Privacy Policy

Introduction

Thank you for using "RUMMY" and we fully value your privacy. We would like to hereby explain how we collect, use, store and share the information, and how you may access, update, control and protect your personal information when using "RUMMY" services (including the website and mobile application of "RUMMY").

You may find the specific provisions of our Privacy Policy in the corresponding sections:

1. Introduction of Personal information

2. Personal information we collect

3. How we use the personal information we collect

4. How we use cookies and relevant technologies

5. How we store personal information

6. The personal information you share, transfer and disclose

7. Your rights to personal information

8. About the information you share

9. About sensitive personal information

10. How we protect minors

11. Application Scope

12. Changes to Privacy Policy

We RUMMY respect and protect your privacy. When you use our services, we may collect, use, store and share your information in accordance with the "Rummy" privacy policy (this “Privacy Policy”). Through this Privacy Policy, you would understand how you may access, update, manage and protect your information via our services. This Privacy Policy is closely related to the "RUMMY" service, we recommend that you carefully read and comprehend the full content, and make the choice as you deem appropriate. We strive to draft this Privacy Policy in easy and concise wording, and highlight in bold the terms that are significant to your rights and interest, and sensitive personal information. We also provide links to further clarifications on the technical terms involved in this Privacy Policy for better comprehension. If you or your guardian disagree with anything in this Privacy Policy, you should immediately cease using it. By using the services of "Rummy", you/your guardian would deem to consent to RUMMY’s collecting, using, preserving and sharing your personal information in accordance with this Privacy Policy.

1. Introduction of Personal information

1.1 "Personal information" refers to all kinds of information recorded electronically or otherwise that can be used to independently identify or be combined with other information to identify natural persons. For the purpose of this Privacy Policy, the information includes name, nickname, mobile phone number, e-mail address, user password, identity information, photo, facial recognition features, gender, age, occupation, log information, equipment information, location information, IP address, audio and video recordings, payment information, mobile phone recharge, consumption record and integral mall credit exchange record.

1.2 "Personal sensitive information" means the personal information that may endanger personal and property safety once disclosed, illegally provided or misused. It would possibly cause damage to or discriminatory treatment to personal reputation or physical and mental health. For purposes of this Privacy Policy, the term includes mobile phone number, email address, user password, ID card or other identification, facial recognition features, occupational information, audio and video recordings, and payment information.

1.3 "Information after anonymization" is information whose subject could not be identified and could not be restored after technical processing. The information after anonymization shall not be classified as personal information.

1.4 Other information that cannot identify or reflect the activities of specific natural persons shall not be classified as personal information.

2. Personal information we collect

When providing services, "RUMMY" will collect your information as mentioned hereafter based on legality, rightfulness and necessity. If you do not provide the information, you may not be able to register as a user of Rummy, or enjoy some of the services provided. Even if RUMMY may continue to provide some of the services, it may not reach the intended effect.

2.1 You would be required to provide the following information that we collect:

2.1.1 Before using the "RUMMY" service, you shall create an account and complete your profile. You shall provide the mobile number or email address and set up a user password. You may sign in "RUMMY" with Facebook or a Google account. If so, we shall collect your Facebook or Google Open ID (including unique identification, avatar, and nickname). We shall identify you on the "RUMMY" platform and serve you accordingly.

2.1.2 You may choose to provide us with photos/avatars, nicknames, names, ID cards or other identification, gender, age, industry, company, occupation, personalized message. You can choose whether to fill in or authorize "RUMMY" to access the above information in your personal account profile. This would allow other users to understand you more comprehensively.

2.1.3 When you make transactions on the "RUMMY" platform through a third party payment function, it will deem to have your consent to obtain the information of your payment instrument, risk management and payment status.

2.1.4 When you contact "RUMMY" Customer Service Team, we shall note down your email, comments or suggestions, name and contact information so that we could follow up, settle disputes or resolve problems. If you refuse to provide such information, you shall be unable to contact our customer service or our customer service team would not be able to give you feedback on the results. But this would not affect your use of the "RUMMY" service.

