SINGULARITY GAMES PRIVATE LIMITED

Store Privacy Policy

Effective Date: March 25th, 2025

Last Updated: April 1st, 2025

A. Introduction

This Store Privacy Policy (‘Policy’) will help you understand how Singularity Games Private Limited (‘BattleBucks’ or the ‘Company’) collects, processes, uses, and safeguards the personal information and data you provide when you visit, use, or access the Store, create or use a Store account, or make a purchase on the Store. This Policy does not apply to any other forms of data collection or processing, including, without limitation, data gathered offline or data collected on third-party websites or checkout pages. This Policy is intended to supplement and operate in conjunction with the Terms of Store (which can be accessed at hear) and Supporting Policies. Any term not specifically defined herein shall have the meaning ascribed to it in the Terms.

BattleBucks 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 BattleBucks related to their obligations under this Policy. It is the sole responsibility of the User to stay informed of any updates, or policy amendments or modifications issued by BattleBucks, as more particularly detailed in Section K (Amendments and modifications to the Terms or the Supporting Policies) of the Terms.

Battlebucks may, at its sole discretion, determine that any action by the User breaches this Policy, the Terms, or the Supporting Policies, and BattleBucks may, at its sole discretion and without prior notice, cancel, modify, or terminate your account at any time.

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 Store. 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 Supporting 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 N (Contact and Support). 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.


B. What Data Do We Collect?

When you use or access the Store, you trust us with your personal information. The information we collect depends on how you use the Store and which Products or services you choose. We only collect data that is necessary to provide, improve, and support Store features and to fulfil your orders in the best possible manner. To use or access the Store, BattleBucks may collect your personal information with your prior consent. The requested information may include, but is not limited to:

  1. Contact and Personal Information: We may collect your name, age, date of birth, email address, mobile number, shipping and billing addresses, recipient details, and account identifiers. Where required, we may also collect identity documentation for KYC or compliance with applicable laws.
  2. Transaction information: We may collect Store-specific order and transaction details such as items viewed or purchased, digital goods used (e.g. gift cards), digital goods redemption history, order IDs, invoices, payment method type (e.g., UPI, card network, wallet), masked instrument identifiers as returned by the payment gateway, authorization/settlement status, and refund or chargeback outcomes (we do not store full card numbers or CVV on our servers). We may collect shipping and logistics information necessary to fulfil orders, including the name of our courier partner, tracking IDs, delivery status and attempts, proof of delivery, and order history. Returns and after-sales data may also be collected, including return/exchange requests, reasons provided, pickup details, and quality inspection results for products.
  3. Technical and Device Information: We may collect information about the devices and networks you use to access the Store, such as device type, operating system, browser type, IP address, and interaction logs (pages visited, cart events, 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.
  4. Support and Communications: We may collect records of communications with customer support (emails, chat transcripts, voice recordings, attachments such as photos/videos provided for claim assessment) and your stated preferences regarding returns, refunds, cancellations, or exchanges.
  5. Other information: We may collect demographic details provided through surveys or feedback, information received when you connect social accounts to the Store, and data collected for advertising, analytics, and personalisation purposes.

C. 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 directly from you when you register/sign up on the Store, place an order, enter delivery details, provide payment information, submit reviews or feedback, contact customer support, or otherwise interact with the Store.
  2. Automatically: We may gather information through cookies, web beacons, and similar tracking tools that monitor your interaction with the Store. For the purposes of this policy, ‘non-personal information’ means the information that does not directly identify you. We may use tools or third-party analytical software to collect and use certain non-personal information automatically. For a more detailed understanding of how cookies are used to collect, analyse, and enhance your experience, please refer to the Cookie Policy at hear. We may also collect Store-specific technical and transactional data (such as page views, cart events, checkout steps, and error logs) to improve Store performance and user experience.
  3. Through Your Device: When you use or access the Store, we may collect information from your device, including location data, to provide location-specific features (for example, showing prices in your local currency, tailoring promotions to your region, or identifying the nearest pick-up or service centre) or comply with applicable laws and regulations. We may also process information necessary to send you transactional updates and promotional communications via SMS, email, and/or in-app notifications, as per your communication preferences. With your permission, we may access your device’s camera and microphone functionalities, such as recording video and audio, for purposes that include, but are not limited to, video KYC processes (where applicable) or enable voice typing. We may also access files stored on your device, such as audio and video files, for the functioning of various in-app features, including but not limited to in-app chat services with customer support.
  4. Through third parties: We may receive limited information from payment gateways (such as masked payment instrument details, authorisation/settlement status), logistics providers (such as tracking and delivery confirmations), third-party sellers (such as order and return updates), or analytics and advertising partners, to enable us to process transactions, provide Store-level customer support, and improve your experience.
  5. From Social Media or Connected Accounts: If you choose to link your Store account with a social network or other third-party service, we may receive basic profile information as permitted by your settings on that 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.


D.How Do We Use Your Data?

