Privacy Policy

This Privacy Policy (hereinafter referred to as the "Privacy Policy") adopted by LeadMint Technologies Pvt. Ltd. (hereinafter referred to as "LeadMint," "We," "Us," or "Our") governs the collection, use, and transfer of information capable of identifying a person (Personal Information) accessed or shared with Us by virtue of the use or access of our mobile application, Ludo Money (hereinafter referred to as the "Platform").

By agreeing to this Privacy Policy, or by accessing or using the Services (defined below) through the Platform, you consent to the collection, transfer, adaptation, alteration, storage, disclosure, and other uses of your Personal Information as described in this Privacy Policy. If you have any concerns about providing data or having it used in any manner permitted in this Privacy Policy, you should not use the Ludo Money Services.

Unless specified otherwise, this Privacy Policy applies only to the Platform and the services, features, software, and functionalities offered by Us via the Platform.

For the purposes of this Privacy Policy, "Sensitive Personal Data or Information" or "Sensitive Information" means Personal Information that consists of the following:

• (i) Password;
• (ii) Financial information, such as bank account, debit, or credit card details;
• (iii) Physical, psychological, and mental health condition;
• (iv)Sexual orientation;
• (v) Biometric information;
• (vi) Any detail relating to the above as provided to the body corporate for providing a service; and
• (vii) Any of the information received under each of the aforesaid heads by the body corporate for processing, or to be stored or processed under a lawful contract or otherwise.

This Privacy Policy incorporates the requirements under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

(I) Our Business & Policy Applicability

LeadMint Technologies Pvt. Ltd. develops and operates software and technology products/platforms and associated services for enabling, conducting, and offering online cash-based skill games, i.e., games where skill predominates over chance, whether through the deployment of physical or mental abilities (hereinafter referred to as the "Services"). By accessing our Platform, users and players (hereinafter referred to as "Users," "You," or "Your") can access our Services, which include the provision of access to various games available on the Platform.

As set out in the terms and conditions relating to the Services (the "Terms"), you must be at least of legal age (minimum age of 18 years) to access and/or use the Services. The Services are not directed to persons under the legal age of majority or such persons residing outside India. We do not knowingly collect any Personal Information from children under the legal age. If we become aware that a child under the legal age has provided Personal Information, steps will be taken to remove such information and terminate such an account. If you become aware that any Personal Information of a child/minor has been provided, please contact our Grievance Officer (defined below).

For the purposes of this Privacy Policy, unless defined herein, all capitalized terms shall have the meaning ascribed to them under the Terms.

THIS PRIVACY POLICY DOES NOT APPLY TO MOBILE APPLICATIONS OR WEBSITES THAT ARE NOT OWNED OR CONTROLLED BY LEADMINT TECHNOLOGIES PVT. LTD., INCLUDING THIRD-PARTY LINKS AND APPLICATIONS THAT YOU MAY INTERACT WITH WHILE USING THE PLATFORM. WE WILL NOT ASSUME ANY LIABILITY FOR ANY HARM CAUSED TO YOU BY ACCESSING ANY THIRD-PARTY WEBSITES OR LINKS ADVERTISED ON THE PLATFORM. YOUR ACCESS AND USAGE OF ANY THIRD-PARTY WEBSITES OR APPS IS ENTIRELY AT YOUR OWN RISK. THE COMPANY SHALL NOT BE A PARTY TO ANY TRANSACTION BETWEEN YOU AND A THIRD-PARTY SERVICE.

Collection & Use of Information

A. Personal Information

We obtain and you consent to provide your Personal Information at the time of registration or through third-party service providers you interact with or engage with us. Such Personal Information includes:

• 1. Registration:
• Phone number
• Google email ID
• Name
• Location
• 2. Using Wallet and Payment Functions:
• Bank account details
• Payment methods (including your UPI handle or Virtual Payment Address associated with your registered mobile number)
• Name
• KYC proof documents
• Note: We do not collect Aadhaar information.
• 3. Customer Support Correspondence:
• Contact information you provide when seeking assistance
• Gameplay or activity details on the Platform
• User ID number
• Financial and payment information
• Correspondence details
• 4. Optional Profile Information:

If available through the Services, you may provide additional profile information (e.g., short biography, location, website, cell phone, picture, or account customization preferences) that you consent to make public.

