “Your”). This Privacy Policy outlines the usage policies and practices that apply to the Website and also sets forth what all Information and/or database the Website gathers (categorized as mandatory or optional) and how We receive, collect, use, hold, share and protect such Information collected from the Users of the Website.

Please review the Privacy Policy carefully so that You understand Our privacy practices. If You have any complaints or and grievances with respect to the procession of Information, You may get in touch with Our Grievance Officer i.e. at rudrashish@epwa.in.

1. Acceptance of terms of the Privacy Policy by the Users

This Privacy Policy is to be read and understood along with the cookie policy (“Cookie Policy”), terms of use (“Terms of Use”) and Disclaimer (“Disclaimer”) collectively referred to as “Policies”), which are applicable on You when You visit, access and/or use Our Website. The defined terms used in this Privacy Policy if not defined herein, shall have the same meaning as assigned to them in other Policies. By using this Website, You signify Your acceptance of the Privacy Policy and expressly consent to Our collection, use, disclosure, and retention of Your data/Information. If You do not agree to this Privacy Policy and/or to Our processing of Your Information in the manner outlined in this Privacy Policy, please do not use this Website or submit any Information to Us. The Association has the right to amend the Privacy Policy without any prior notice to You. To make sure You are aware of any such changes, please read this Privacy Policy periodically. Your continued use of the Website following the posting of changes to this Privacy Policy indicates Your confirmed acceptance to this Privacy Policy.

BY ACCESSING OUR WEBSITE OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY.

2. Scope of the Privacy Policy

This Privacy Policy refers and applies only to the Website. Its main aim is to inform the Users of the way their Information/data is collected and  processed and used, providing relevant information to the User, as well as fixing the accessing conditions and the use of the Website. The data collected is used only to enhance the operation of the Website, allowing You to use all the listed features and allowing us to respond to Your requests/queries in an efficient manner.

3. Information collected by the Website

• Personal identifiable information

The information collected from You by the Association may constitute ‘Personal Information’ or ‘sensitive personal data or information’ as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPI Rules”). Personal Identifiable Information means any information that may be used to uniquely identify an individual, including but not limited to the following:

1. Information about Your personal identity inter alia Your name, age, sex, height, weight, nationality, blood group;
2. Information about Your parents/guardian inter alia their name, age, occupation, nationality;

• Your/Your parent’s or guardian’s contact details such as address, postal code, telephone or mobile number;

1. User ID information such as Your username, email address and other security-related information used by You in relation to access and use of Our Website and Content; However, the password of Your account with the Website automatically get saved in Our server when You create an account or register on the Website which shall not be accessed by the Association unless desired under any legal obligation.
2. Financial information such as bank account, credit card, debit card or other payment instrument details.

The aforementioned shall collectively be referred to as “Personal Information”. Personal Information will also include any personally identifiable information provided by You in any form during any interaction or communication with Us or any other Users of Our Website.

When You use Our Website, We collect and store Your Personal Information in order to offer enrollment, understand and analyze Your use of Our Website, to communicate with You either directly or indirectly through Our partners including for customer service, to notify You of any updated information and new activities and other related functions offered by the Website/Us, keep You informed about the latest activities/initiatives undertaken by the Association, and other facilities and services provided on the Website. The financial information forming part of the Personal Information is strictly used for processing the payment against Annual Fees [as defined under the Player’s Terms and Conditions (“T&C”)]. For the aforesaid purpose, We only collect such Personal Information that We consider relevant to understand You or Your requirements/interest.

Personal Information may also get collected and shared with third-parties if there is content from the Website that You specifically and knowingly upload, share or transmit to an email recipient, online community, Website, or to the public, e.g. uploaded photos, posted reviews or comments, or information about You or anything posted by You that You choose to share with others through features which may be provided on Our Website. Such uploaded, shared or transmitted content will also be subject to the privacy policy of the email, online community, website, social media intermediary or other platforms to which You upload, share or transmit the content.

• Information we collect during access and use of Our Website:

Apart from any Personal Information provided by You, We may also collect certain non-personal and/or technical information through third-party sources, platforms (such as social networking intermediaries, databases, online marketing firms, and ad targeting firms) and other channels, including but not limited to:

1. if any feature of the Website, whether now existing or that may be placed in the future provides You access to any third-party social networking services through the Website, We may collect, personal contact information and/or any personal data that is part of Your profile on such third-party social network and that You allow that third party social network to share with Us (e.g. name, email address, gender, birthday, city, profile picture, user ID, friend list).
2. demographic data, such as age range, gender, and interests;

• advertisement interaction and viewing data, such as ad click-through rates and information about how many times You viewed a particular ad.; and

1. unique identifiers, including mobile device identification numbers, that can identify the physical location of such devices at the point of access in accordance with applicable law.

Please note that the Website may combine the information that We collect with information We obtain from third-party sources.