2.1.5 When you participate in our promotional events, we may require you to provide certain information, including your name, photo, and contact information. The information would allow us to announce the results of the event, promote the event subsequently, contact you to give you gifts, etc. If you refuse to provide such information, you may be unable to participate in the event or receive the gifts, but this will not affect your use of the services under "RUMMY".

2.1.6 The information (metadata) contained in the shared content shared by you through the services of "RUMMY", including the date, time or place of taking or uploading of shared photographs or videos, etc.

2.2 When you use the "RUMMY" service, we also collect the following information from you:

2.2.1 Log information. This refers to the technical information which the system may automatically collect through cookies or other ways when you use the "Rummy" service.

(1) Equipment Information. Including device model, operating system version, unique device identification, and battery and signal intensity.

(2) Software Information. This includes the version of the software and browser type. We collect information about the mobile applications and other software you use in order to ensure the security of your operating environment and to provide services.

(3) IP Address.

(4) Service log information, which means the information you search and browse when using the "RUMMY" service. This includes the website search terms, the URL of the social media page, and other information and content that you browse or request when you use the "RUMMY" service.

(5) Communication log information shall mean the information that you communicate through the service of "RUMMY". This includes the account you have communicated with, as well as the time, data, and duration of the communication.

(6) Log content information. This includes login, item logs, game information, etc. This shall allow you to view your history on the Clients, as well as for operational statistics analysis, customer service complaint handling and other security analysis.

2.2.2 When you use the "RUMMY" product consumption function, we would collect your recharge, consumption records and other information. This would allow you to check your transaction records and maximize the security of your virtual goods. The above information is necessary to fulfill the consumer functions of the "RUMMY" products; otherwise, the transaction could not be completed. But this would not affect you using the "Rummy" service.

2.2.3 Location information is collected so that you do not have to enter the geographic coordinates to obtain services. For your first time using the "Rummy" service, we would prompt you to choose whether and when to allow "RUMMY" to get your location information. While using "RUMMY", you could choose at any time by setting up whether and when to allow "RUMMY" to access your location information. Upon your permission, we would use the IP address, GPS and other sensors that provide the relevant information (e.g. nearby equipment, WIFI access points and base station information for "RUMMY") to obtain your location. If you refuse to allow "RUMMY" to get your location information, you will need to manually locate yourself.

2.2.4 Other relevant information. In order to help you better use our products or services, we shall collect relevant information. To better serve you and improve your experience, we may collect and use relevant operational and game information in “RUMMY” (such information would be referred to as "the Information”. The information includes but not limited to your login status, gaming information/status, achievement information). The information could be presented to you, or other users or your friends.

2.3 Shared information. This refers to the information that you share with other parties, and the information shared by other users which contains your information, and the information stored when you use the services of "Rummy". Of which, the services of "RUMMY" include the link from social media, other services provided by third parties or other websites. You may press the "Share" button from third party social media, services or websites to share some content to "RUMMY" or you may log on through the third-party connection services. These functions may collect your information (including log information) and may install cookies on your computer to ensure the proper function of the aforementioned.

2.4 Please understand that the functions and services may be updated and developed from time to time. If any function or service that is not described in this Privacy Policy would collect your information, we shall otherwise explain the content, scope and purpose of information collection and request your consent by means of webpage prompts, interactive processes, website announcements, separate agreement, etc.

3. How we use the personal information we collect

We strictly comply with the laws and regulations and the agreements with users, and use the collected information for the following purposes:

3.1 Your personal information would be used in the scenarios specified in the "Personal information we collect".

3.2 Your personal information may be used in the following scenarios, directly or reasonably related to the purpose asserted in the "Personal information we collect" section:

3.2.1 When providing services, for the purpose of identity authentication, customer services, security protection, fraud monitoring, archiving and backup, to ensure the security of products and services.

