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Privacy Policy

This policy explains how Orvantis Technologies, the owner and operator of Real11 Fantasy Cricket, handles and protects user information.

This Privacy Policy (“Privacy Policy”) explains how Orvantis Technologies (“Orvantis Technologies”, “Company”, “we”, “us” or “our”), the owner and operator of Real11 Fantasy Cricket (“Real11”, “Platform”), collects, receives, uses, processes, stores, shares and protects information relating to users of Real11.

This Privacy Policy applies to information collected through the Real11 website, mobile application, Platform, Fantasy Cricket services, contests, features, communications and other services provided by or on behalf of Real11.

By registering for, accessing or using Real11, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your information as described herein, to the extent such consent is required under applicable law.

If you do not agree with this Privacy Policy, you should not access or use Real11.

This Privacy Policy forms part of the Real11 Terms & Conditions.

1ABOUT

Real11 is a Fantasy Cricket platform owned and operated by Orvantis Technologies.

For the purposes of applicable data-protection and privacy laws, Orvantis Technologies may act as the entity responsible for determining the purposes and means of processing User information collected through Real11.

References to “Real11”, “we”, “us” or “our” in this Privacy Policy refer to Real11 and/or Orvantis Technologies, as applicable.

2INFORMATION WE COLLECT

We may collect different categories of information depending on how you access and use Real11.

2.1 Information You Provide to Us

When you register for or use Real11, we may collect information such as:

Full name;

Username;

Mobile number;

Email address;

Date of birth;

Gender, where required;

Residential or correspondence address;

State, city or other location information;

PAN or other tax-related information;

Bank account details;

Payment-related information;

Identity verification information;

Documents submitted for verification;

Profile information;

Communication preferences;

Customer support communications; and

Other information that you voluntarily provide to us.

We may require certain information to create and maintain your Real11 Account or to provide specific services.

3IDENTITY, AGE AND ELIGIBILITY VERIFICATION

Because Real11 Fantasy Cricket is available only to eligible Users, we may collect and process information necessary to verify:

Your identity;

Your age;

Your location;

Your eligibility to participate in Fantasy Cricket;

Your compliance with applicable laws and regulations; and

Your compliance with Platform requirements.

Depending on the circumstances, verification may involve information such as PAN details, government-issued identification documents, date of birth, address information, device information or location information.

We may use third-party identity verification and compliance service providers to conduct such checks.

Where legally permitted or required, we may retain records relating to verification and compliance for the applicable period.

4LOCATION INFORMATION

Real11 may collect or otherwise process information relating to your location to determine whether you are eligible to access or participate in Fantasy Cricket services.

Location information may be obtained through:

Device or application permissions;

IP address;

Network information;

GPS or similar location technologies, where enabled and legally permissible;

Information provided by you; and

Third-party verification services.

Location verification may be necessary to comply with applicable laws, regulations, Platform restrictions and eligibility requirements.

If you disable or restrict location permissions where such information is required for eligibility verification, certain Real11 services may become unavailable to you.

You must not attempt to circumvent or manipulate Real11’s location-verification mechanisms.

5DEVICE AND TECHNICAL INFORMATION

When you access or use Real11, we may automatically collect certain technical and device-related information, including:

IP address;

Device type;

Device model;

Operating system;

Browser type and version;

Application version;

Device identifiers;

Network information;

Mobile network information;

Language and regional settings;

Time zone;

Log information;

Access dates and times;

Crash reports;

Diagnostic information; and

Other information generated through your interaction with the Platform.

We use this information to operate, secure, maintain and improve Real11.

6INFORMATION ABOUT YOUR USE OF REAL11

We may collect information relating to your activities on the Platform, including:

Account registration and login activity;

Fantasy Cricket teams created or submitted;

Contest participation;

Contest entries;

Contest rankings and results;

Fantasy points;

Captain and Vice-Captain selections;

Transaction history;

Deposits and withdrawals;

Promotional participation;

Rewards or benefits received;

Customer support interactions;

Device and session activity; and

Other interactions with Real11.

This information may be used to administer Contests, calculate rankings, process transactions, prevent fraud and provide the Platform’s services.

7PAYMENT AND TRANSACTION INFORMATION

Where payment, deposit, withdrawal, wallet or other monetary functionality is available, we may collect information necessary to process and administer transactions.

Such information may include:

Transaction ID;

Transaction amount;

Transaction date and time;

Payment status;

Bank account information;

Payment method;

Payment reference number;

Withdrawal information;

Tax-related information; and

Other information necessary for transaction processing and verification.

Payments may be processed through authorised third-party payment processors, banks and financial service providers.

Where a third-party payment provider processes your payment directly, its own privacy policy may also apply.

Real11 does not intend to collect or store full payment-card information where such information is processed directly by an authorised payment service provider, except where permitted or required by applicable law.

8COOKIES AND SIMILAR TECHNOLOGIES

Real11 may use cookies, software development kits (“SDKs”), pixels, local storage and similar technologies to operate and improve the Platform.

These technologies may be used to:

Maintain login sessions;

Remember preferences;

Understand Platform usage;

Improve functionality;

Monitor performance;

Detect fraudulent or suspicious activity;

Improve security;

Analyse traffic and usage patterns; and

Provide relevant communications or promotional content, where permitted by law.