B. Non-Personal / Aggregated Data

To enhance user experience and analyze behavior, Ludo Money may collect non-personal data, including but not limited to:

• 1. Ads:
• Advertising identifiers to deliver tailored ads (Interest-Based Advertising or IBA)
• Non-personal, device identifiers for measuring and optimizing ad campaigns
• 2. Location Services:
• Location data to enable features, deliver interest-based ads, and ensure compliance with geographical restrictions in India
• 3. Log Data Services:
• Information such as IP address, browser type, operating system, referring web page, pages visited, location, mobile carrier, and device/application IDs
• 4. Third-Party Services:
• Information collected by hosting providers, ad partners, and other service providers (e.g., cookies, IP address, location, and device identifiers)
• 5. Device Management Services:
• Metadata of calls/messages, device storage details, and application history for aggregated and individualized analytics, research, and service improvement

C. Sensitive Personal Data or Information

We will always seek your express consent before collecting any Sensitive Personal Data or Information (e.g., passwords, financial details, health data, etc.). Ludo Money ensures:

• 1. Purpose-Driven Use:

Sensitive information will only be used for purposes expressly consented to by you.

• 2. Data Security:
• Adherence to high security standards for storing and processing Sensitive Personal Data
• Compliance with the Reserve Bank of India's directives for payment data retention within India
• 3. Third-Party Handling:
• Third parties handling your Sensitive Personal Data are required to maintain the same security standards as us and will not disclose data without your consent.
• 4. Payment Information:
• Virtual Payment Addresses (VPAs) may be stored to facilitate seamless payment transactions and enhance the user experience.
• The Platform may fetch other VPAs associated with your registered mobile number from Payment System Providers to improve your payment experience.
• 5. Disbursal Information:
• Billing, payment, and financial data for processing transactions may be collected and/or stored by Ludo Money or relevant payment service providers.
• Purchases of third-party services are subject to the policies of those providers.

Use of Information

Some Personal Information, such as your name and/or username, may be listed publicly on the Platform, including on your profile page and in search results. By using Ludo Money, you agree that we, our partners, or authorized third parties may use and store your Personal Information for the following purposes:

• 1. Age Restriction

You must be at least 18 years of age (or 21 where applicable) to use this app. Users from states where online gaming with real money is restricted (such as Assam, Odisha, Telangana, Andhra Pradesh, etc.) are not eligible to participate.

• 2. Information We Collect

We collect:

• Personal information (name, phone number, email)
• Financial data (UPI ID, bank account details, wallet transactions)
• KYC documents (PAN, Aadhaar, etc.)
• Device information, IP address, and location data
• 3. Use of Information

We use your information to:

• Verify your identity and age
• Process payments and withdrawals
• Detect and prevent fraud
• Comply with legal obligations
• Improve app performance and experience
• 4. Data Sharing

We may share your data with:

• Payment gateway providers
• Analytics and anti-fraud tools
• Law enforcement or regulators if required

We do not sell your personal data.

• 5. Cookies and Tracking

We may use cookies and similar technologies to:

• Maintain sessions
• Track user engagement
• Improve performance and offer personalization
• 6. Security Practices

Your data is encrypted and stored securely. We use industry-standard security protocols. Sensitive data like KYC documents are handled with strict access control.

• 7. User Control

You can request:

• Data deletion
• Account deactivation
• Updates or corrections to your personal data
Contact: [email protected]
• 8. Retention Policy

We retain your data for as long as your account is active or as needed for legal and regulatory purposes.

• 9. Updates

We may update this policy. Changes will be communicated via app or email.

Information Sharing and Disclosure

We may disclose your Personal Information in the circumstances outlined below. By using Ludo Money, you consent to the sharing of your Personal Information as described:

1. Provision of Services

To provide you with seamless access to our services, your Personal Information may be shared with third-party service providers where necessary. This includes:

These third-party providers are granted access to Personal Information only to the extent necessary for their services.

2. Law Enforcement

We may disclose your Personal Information to:

• Comply with applicable laws and regulations.
• Respond to valid claims, legal processes, or judicial orders.
• Protect the property and rights of Ludo Money, its users, or the public.
• Prevent or stop illegal, unethical, or legally actionable activities.