3.2.2 Assist in designing new services and improving existing services.

3.2.3 Better understand how you access and use "RUMMY"'s services and respond specifically to your personalization, including language, location, personalized help services and instructions setting, or reply to your other requirement.

3.2.4 We would analyze statistics on our service usage and may share these statistics publicly or with third parties, but these statistics do not contain any identifiable information.

3.2.5 We provide you with relevant advertisements instead of commonly released advertisements.

"Rummy" may analyze your information to send you marketing information through "RUMMY" services, e-mail or otherwise to provide or promote "RUMMY" or third parties' goods and services including:

Goods and services supplied by "RUMMY", its affiliates and joint venture partners, including instant messaging, online media, interactive entertainment, social network, payment, internet search, location and map, application, data management, online advertising, internet finance and other social media, entertainment, e-commerce, information and communication software and services ("internet services"); and

Goods and services from third-party internet providers and other providers related to following sectors: food and beverage, sports, music, films, television, live performances and other arts and entertainment, books, magazines and other journals, clothing and accessories, jewelry, cosmetics, personal health and hygiene, electronics, collectibles, household utensils, electrical appliances, furnishings and decoration, pets, cars, hotels, transportation and tourism, banking, insurance and financial services, membership points and reward schemes, and other goods and services that "RUMMY" believes may be relevant to you.

If you do not wish "RUMMY" to use your personal information for the purpose of the foregoing advertising, you may, through the instructions provided by "RUMMY" in the advertisement or the guidelines provided in a specific service, request that "RUMMY" cease to use your personal information for such purpose.

3.2.6 Evaluate and improve the advertising and promotional activities in the "Rummy" service.

3.2.7 Software certification or management software updates.

3.2.8 Enable you to participate in surveys on "RUMMY" products and services.

3.2.9 In order to provide users with a better experience, improve services or other purposes as agreed by you, subject to applicable laws and regulations, we may use personal information collected through one of "RUMMY"'s services to apply to other "RUMMY"'s services. This would include using the personal information collected from one of the "Rummy" services and use it in another service, to provide you with the specific content or to present relevant information rather than commonly released one. If "RUMMY" provides the corresponding options in the related services, you can also take the initiative to request "Rummy" to provide and store personal information in the service for other services.

3.3 We will notify you and obtain explicit consent to any use of your personal information that exceeds the intended and reasonable related scope of the "Personal information we collect".

3.4 In addition, in accordance with relevant laws and regulations as well as national standards, we may collect or use your personal information without your authorization in the following circumstances.

3.4.1 Those directly related to the national security and national defense;

3.4.2 Those directly related to public security, public health or vital public interests;

3.4.3 Those directly related to the criminal investigation, prosecution, trial and enforcement of judgments;

3.4.4 For the purpose of protecting the major legitimate rights and interests of the information subject or other individuals but difficult to obtain the consent of the subject himself or herself;

3.4.5 Where the personal information collected is made public by the subject of personal information on its own;

3.4.6 Collecting personal information from the information center that lawfully discloses such information, such as lawful news reports and government information disclosure, etc.;

3.4.7 Other circumstances as stipulated by laws and regulations.

4. How we use cookies and relevant technologies

4.1 "RUMMY" and third party partners may collect and use your information through cookies or some other means, and save such information as log information.

4.2 "RUMMY" uses its own cookies in order to provide you with more personalized user experience and service, as well as for the following purposes:

4.2.1 Remember your identity. Cookies help "RUMMY" to identify you as a registered user of "RUMMY" or save any information you provide to "RUMMY" about your preferences or other information.

4.2.2 Analyze your use of the "RUMMY" service. "Rummy" can use cookies to find out why you are using RUMMY's services, or which pages or services are most popular.

4.2.3 Advertising optimization. Cookies help "RUMMY" to provide you with ads of relevancy based on your information, rather than with universal advertising.

4.3 While "RUMMY" uses cookies for these purposes, it may provide advertisers and other partners summarized non-personal information collected through cookies. These may be used to analyze how you and other users use "RUMMY"'s services and use such information for advertising services.

