SINGULARITY GAMES PRIVATE LIMITED

Privacy Policy

Effective Date: March 25th, 2025

Last Updated: April 1st, 2025

Introduction

This Privacy Policy (‘Policy’) will help you understand how the Company or BattleBucks (i.e. Singularity Games Private Limited), collects, processes, uses and protects the personal information and data that you provide to us when you visit, install or register on the Platform or use our Services. This Policy does not extend to any other forms of data collection or processing, without limitation, data gathered offline, through our Platform and/ or the Services that do not expressly reference this Policy, or through third-party websites that we may link to.

This Policy is intended to supplement and operate in conjunction with the Terms of the Company, which can be accessed at hear Any term not specifically defined herein shall have the meaning ascribed to it in the Terms.

The Company reserves the right to, from time to time, amend and modify this Policy. The User acknowledges and accepts that they may also be subject to receiving periodic communications from the Company related to their obligation to comply with this Policy. It is the sole responsibility of the User to stay informed of any updates, policy amendments or modifications issued by the Company, as more particularly detailed in Section G (Amendments and modifications to the Terms or the BattleBucks Policies) of the Terms.

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please see Section W (How to contact us?) of the Terms.

For users who are minors (persons under 18 years of age), valid verifiable consent from a parent or legal guardian is required before registering for or using the Platform and/or the Services. Minors may use the Store only with their parents' or guardians' consent. The parent or legal guardian is responsible for supervising and authorising the minor’s use and for any purchases or agreements made on the minor’s behalf; by providing consent, the parent/guardian represents that they have the authority to do so and accepts this Policy, the Terms and the BattleBucks Policies on the minor’s behalf. Where required by applicable law or platform rules, we will obtain verifiable parental consent and may implement parental gates, limited functionality, or other protective measures for minor accounts. Parents and guardians may review, correct, or request deletion of their child’s personal data and may revoke consent by contacting us at the details provided in Section W (How to contact us?) of the Terms. We process and protect minors’ personal data in compliance with applicable legal and platform requirements and apply heightened safeguards to such data.

This document is an electronic record in terms of the Information Technology Act, 2000 and rules thereunder as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.


What Data Do We Collect?

When you use or access the Platform and/or the Services, you trust us with your personal information. The type of data we collect depends on how you engage with the Platform and/or the Services and which features you choose. We only collect information necessary to provide, improve, and support the Platform and/or the Services. To use or access the Platform and/or the Services, BattleBucks may collect your personal information with your prior consent. The requested information may include, but is not limited to:

  • Contact and Personal Information: We may collect your name, age, date of birth, email address, mobile number, addresses, and account identifiers. Where required, we may also collect identity documentation for KYC or compliance with applicable laws.
  • Transaction Information: We may collect records of your activity and transactions within the Platform and/or the Services, such as in-game purchases, contest entries, referral redemptions, reward claims, order or transaction identifiers generated by us, invoices, the type of payment method used (for example UPI, card network, or wallet), masked payment instrument identifiers returned by payment gateways, and the status of authorisation, settlement, refunds, or chargebacks.
  • Technical and Device Information: We may collect information about the devices and networks you use to access the Platform and/or the Services, such as device type, operating system, browser type, IP address, and interaction logs (pages visited, events triggered, error reports). We may also collect unique identifiers made available by your device or platform provider (such as resettable app identifiers, including Google’s App Set ID or Apple’s Identifier), which are used in accordance with this Policy for purposes such as analytics, security, fraud prevention, and functionality.
  • Support and Communications: We may collect records of your communications with customer support, including emails, chat transcripts, call recordings, and attachments such as screenshots, photos, or videos provided for troubleshooting or claim assessment. We may also record your preferences relating to cancellations, refunds, or reward queries.
  • Other Information: We may collect demographic details you provide through surveys or feedback forms, information received when you connect social accounts to the Platform and/or the Services, and data collected for advertising, analytics, and personalisation purposes.

How Do We Collect Your Data?