• In addition to the above, We may collect information about how You use Our Website such as the date and time You visit the Website, the sections or pages of the Website that You visit, the amount of time You spend viewing the Website, the number of times You return to the Website, visits to Website outside Our network, and other click-stream data. Some of this data may be shared with partners who referred You to Our Website and who will use the data to optimize who else they refer to Our Website. Sometimes this data can be shared with partners who help Us deliver ads to You on Websites not controlled by Us.

The aforementioned information herein collected by Us under Clause 3.1, 3.2 and 3.3 are collectively referred to as “Information”.

4. How will Information be used

We use the Information to understand Your needs and accordingly facilitate Our services and route You through the relevant information that meets Your needs/interest. We do not sell, rent, trade or exchange any Information of Our Users. We may provide the Information to Our affiliates and service providers under contract (such as logistic service providers, customer care, data analytics) to support the operation of the Website and Our services To the extent We use Your Personal Information to market to You, We will provide You the ability to opt-out of such uses.

We may also use the Information to provide contents and services that are targeted to Your interests. By accepting the Privacy Policy, You expressly agree to receive this communications/information. If You do not wish to receive these communications, We encourage You to opt out of the receipt thereof by clicking unsubscribe to any email communications.

• Processing for User Login

We may use the Information for processing Your login for Our Website.

• Technical and functional management

We use technical data such as Your IP address to help diagnose problems and resolve issues related to functionality of the Website.

• Improvement of Website

We aggregate and analyze the Information that We collect and may use the same to monitor and analyze use of the Website, to increase Our Website’s functionality, and to better tailor Our Content and design to suit Our Users’/visitors’ needs so as to provide them with a smooth, efficient, safe and customized experience while using the Website.

• Request fulfillment & to improve customer service

We may also use the Information that We collect to fulfill Your requests for services,  content and information, which helps Us respond to Your customer service requests and support needs, more efficiently. We may also use Information in the aggregate to understand the preferences and choices of Our Users as a group and use feedback You provide to improve Our services/functionality and provide information that may interest the Users.

Further, We use the Information to resolve disputes; troubleshoot problems; measure consumer interest in the services/Content provided by Us; detect and protect Us against error, fraud and other criminal activity; enforce the Terms of Use or this Privacy Policy, and in general to improve the Users experience.

• Email Communications w.r.t marketing and newsletters etc.

We may use the Information that We collect to send You e-mail communications, such as editorial updates, information about Our Website and/or Us through the Website or otherwise, newsletters, marketing and promotional messages about Our own or Our marketing partners’ products and services that may be of interest to You. It may also be used to respond to Your inquiries, questions, and/or other requests. If You signed up for one of Our email newsletters, We will also send You the newsletters that You requested. If You decide to opt-in to Our mailing list, You will receive emails that may include Association’s news, updates, initiatives or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, We include detailed unsubscribe instructions at the bottom of each email or User may contact Us via Our Website.

• Enforcement

We may use the Information that We collect to prevent illegal activities, to enforce the Privacy Policy, and to otherwise protect Our rights and the rights of Our Users. In addition to the uses identified above, We may use the Information that We collect for any other purposes disclosed to You at the time We collect Your information.

5. Disclosure of Information to Others

• Legal Requests and/or Compliance with Applicable Laws

We co-operate with law enforcement and regulatory inquiries, as well as other third parties to enforce laws, such as intellectual property rights, fraud and other rights, to help protect You and the community. Therefore, in response to a verified request by any statutory authority including but not limited to law enforcement agency or other government officials relating to a criminal investigation or alleged illegal activity, We may (and You authorize Us to) disclose, as per the applicable laws, some of Your Information as is reasonably necessary to respond /comply with the statutory mandate including but not limited to court orders, or other legal process. We may access, use, transfer or disclose Your Information to third parties such as government or law enforcement authorities or private parties, if it is legally and statutorily required to do so under any of the following conditions:

1. To satisfy any applicable law, rule, regulation, governmental requests or legal process.
2. To protect and/or defend and/or enforce Our Privacy Policy for online services or other policies applicable to any online services in case of potential violations.

• To secure Our systems.

1. To respond to claims that an advertisement, posting or other Content violates the rights of a third party.
2. To protect the rights, property or personal safety of the Users and the public in general for any reason.
3. To detect, prevent or otherwise address fraud, security or technical issues.

• To prevent or stop activity We may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity.

In case of any illegal, unethical or legally actionable activity, We may use IP address or other device identifiers, to identify users, and may do so in cooperation with third parties such as internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such Information to third parties, all in Our discretion. Such disclosures may be carried out without notice to You. However, We shall not sell or rent a User’s Information to any third party or use any Users’ e-mail id for sending any unsolicited mails.

• Other Corporate Entities

We share much of Our data, including Information about You, with Our affiliates, subsidiaries, and joint ventures that are committed to servicing Your online requests and related services, throughout the world. To the extent that these entities have access to Your Information, they remain bound by the existing Privacy Policy. As We continue to develop Our business, We might sell or buy stores, subsidiaries or business units. In such transactions, Users’ Information generally is one of the transferred business assets but shall remain subject to the terms and conditions contained in this Privacy Policy.