2. Law Enforcement

We may disclose your Personal Information to:

• Comply with applicable laws and regulations.
• Respond to valid claims, legal processes, or judicial orders.
• Protect the property and rights of Ludo Money, its users, or the public.
• Prevent or stop illegal, unethical, or legally actionable activities.

3. Affiliates

Personal Information may be shared with our affiliates, business partners, agents, or third parties for:

• Facilitating services on the Platform.
• Marketing and promotional activities undertaken by or on behalf of Ludo Money.

4. Change in Control

In the event of a change in ownership, including bankruptcy, merger, acquisition, reorganization, or sale of assets, your Personal Information may be transferred to the new entity. The commitments made under this Privacy Policy will continue to apply to your data post-transfer.

• Facilitating services on the Platform.
• Marketing and promotional activities undertaken by or on behalf of Ludo Money.

Your Rights

At Ludo Money, we value your privacy and ensure that your data is retained only for as long as necessary, except where legal obligations require otherwise. Your rights include the following:

1. Data Retention

We will retain your Personal Information only for as long as it is necessary to:

• Fulfill the purposes outlined in this Privacy Policy or any agreement you have entered into with us.
• Comply with applicable laws, regulations, or evidentiary requirements.
• Address tax, fraud prevention, or legal disputes, including claims and defenses within the applicable statute of limitations.

2. Right to Withdraw Consent

You may withdraw your consent to the collection or processing of your Sensitive Personal Information for future use. However, such withdrawal:

• Will not be retrospective or apply to records required for statutory purposes.
• Will not affect ongoing contractual obligations unless the contract itself is terminated alongside the withdrawal of consent.

3. Erasure/Deletion of Data

Your data will be erased or deleted when:

• It has served the purpose for which it was collected and is no longer necessary.
• You have withdrawn consent, and there is no overriding legal obligation to retain it.
• Retention of such data is contrary to or prohibited by applicable law.

4. Right to Data Portability

You have the right to:

• Receive a copy of your Personal Information in a structured, machine-readable format.
• Transfer this information to another service provider or third party, subject to a fee. Details of this fee will be communicated upon request.
• Retention of such data is contrary to or prohibited by applicable law.

Protection of Information

At Ludo Money, we prioritize the security of your Personal Information and maintain robust technical and physical safeguards to protect it from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and other unlawful forms of data processing.

1. Security Measures

We employ the following security practices to ensure the protection of your information:

• Encryption, firewalls, and password protection.
• Restriction of access to authorized personnel on a need-to-know basis.
• De-identification and encryption of sensitive data.
• Physical security measures to prevent unauthorized access to servers and systems.

All your information is securely stored on servers located in Mumbai, India. These security practices are aligned with the sensitivity of the information and the nature of our business operations. By using our platform, you agree that these measures are reasonable and designed to protect your data.

2. Data Transfer and Storage

• Sensitive Personal Data or Information (except data subject to localization laws) may be transferred or stored at secure locations worldwide.
• Any transfer of data is done to destinations that ensure a similar level of security and protection under applicable Indian laws.

3. Breach Notification and Risk Disclosure

While we strive to protect your data, it is important to understand the following:

• No online system guarantees absolute security.
• There is a risk in transmitting Personal Information over the internet, and we cannot ensure complete protection during transmission.
• In the event of a security breach, we will take all reasonable steps, including notifying affected individuals, as required by applicable laws.

4. User Responsibility

To minimize risks, refrain from sharing any unnecessary Sensitive Personal Data or Information while using our platform. Your discretion is essential in safeguarding your data during its transmission to our services.

Term

Ludo Money may retain your Personal Information for as long as it is necessary to fulfill the purposes for which it was collected or to provide the Services. This retention period may extend even after:

• You have discontinued or deleted your account.
• The termination of the Services provided to you.

Retention Purposes

Personal Information may be retained for the following reasons:

• Compliance with legal obligations.
• Meeting regulatory requirements.
• Resolving disputes among users.
• Preventing fraud or other malicious activities.
• Any other lawful purpose necessary to maintain the integrity of our platform and services.

Deletion or Anonymization

Once the purpose for retaining your Personal Information has been fulfilled and it is no longer required for any of the aforementioned reasons, we will take steps to delete or anonymize your data in accordance with applicable laws.

Contact us:

Any questions or clarifications with respect to this Policy or any complaints, comments, concerns or feedback can be sent to LudoMoney at: — [email protected]