4.4 There may be cookies placed by advertisers and other partners on "Rummy"'s products and services. These cookies may collect non-personal information that can be used to analyze how users use the service, send you ads that may be of interest to you, or evaluate the effectiveness of the advertising service. These third-party cookies’ collecting and using such information does not subject to this Privacy Policy, but to their own privacy policy, and "RUMMY" is not liable for third party cookies.

4.5 You can deny or manage cookies through browser settings. But be aware that if you deactivate cookies, "RUMMY" may not provide the best service experience for you, and some services may not work properly. At the same time, you will still receive the same amount of ads, but these ads will be less relevant to you.

5. How we store personal information

5.1 Retention Period

5.1.1 We will continue to store our users' personal information throughout the period they use the RUMMY service.

5.1.2 When you delete your personal information or close your account, we will retain your existing personal information for the minimum period of time required by the laws and regulations, and we will no longer commercialize your personal information for the minimum period of time required by the laws and regulations. We will anonymize your personal information if it exceeds the above retention period. The exception would apply in the following circumstances:

(1) In order to cooperate with public security, national security and other governmental agents in investigating the criminal acts committed by users in the course of using the "RUMMY", when users delete their personal information or close their accounts on their own initiative, we will, within the limitation period for criminal prosecution provided by the Criminal Law, encrypt and isolate the personal information of users for archiving.

(2) If you seriously violate laws, regulations or platform agreements when using the “RUMMY” service, your credit record of violation of laws or breach of contract will be kept permanently.

(3) Where "RUMMY" and you have entered into a specific privacy agreement to agree on the retention period of certain types of information, such agreement shall prevail.

5.2 Information Storage Location

The personal information we collect shall be stored and transmitted according to Indian law.

5.3 Safety Protection Measures

5.3.1 We will adopt a strict security system and customary security technologies (such as TSL and SSL) and procedures to ensure that your personal information will not be lost, leaked, damaged or unauthorized accessed or used.

5.3.2 We will take the following security technical measures to protect your personal information:

(1) The personal information of users is encrypted and stored in the server through data isolation technology.

(2) The encrypted transfer protocol will be used in the data transfer.

(3) Strictly control the access to data, and establish a comprehensive system for applying for and approving access to sensitive data.

(4) Establish a data security monitoring and audit system, and carry out comprehensive data security control.

5.4 Disposal Method

5.4.1 In response to the security risks that may arise from the disclosure, damage or loss of personal information, we have promulgated a number of regimes within the company, specifying the classification, grading standards, internal process (including emergency response process) and remedial actions of security incidents and vulnerabilities.

5.4.2 In the event of a security incident, we will promptly inform you of the basic circumstances and risks of the incident, the measures we have taken or will take and recommendations on how you can reduce the risks yourself.

5.4.3 We will promptly notify affected users of the security incident by notification, letter or telephone call, etc. When it is difficult to inform users one by one, we will announce the warming through the platform.

5.5 Suspension of Operation

5.5.1 If "RUMMY" ceases to operate, we will issue an announcement at least 30 days in advance on the "RUMMY" platform and stop collecting personal information in a timely manner.

5.5.2 Upon suspension of operations, we shall cease the commercial use of personal information and the collected information will be anonymized after the minimum retention period prescribed by laws and regulations.

6. The Personal Information you share, transfer and disclose

We shall comply with all relevant laws and regulations and keep your personal information confidential. We would not share your personal information except in the following situations:

6.1 Subject to your prior consent, we may share with third parties the personal information prescribed under "Personal information we collect";

6.2 For necessary external process only, we may share your personal information with third-party partners (third-party service providers, contractors, agents, advertising partners, application developers, etc., for example, communications service providers who send emails or notifications on our behalf, map service providers who provide us with location services) which may not located in your jurisdiction. They would process the information on our behalf in accordance with our instructions, privacy policies and other relevant confidentiality and security policies, and for the following purposes:

(1) To provide you with our services;

(2) Achieving the purposes prescribed in Section “Personal information we collect”;

(3) To comply with our obligations and exercise our rights under this Privacy Policy;

(4) To understand, maintain and improve our service.