We, and third parties acting on our behalf, collect information about you in the following ways:

  1. Directly from you: We collect information when you register or sign up on the Platform, create or update your account, participate in contests or promotions, provide payment information for in-app purchases, submit reviews or feedback, contact customer support, or otherwise interact with the Platform and/or the Services.
  2. Automatically: We may gather information through cookies, web beacons, and similar tracking tools that monitor your interaction with the Platform and/or the Services. For the purposes of this policy, “non-personal information” means the information that does not directly identify you. BattleBucks may employ tools or third-party analytical software to automatically collect and use certain non-personal information. For a more detailed understanding of how cookies are used to collect, analyse, and enhance your experience, please refer to the Cookie Policy, accessible at hear
  3. Through Your Device: When you access the Platform and/or the Services, we may collect information from your device, including location data (for example, to enable region-specific features or comply with legal requirements). We may also process information to send you transactional updates and promotional communications via SMS, email, and/or in-app notifications, in line with your communication preferences. With your permission, we may access your device’s camera and microphone functionalities (for example, to support video KYC processes where applicable, or to enable voice input features). We may also access files stored on your device, such as audio or video files, if required to enable certain in-app features such as chat or support services.
  4. Through third parties: We may receive limited information from payment gateways (such as masked payment instrument details, authorisation or settlement status), distribution partners, analytics providers, or advertising partners, in order to process transactions, provide customer support, and improve the Platform and/or the Services.
  5. From social media or connected accounts: If you choose to link your account on the Platform with a social network or other third-party service, we may receive basic profile information from that service (such as your name, email address, and profile picture) as permitted by your settings on the third-party service.

When we utilise Google API Services or Apple frameworks to access your data, we will accurately represent BattleBucks as the requesting party, maintain all credentials in confidence, and clearly disclose the categories of data being requested. If we later seek to access any new categories of such data not already disclosed in this Policy, we will first update this Policy and prompt you to review and consent to those changes before accessing the new data.


How Do We Use Your Data?

When you engage with the Platform and/or the Services, we may collect and store information such as your contact details, payment and billing information, preferences relating to refunds or cancellations, and your activity within the Platform and/or the Services. This information is used to process your requests, streamline your experience, and enable us to provide and improve the Platform and/or Services. We do not and will never sell your data to third parties for profit.

If data is obtained through Google API Services or Apple frameworks, we will only use that data for the purpose(s) explicitly disclosed at the time of authorisation. We will not use such data for any secondary or undisclosed purpose without obtaining your renewed consent.

The data we, and/or third parties acting on our behalf or providing services to us, collect is used for the following purposes:

  1. Enable services: We use collected data to maintain, improve, and personalise the Platform and/or the Services. This includes:
  • Creating and managing your account and profile.
  • Providing, maintaining, and enhancing the design, features, and functionality of the Platform and/or the Services.
  • Facilitating Contests, Deals, Levels, and In-Game Assets as set forth in Section L of the Terms.
  • Processing in-app purchases, redemptions of rewards, gift cards, or other digital entitlements, and maintaining related transaction records.
  • Sending transactional notifications, policy updates, or account-related communications.
  • Providing requested information and support needed to effect transactions on or through the Platform and/or the Services.
  • Determine your eligibility to avail of our Services and participate in exclusive contests, programs and related offerings.
  • Perform internal operations that are necessary to provide our Services, such as troubleshooting software bugs, conducting data analysis, detecting fraud, or analysing usage and activity trends on the Platform.
  • Detecting, preventing, and investigating fraud, misuse, or suspicious activity; and
  • Confirming your registration for any of our Services, including seminars, webinars, or workshops.
  • Customise your experience with us, which could include displaying content based on your preferences.

2.Customer Support: We use the data collected to provide customer support and/or resolve your concerns arising from the use of our Services.

3.Research and Development: We use the data collected for research, analysis, and the development of the Platform to improve the UI/UX to allow you optimum use of the Platform and the Services. We may also look at site trends and customer interests by combining information we receive from you with information about you obtained from third parties to enhance the Platform and/or the Services.