When you make transactions through the Store, we may collect and store information, including your contact details (such as phone number and email address), payment and billing information, shipping or delivery address, and preferences regarding returns, refunds, or cancellations, as well as order and delivery details. This information is used to process your requests, automatically complete forms for future transactions, and enhance your User experience. 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 the data collected to maintain, improve, and personalise our Services. This includes using the data to:
  • create your profile with us;
  • provide, maintain and improve the services, design and functionality of the Store;
  • process, fulfil, ship, deliver BattleBucks-Fulfilled Product orders, and coordinate with payment gateways and logistics partners;
  • handle returns, refunds, cancellations;
  • issue and redeem gift cards, apply rewards or in‑game currency for Store purchases, and maintain related transaction records;;
  • generate invoices and comply with legal requirements, including GST disclosures and e‑commerce regulations;
  • run Store promotions, contests, deals;
  • send transactional notifications, policy updates, or account-related communications;
  • detect, prevent and investigate fraud or misuse;
  • 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 Store;
  • Personalise product recommendations and promotional content based on your Store activity.

2.Customer Support: We use the data collected to provide customer support and resolve any concerns you may have regarding the use and access of our Store.

3.Research and Development: We utilise the data collected for research, analysis, and the development of the Store to enhance the UI/UX, enabling you to use and access the Store effectively. 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 Store.

4.Security Purposes: We may use the information to protect us, our users, or the Store.

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

6.Legal Requests and 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.

We will not use information collected from you for any purpose other than those described in this Policy, unless we update this Policy and, where required by law, obtain your consent before such use.


E. Storage, Retention and Security

We and/or third parties acting on our behalf or providing services to us follow reasonable security practices and procedures 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 Store, applications, portals, and network equipment have industry-standard security precautions in place to protect against the loss, misuse, and alteration of information within 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 Store, 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 and/or third parties acting on our behalf or providing services to us 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 can access your information by logging into your account or profile on the Store.
  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 address provided in Section N (Contact and Support) below.
  3. Withdrawal of Consent and Account Deletion: You may withdraw your consent to our processing of your personal information at any time. Withdrawing consent may affect our ability to provide certain services that rely on such processing. If you wish to delete your account, you can do so through the profile menu on the Store or by contacting us at the email address given in Section N (Contact and Support) below. Upon account deletion, we will stop collecting new data from you and will delete or anonymise your personal information, except where we are required to retain it under applicable law or for the purposes of preventing fraud, resolving disputes, enforcing our agreements, or other legitimate business needs. Please note that withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal, and some information may remain in backup systems for a limited time until overwritten.

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 Store or for safety, security, or fraud prevention to re-enable your use of our Store, or to comply with our legal obligations as per applicable law. We will not retain your data if it is no longer required by us and there is no legal obligation to retain it.


G. 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 Store, 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 users, including processing payments, shipping/delivery, and handling returns/refunds/exchanges for BattleBucks-Fulfilled Product. 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 financial institutions with which we have partnered. These partners will use the information we provide as described in their respective policies. Any business partners 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, we may share customer information as part of the transaction. We ensure that any such transfer is subject to contractual safeguards or adequacy mechanisms as required by applicable law.
  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 ensure that any such transfer is subject to contractual safeguards or adequacy mechanisms as required by applicable law.

H. Social Media

The Store may provide the option to integrate with sharing services and tools (such as the Google+1 button, Facebook Like button, among others) that can be used to share information while using or accessing our Store. The use of these services and tools is a free choice for the users.

The social features that the User agrees to use enable the sharing of information with other contacts or the general public, depending on the configuration options provided by the social media entity. 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 or access the Store 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 the User experience. This information is used solely to connect to social media and display your data on the Store, such as your username, and to enable actions like sending requests, connecting 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. Linking your social media account to the Store is entirely optional. If you choose to unlink your social media account, the connection will be removed, and we will no longer receive new information from that account. However, unlinking does not automatically delete any data previously shared or collected through the integration. To delete the data we have received from your accounts, you may write us an email at the address given in Section N (Contact and Support) below.


I. Miscellaneous
  1. We diligently strive to maintain our records with the latest information provided by you. It is your responsibility to ensure that the information or data you provide is accurate and up-to-date, and that you have all the necessary rights, permissions, and consent to provide such information or data.
  2. The Store may contain links to external websites that are not managed or maintained by us. This Policy applies solely to the use and access of the Store. You are requested to read the privacy policies of other websites when visiting them.
  3. Links to third-party websites on the Store 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 [insert email]. 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. Amendments and modifications to the Privacy Policy

We reserve the right to change this Policy at any time. In the event that we make material changes to this Policy, they will be re-posted in the ’Privacy’ section of our websites and apps with the date the modifications were made indicated at the top of the page. BattleBucks reserves the right to modify or amend this Policy at its sole discretion, at any time, to the extent permitted by applicable laws. Any notices, updates, or policy changes may be communicated to you through such means as the Company may, in its sole discretion, deem appropriate, including but not limited to one or more of the following methods: email to the address registered on your Store account, SMS to your registered mobile number, in‑app notifications, website pop‑ups, or messages within your Store account dashboard. You agree that any such communication shall constitute valid and sufficient notice, and that it is your responsibility to keep your contact information current and to check for such communications regularly. Please review this Policy periodically to stay informed about any changes that may be made to it. Your continued use of the Store after such change(s) constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Store or opt out by sending us appropriate notice. If you wish to obtain further information about the changes or to opt out of the use or access of the Store, please write to us at the address provided in Section N (Contact and Support) below.


L. Legal Disclaimer

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


M. 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 O (Grievance Redressal Mechanism) and Section R (Dispute Resolution and Arbitration Agreement) of the Terms.


N. Contact and Support

For support regarding how we collect and process your data, who we share your data with, or any other concerns related to this Policy, you may contact the Store Customer Support at support@battlebucks.com.