We would use encryption, anonymization and other means to protect your information security when sharing your information with the above mentioned third parties.

6.3 When your personal information is shared with third parties as a result of mergers, acquisitions, asset transfers and other transactions along with the development of our business, we will notify you of the relevant circumstances by notification, public announcements or otherwise. We shall continue to protect or require new administrators to protect your personal information in accordance with laws and regulations and at standards no lower than those required by this Privacy Policy.

6.4 We shall use the information we have collected for big data analysis. For example, the information we collect may be used to analyze urban thermographs or industry insights that do not contain any personal information. We may share statistically non-identifiable information with our partners about how users use our services or about the general trends of our services.

6.5 In addition, in accordance with relevant laws, regulations and national standards, we may not require the prior authorization from the persons whose personal information is involved in the sharing, transfer and public disclosure of personal information in the following circumstances:

 (1) Those directly related to the national security and national defense;

 (2) Those directly related to public security, public health or vital public interests;

(3) Those directly related to the criminal investigation, prosecution, trial and enforcement of judgments;

(4) For the purpose of protecting the major legitimate rights and interests of the information subject or other individuals but difficult to obtain the consent of the subject himself or herself;

(5) Where the personal information collected is made public by the subject of personal information on its own;

(6) Collecting personal information from the information center that lawfully discloses such information, such as lawful news reports and government information disclosure, etc.

7. Your rights to personal information

7.1 Access to personal information. You may access your information at "Rummy" by the following:

(1) Account. You may access your personal information by clicking on your avatar through the "RUMMY" application.

(2) Recharge Records. You may access your recharge records through the Application – Recharge – Recharge Records.

7.2 Amend personal information. You have the right to update or correct when you need to update your personal information, or when you find errors in the personal information that "RUMMY" collects or stores. You may correct or modify personal information at "RUMMY", either by submitting your request to the "RUMMY" customer service team, or correct or modify your own personal information through the following:

 (1) Account. You correct or modify the personal information at the Account.

 (2) Setup. You may correct or modify such information as passwords through the Setup.

(3) Recharge. You may correct or modify the payment method or other information through the Recharge function.

7.3 Delete personal information. If you wish to delete your personal information, you could contact "RUMMY" online customer service or by phone and submit a request. We will delete or anonymize your personal information in the minimum retention period required by the laws and regulations. We will not commercially use your personal information during the minimum retention period required by the laws and regulations mentioned above. However, your request to delete personal information will not be subject to the minimum retention periods required by laws and regulations in the following circumstances:

 (1) ”Rummy” collects and uses your personal information violating laws and regulations.

(2) “RUMMY” collects and uses your personal information violating our agreement.

7.4 Withdrawal of consent. We will safeguard the user’s right to withdraw such consent by the following means:

(1) The commercial advertisement message sent by "RUMMY" will provide you with specific unsubscription methods. You may withdraw your consent accordingly.

(2) You may withdraw the authorization for "RUMMY" to access your personal information through the device setup function by turning off permissions to the device (including location, address book, photos, microphones, cameras, notices, etc.).

(3) You may also revoke authorization partially by deleting information or otherwise. When you revoke your consent or authorization, we may be unable to provide the services corresponding to the revoked authorization. However, your withdrawal of consent or authorization shall not affect the processing of personal information based on your consent prior to such withdrawal.

7.5 Cancellation of account. You could cancel your account by setting up "Rummy". Unless otherwise required by laws and regulations, after the account is canceled, we shall cease to provide services to you and will keep your personal information for the period set forth herein. Upon expiry of such a period, we will anonymize your personal information.

7.6 If you are unable to access, correct or delete your personal information, withdraw your consent or cancel your account, you may contact the "Rummy" customer service team via the "User Feedback" function of the application or by phone. The "RUMMY" team may need to verify your identity. We shall respond or explain within 20 days after verifying your identity.