4. Security Purposes: We may use information to safeguard the Platform, our users, and our systems against threats or abuse.

5.Marketing and Outreach: We may use the data collected to promote and market the Platform and/or the Services. This includes using your information for calls and mails to users regarding site updates, new services, upcoming events, and the status of any orders placed on the Platform and/or the Services.

6.Legal Compliance: We may use the data collected to fulfil our legal or contractual obligations, as required by applicable law, or as requested by legal, regulatory, or investigatory authorities. Upon receipt of a valid and lawful order from a court or a government agency authorised to carry out investigative, protective, or cybersecurity functions, we will provide information in our control or possession, or other required assistance, as soon as reasonably possible and no later than seventy two (72) hours from receipt of such order, or within such other time as may be prescribed by applicable law, including but not limited to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.


E.Storage, Retention and Security

We follow reasonable security practices and procedures, as required by the applicable law, to protect your personal information from unauthorised access to and unlawful interception, disclosure, alteration, or destruction.. These measures include administrative, technical, and physical safeguards. Access to personal information is limited to our employees and partners only on a strictly need-to-know basis. The Company may adopt advanced certifications or frameworks, such as ISO/IEC 27001, in the future as it continues to enhance its security standards.

The Platform, applications, portals, and network equipment have industry-standard security precautions in place to protect the loss, misuse and alteration of information which is in our environment. We apply encryption or other appropriate security controls to protect Personal Information when stored or transmitted by us. Whenever you change or access your account information, we facilitate such changes using secure systems. Your information or data will primarily be stored in electronic form. However, certain data can also be stored in physical form.

We may enter into agreements with third parties to collect, store, and process your information or data in compliance with applicable laws.

We have taken appropriate steps for the security and protection of the Platform and the Services, however, we shall not be responsible for any breach of security or the disclosure of personal information for reasons beyond our control, including but not limited to hacking, social engineering, cyber terrorism, espionage by third parties, or any events by way of force majeure such as sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government.

We may retain certain account information for a period of up to one hundred and eighty (180) days following the cancellation or withdrawal of a user account, or for such other period as may be required under applicable law, including but not limited to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.


F. What Are Your Rights Regarding Your Data?

We employ technical, administrative, and physical safeguards to protect your data from unauthorised access, alteration, or destruction. However, no security system is impenetrable, and we cannot guarantee absolute protection. The following are your rights regarding your data:


  1. Access: You may access your information by accessing your account or profile on the Platform and/or the Services.
  2. Rectification: You may also request corrections, updates, or deletion of your information. We will make reasonable efforts to respond promptly to such requests in accordance with applicable laws and regulations. You can reach out to us at the email address provided in Section W (How to Contact Us) of the Terms.
  3. Withdrawal of Consent: You may withdraw the consent you have given us for processing your data. If you do so, we may be unable to provide the Services for which such data was sought. To withdraw your consent, you may please write us at the email address provided in Section W (How to Contact Us) of the Terms.
  4. Deletion of Account: If you wish to delete your account maintained with us, you must write to us at the email address provided in Section W (How to Contact Us) of the Terms, or you may do so through the profile menu on the BattleBucks Platform.

Please note that notwithstanding the above rights, we may retain your data for as long as is necessary for the performance of the contract between you and us, or to prevent, investigate, or identify possible misuse of our Services or for safety, security, or fraud prevention to re-enable your use of our Services, or to comply with our legal obligations. We will not retain your data if it is no longer required by us and there is no legal obligation to retain it.


With Whom Do We Share Your Data?

