India Data Privacy Addendum
This Addendum supplements and forms an integral part of the core Privacy Notice. It applies to individuals who access or use our Services from India, including: (1) users of our Services; (2) visitors to our platforms, website, and apps; (3) individuals interacting with us via social media, email, phone, or other means; (4) suppliers and service providers (including their personnel); and (5) any other individuals with whom we communicate or conduct business in India. It constitutes a standalone itemised notice and is provided in accordance with the requirements of applicable laws. In the event of any inconsistency between the core Notice and this Addendum, this Addendum shall prevail.
DEFINITIONS
For the purposes of this Addendum, “Personal Data” means any information which may be collected or otherwise received by us that relates to you, and which either directly or indirectly, in combination with other information available, is capable of identifying you.
CATEGORIES OF PERSONAL DATA
| Category | Specific Data Elements | Purpose(s) |
|---|---|---|
| Identifiers | Name, username, email address, mobile device ID, IP address, advertising IDs | Account creation, Service delivery, advertising |
| Technical / Usage Data | OS version, device type, browser and device information, Clickstream Data, log data, cookies and web beacons, third-party websites visited | Service improvement, analytics, fraud prevention, information security |
| Payment / Transaction Data | Purchase history, in-app transaction records (financial SPDI such as card details is held only by payment processors) | Payment processing, legal compliance |
| Customer Support Data | Correspondence, game-play history, username/ID | Customer support |
| Geolocation Data | City- and country-level only; region or postal code (not precise GPS data) | Service localisation, advertising |
| Communication Preferences | Interests, notification settings | Marketing (subject to consent) |
PURPOSE OF PROCESSING
We ensure that Personal Data is collected and processed for lawful purposes in a fair and transparent manner. These purposes include:
- For marketing, data analytics, marketing campaigns, and survey purposes;
- To provide you with a more personalised and improved user experience;
- To ensure safety at our premises and to ensure the technical functionality and security of our Services;
- To monitor traffic and usage patterns for information security purposes;
- To update, consolidate, and improve the accuracy of any information related to you;
- To meet our legal and regulatory obligations, and to comply with applicable law including by seeking professional, legal, or accounting advice; and
- Any other purpose reasonably connected with the Services and notified at the time of collection.
HOW WE COLLECT PERSONAL DATA
In addition to the means described in the core Notice, we may collect Personal Data from and/or about you in the following ways:
- Directly from you (such as when you access our platforms or contact us through our services);
- Automatically when you use our IT systems, security tools, or websites (such as cookies, web beacons, and analytics tools); and
- From third parties, including insurers, regulators, and our affiliates.
MINORS
We do not knowingly or intentionally process the personal data of minors below the Applicable Minimum Age. Any personal data of a minor inadvertently received by us will be promptly deleted in accordance with our core Privacy Notice.
RIGHTS OF DATA PRINCIPALS
Indian users have the following rights:
- Right to Access Information: Right to obtain a summary of personal data being processed and the processing activities.
- Right to Correction and Erasure: Right to correction, completion, updating, and erasure of personal data.
- Right to Grievance Redressal: Right to have grievances redressed by the Data Fiduciary.
- Right to Nominate: Right to nominate another individual to exercise your rights in the event of your death or incapacity.
- Right to Withdraw Consent: You may withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing before withdrawal. Where consent withdrawal makes it impractical to continue providing a Service, we may discontinue that Service.
To exercise these rights, please contact our Grievance Officer at harsh@spill.games or our Global Privacy Contact at privacy@spill.games. We will respond within reasonable time as per applicable laws. You may withdraw consent as specified in the core notice. You may also give, manage and withdraw consent through a Consent Manager registered with the Board.
DATA RETENTION
We will retain the personal data of Indian users for as long as reasonably necessary to fulfil the purposes for which it was collected, as required by applicable law, or until withdrawal of consent (whichever is earlier).
CROSS-BORDER TRANSFER
Transfers of personal data of Indian users outside India will be made in accordance with applicable laws and any government notifications restricting transfers to specified countries. Where required by applicable notifications, we will implement data localisation for the relevant categories of personal data. The sections of the core Notice titled “Sharing of Your Information” and “Transfer of Personal Information Outside Your Country” apply, mutatis mutandis, to the categories of individuals listed in the scope of this Addendum, to the extent relevant and applicable.
CHANGES TO THE ADDENDUM
We reserve the right to amend, modify, or update this Addendum at our sole discretion from time to time as and when the need arises. The most recently published version of this Addendum shall prevail over any of its previous versions. You are encouraged to check this Addendum periodically to stay informed of any changes.
CONSENT AND WITHDRAWAL
By submitting Personal Data to us, you acknowledge that you have read and understood this Addendum and agree to the collection, use, processing, and transfer of your Personal Data as set out herein, and that all information provided by you is accurate and complete to the best of your knowledge. In the event of a change in applicable law regarding data protection in India, including by way of further implementation, you expressly consent to our continued collection, use, storage, and disclosure of your Personal Data. You may be required to provide additional consents in the form and manner prescribed. Should you choose not to provide such additional consents, you may not be able to use and/or access certain functionalities and Services.
You are entitled to withdraw your consent for the processing of any Personal Data at any time. However, as certain categories of data are necessary to administer the Services, withdrawal of consent for such processing may limit or prevent us from providing such services. All such withdrawal requests must be submitted in writing to the Grievance Officer with sufficient details to enable identification of the relevant records. We will assess and respond to each request within a reasonable period and as per timelines notified by applicable law.