8. About the information you share

"Rummy"'s multiple services allow you to share information about you publicly not only with your social network, but also with all users who use the service. For example, information that you upload or publish (including personal information that you publish, lists that you create), your reply to information uploaded or published by others, and location data and log information that is related to this information.

Other users using the "RUMMY" service may also share information (including location data and log information) that pertains to you. In particular, "RUMMY"'s social media service is designed to allow you to share information with users around the world, allowing shared information to be communicated in real-time and widely.

Information remains in the public domain as long as you do not delete shared information; even if you delete shared information, it may be independently cached, copied, or stored by other users or unrelated third parties not controlled by "Rummy", or stored by other users or such third parties in the public domain. Therefore, please seriously consider the information you upload, release and exchange through our service. In some cases, you can control the scope of visitors who may access your shared information by privacy settings for certain services. If you request to delete your personal information from the services under “RUMMY”, please do so in the manner provided by these Special Terms of Service.

9. About sensitive personal information

Certain personal information may be considered sensitive because of its specificities, such as race, religion, personal health, and medical information. Compared with other personal information, sensitive personal information is subject to stricter protection. Please note that your sensitive personal information may be disclosed as a result of the content and information you provide, upload or publish when using our service (such as photographs or information about your social activities). You need to think carefully about whether to disclose your sensitive personal information when using our service. By continuing to use Rummy,” you agree that your sensitive personal information may be processed for the purposes and in the manner described in this Privacy Policy.

10. How we protect minors

10.1 We expect parents or guardians to instruct minors to use our services. We will protect the confidentiality and security of minors’ information under applicable national laws and regulations.

10.2 If you are minor, it is recommended that you use our service and provide your information after your parents or guardians have read this Privacy Policy and with their consent. In cases where we collect your information with the consent of your parent or guardian, we will only use or disclose this information where it is legally permissible, explicitly consented to by the parent or guardian or necessary to protect your interest. If your guardian does not agree that you may use our services or provide us with information in accordance with this Privacy Policy, please cease using our services immediately and promptly notify us so that we may take appropriate action.

10.3 If you are a parent or guardian of a minor, please contact us at the contact details above if you have questions regarding the processing of information about the minor under your guardianship.

11. Application Scope

11.1 This Privacy Policy applies to all services provided by "RUMMY" except for certain specific services. Those specific services will be governed by a specific privacy policy. The privacy policy for that particular service or services constitutes a part of this Privacy Policy, and, in the event of any inconsistency, the specific privacy policy shall apply.

11.2 Please note that this Privacy Policy does not apply to the following circumstances:

11.2.1 Information collected by third party services connected through the services of “RUMMY”, including any third party websites;

11.2.2 The information collected by the third party which provides advertising services under “RUMMY”. If you use products or services of third parties, you are subject to the privacy policies of such third parties (and not this Privacy Policy), and you are required to read their contents carefully.

12. Changes to Privacy Policy

12.1 We will amend this Privacy Policy in a timely manner if “RUMMY” undergoes any of the following changes:

(1) Changes in the business function;

(2) Change of the storage place of users' personal information;

 (3) Any change in the usage rules of the personal information;

(4) Any change in our contact information or complaint channel;

(5) Other changes which may affect the security of users’ personal information or affect the users’ right to privacy.

12.2 After the revision of the privacy policy, we will release the latest version at "RUMMY" and notify the users with the latest version.

12.3 We would not reduce your rights under this Privacy Policy without your explicit consent.

12.4 Unless otherwise specified, the revised privacy policies shall come into force on the released date.

The Version of 04th, March 2020

Effective as of 04th, March 2020

company name:LEGEND TECHNOLOGY PRIVATE LIMITED

company address:Shop at 308,Plot No-2, Sector 5 Aggarwal,MLU 

Plaza,Dwarka,NEWDELHI,South West Delhi,Delhi,India,110075

consumer hotline:+91 6396854223

Email:legendtp2020@gmail.com