  1. Third-Party Service Providers: We share information with vendors, deferred payment options, SMS services, freelance professionals, marketing agencies, and cloud setup agencies who assist us in managing the Platform, online processes, and the Services. This information may be shared with these third parties strictly in accordance with this Policy, the Terms and the Cookie Policy, which will assist in providing services to the users, including payment gateway processors. Any third party that receives user data shall have in place a written agreement with us requiring compliance with this Privacy Policy and with the developer policies and requirements of the Apple App Store and Google Play Store; such agreement obligates the third party to process data only as instructed, to maintain confidentiality and appropriate security measures, and not to engage in activities prohibited by those platform policies, agreements, or guidelines. We ensure that any such transfer is subject to contractual safeguards or adequacy mechanisms as required by applicable law.
  2. Business Partners: We may share information with our business partners, including third-party sellers, aggregators, and partnered financial institutions. These partners will use the information we provide as described in their respective privacy policies. Any business partner that receives user data shall have in place a written agreement with us requiring compliance with this Privacy Policy and with the developer policies and requirements of the Apple App Store and Google Play Store; such agreement obligates the third party to process data only as instructed, to maintain confidentiality and appropriate security measures, and not to engage in activities prohibited by those platform policies, agreements, or guidelines. We ensure that any such transfer is subject to contractual safeguards or adequacy mechanisms as required by applicable law.
  3. Legal Compliance: We may share information if necessary to comply with the law, such as responding to a court order, or to protect our rights. This includes sharing information with government agencies or regulatory bodies.
  4. Business Successors: In the event of a sale or transfer of all or part of our business, customer information may be shared as part of the transaction.
  5. Cross-Border Data Transfer: All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to countries within the European Economic Area (“EEA”), the United Kingdom (“UK”), the United States of America, the Republic of Korea and others, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

H.Social Media

The Platform and the Services may provide the option of integrations with sharing services and tools (such as Google+1 button, Facebook Like button, among others) that can be used to share information while using or accessing our Services. We may also integrate social media services in our competitive gaming features for sharing scores and achievements between players, such as Google Play Games Services. The use of these services and tools is a free choice for the users.

The social features that the User agrees to use enables the sharing of information with other contacts or the general public, depending on the configuration options the social media entity provides. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

If you use the Platform or access the Services and connect to your Facebook or other social media accounts, you will provide us with basic account information, (i.e., user ID, name, email, gender, birthday, current city, profile picture URL and the user IDs of your friends who have also connected with our applications). We may cache data from these social media APIs to enhance User experience.This information is used solely to connect to the social media and display your data on the game accounts, such as your username, and to enable actions such as sending requests, connecting and playing with friends and sharing information on their walls or timelines.

This information is provided voluntarily when you connect our app to your social media accounts. If you do not wish to share this data, refrain from linking your social media accounts. To delete the data we have received from your accounts, please contact us at the email address provided in Section W (How to Contact Us) of the Terms.


Miscellaneous

  1. We diligently strive to maintain our records with your latest information. It is your responsibility to ensure that the information or data you provide is correct and always updated, and you have all the rights, permissions and consent to provide such information or data.
  2. The Platform may contain links to external websites that are not managed or maintained by us. This Policy applies solely to the Platform. You are requested to read the other websites’ privacy policies when visiting these websites.
  3. Links to third-party websites or services on the Platform and/or the Services do not imply endorsement or affiliation with that third party. We are not responsible for their privacy practices, and this Policy does not govern their use. We encourage you to review their privacy policies independently.
  4. Where required by Google or Apple platform rules, we will provide you with updated disclosures and obtain your renewed consent before accessing new categories of Google or Apple user data.

J. Email Opt-Out

To stop receiving our promotional emails, please email support@battlebucks.com. It may take about ten days to process your request. Even if you opt out of receiving marketing messages, we will still send you transactional messages via email and SMS about your purchases.


K. Legal Disclaimer

Our Platform and/or the Services operate as-is, and we do not represent or warrant that our Platform and/or the Services will be available at all times, or that your use of the Platform and/or the Services will be uninterrupted or error-free. We are not responsible for your ability to use or access the Platform and/or the Services or matters beyond our control. The laws of India govern this Policy.


L. Grievance Redressal Mechanism

If you believe you have been unfairly treated, harmed, or have encountered anything that violates this Policy, you have the right to raise a complaint or grievance in accordance with Section M (Grievance Redressal Mechanism) and Section P (Dispute Resolution and Arbitration Agreement) of the Terms.