• Internal Service Providers

We may employ third party services to facilitate or outsource one or more aspects of the business and, therefore We may provide some of Your Information to these internal service providers. These internal service providers are subject to confidentiality agreements with Us and other legal restrictions that prohibit their use of Your Information for any other purpose except to facilitate the specific outsourced service. In the event of Your direct involvement with the internal service provider, any additional information disclosed by You to them shall be subject to internal service provider’s own applicable privacy policy and the Association shall not be responsible for the same.

• With Users’ explicit consent

We do not sell or rent Uses’ Information to third parties for their marketing purposes, but with Your explicit consent, We may disclose Your Information (i) to third parties for their marketing and advertising purposes; (ii) to send You promotions, notifications, or other services. However, the Users have the right to opt-out of receiving marketing communications about the Association/Website.

6. Protection and Security Information collected by the Website

We take Our security responsibilities very seriously and take all reasonable technical and organizational measures to protect Your Information once We have received the Information. We use Website security measures consistent with current best practices to protect Our Website, email and mailing lists. These measures include technical, procedural, monitoring and tracking steps intended to safeguard data from misuse, unauthorized access or disclosure, loss, alteration or destruction.

We also have physical, electronic, and procedural safeguards that comply with the laws prevalent in India to protect Information about You and, accordingly, We take appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of Your Information, username, password, transaction information and data stored on Our Website in compliance with the provisions of the Information Technology Act, 2000 and SPI Rules, to ensure the protection and preservation of Your privacy. In addition to the above, We, on best endeavor basis, try to limit access to Personal Information of Our Users to only such Users who We believe reasonably need to come into contact with that information to provide services to You. However, no data transmissions over the internet can be guaranteed to be 100 percent secure. Consequently, We cannot ensure or warrant the security of any information You transmit to Us and You understand that any information that You share is done at Your own risk.

7. Retention of Information

Unless specified otherwise in this Privacy Policy, We will retain Your Information as permitted or required by applicable law. In some cases, even after cancellation of enrolment as per the T&C, the Player’s (as defined under the T&C) Information may be retained for the purpose of legal and regulatory compliances, resolving disputes, concluding activities related to enrollment cancellation, enforcing Our agreements and Privacy Policy or for any other reason which may be deemed necessary. However, the Information of the User will get anonymized upon cancellation of enrollment except for the above mentioned purposes.

8. Change in Personal Information

You are responsible for maintaining the accuracy of the Personal Information submitted at the time of enrollment with the Association. If there are any changes in Your Personal Information details, You may correct or update the information. To do so, please log into Your account, and You will find options for editing the information You have submitted.

9. Disclaimer

This Privacy Policy is to be read with the other Policies (as may be applicable to You) which together establish the use and limitations of liability governing the use of the Website.

10. Usage of Cookies

In some instances, We and Our service providers use cookies and other technology to automatically collect certain types of information when You visit Our Website, as well as through emails that We may exchange. The collection of this information allows Us to customize Your online experience, improve the performance, usability and effectiveness of Our online presence, and to measure effectiveness of Our marketing strategies. To know more about this,

11. Indemnification

You agree and undertake to indemnify and hold harmless Us, from and against any and all suit, dispute, actions, losses, damages, costs and expenses, if any, of whatsoever nature, arising out of or in any way connected with this Privacy Policy, Information and/or Your use or access of Website.

You expressly understand that under no circumstances, including, but not limited to, negligence, shall We be liable to You or any other person or entity for any direct, indirect, incidental, special, or consequential damages, including, but not limited to damages for loss of profits, goodwill, use, data or other intangible losses, resulting from circumstances, including but not limited to: (i) unauthorized access to or alteration of Information; (ii)  any unauthorized access to or use of Our secure servers and/or any and all Information stored therein.

You represent that You have accessed the Website and have provided Information on Your own initiative and are responsible for compliance with all applicable laws including, but not limited to, any applicable local laws. This Privacy Policy is governed by the laws of India and the courts at New Delhi shall have exclusive jurisdiction.

12. Changes in this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time. Although We will post/display details of all changes made to the Privacy Policy on the Website or send Users an email, however, the same can be changed without prior confirmation to You. We encourage You to visit the Website from time to time to make sure You are aware of any changes and/or latest information on Our privacy policies and practices. We shall not be liable for any damages You may suffer as a result of failure to provide You notice of any changes to this Privacy Policy as set forth herein.

13. Contact Us

In case You have any queries pertaining to the Privacy Policy or our use of Your Personal Information, You can direct any questions or complaints to Us by contacting the designated grievance officer through e-mail at rudrashish@epwa.in. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of Your Personal Information as soon as possible. We try to respond to all legitimate requests within 30 (thirty) days from date of receipt of the complaint. Occasionally it may take Us longer than the same if Your request is particularly complex or You have made a number of requests. In this case, we will notify You and keep You updated.