You may be able to manage certain cookie preferences through your browser or device settings.

Disabling certain cookies or similar technologies may affect the availability or functionality of some Real11 services.

9HOW WE USE YOUR INFORMATION

We may collect, use and process User information for purposes including:

Account and Platform Administration

Creating and managing your Real11 Account;

Authenticating your identity;

Providing access to Fantasy Cricket services;

Maintaining Account records; and

Providing customer support.

Fantasy Cricket Services

Enabling you to create Fantasy Cricket teams;

Administering Fantasy Cricket Contests;

Calculating fantasy points;

Determining rankings;

Processing Contest settlements;

Communicating Contest-related information; and

Providing results and related services.

Verification and Compliance

Verifying age and identity;

Verifying location and eligibility;

Meeting legal and regulatory requirements;

Conducting compliance checks;

Preventing prohibited participation; and

Responding to lawful requests from governmental or regulatory authorities.

Payments and Financial Administration

Processing deposits and withdrawals;

Verifying payment information;

Processing refunds where applicable;

Detecting payment-related fraud;

Complying with tax requirements; and

Maintaining transaction records.

Safety, Security and Fraud Prevention

Detecting and preventing fraud;

Detecting duplicate or suspicious Accounts;

Preventing collusion and Contest manipulation;

Detecting unauthorised access;

Protecting Platform systems;

Investigating technical exploitation; and

Protecting the integrity of Real11.

Communications

Sending Account-related communications;

Providing Contest updates;

Responding to support requests;

Sending service notifications;

Communicating changes to policies or terms; and

Sending promotional communications where permitted and in accordance with applicable law.

Analytics and Improvement

Understanding how Users interact with Real11;

Monitoring Platform performance;

Identifying technical problems;

Improving User experience;

Developing new features and services; and

Conducting internal analysis and research.

10LEGAL BASES FOR PROCESSING

Depending on the applicable law and the circumstances, we may process User information on one or more of the following bases:

Your consent;

Performance of a contract or provision of requested services;

Compliance with legal or regulatory obligations;

Prevention and detection of fraud, abuse or security threats;

Protection of the rights, safety and security of Users and the Platform;

Legitimate business or operational purposes, where legally permissible; or

Other lawful grounds available under applicable law.

Where processing is based on consent and applicable law provides a right to withdraw such consent, you may withdraw consent in accordance with the applicable process.

Withdrawal of consent may affect our ability to provide certain services where the relevant information is necessary for that service.

11SHARING OF INFORMATION

We may share User information with third parties where necessary for the purposes described in this Privacy Policy or where otherwise permitted or required by law.

Such third parties may include:

Service Providers

We may engage service providers for:

Hosting and cloud infrastructure;

Identity verification;

Age and location verification;

Payment processing;

Banking services;

Data storage;

Analytics;

Security;

Fraud prevention;

Communications;

Customer support; and

Other technology or operational services.

Legal and Regulatory Authorities

We may disclose information where required or permitted by law, including in response to:

Government requests;

Regulatory requirements;

Court orders;

Legal proceedings;

Law-enforcement requests; or

Other lawful processes.

Professional Advisers

Information may be shared with professional advisers, auditors, lawyers, consultants and other advisers where reasonably necessary for legitimate business, legal, compliance or regulatory purposes.

Corporate Transactions

In connection with a merger, acquisition, restructuring, financing, sale of assets, transfer of business or similar corporate transaction, User information may be transferred or disclosed to the relevant parties, subject to applicable law.

We do not sell User personal information to third parties for their independent commercial use where such sale is prohibited by applicable law.

12THIRD-PARTY SERVICE PROVIDERS

Real11 may use third-party providers to support the operation of the Platform.

These providers may process information on our behalf for purposes including:

Identity verification;

Payment processing;

Cricket data;

Match statistics;

Hosting;

Cloud services;

Security;

Analytics;

Communications;

Customer support; and

Fraud prevention.

Third-party providers may process information in accordance with their own privacy policies and contractual obligations.

Where required by applicable law, we will take reasonable steps to ensure that relevant service providers process User information in accordance with applicable privacy and security requirements.

13CRICKET DATA AND THIRD-PARTY INFORMATION

Real11 may receive cricket-related information from official, authorised or third-party data providers.

Such information may include:

Match schedules;

Playing XI;

Player profiles;

Live scores;

Player statistics;

Match events; and

Final match results.

Information relating to real-world cricket players or matches may be obtained from third-party sources and is not necessarily personal information collected directly from the User.

Real11 may use such information to administer Fantasy Cricket Contests and calculate fantasy scores.

14COMMUNICATIONS

We may communicate with you through:

SMS;

Email;

Push notifications;

In-app notifications;

Telephone calls;

WhatsApp or other messaging services, where permitted;

Customer support channels; and

Other communication methods made available by Real11.

Service-related communications may include:

Account verification;

Login or security alerts;

Transaction notifications;

Contest updates;

Results;

Policy or Terms updates;

Customer support responses; and

Other communications necessary to provide Real11 services.

Where permitted by applicable law, we may also send promotional or marketing communications.

You may opt out of certain promotional communications through the mechanism provided in the relevant communication or through your Account settings, where available.

You may continue to receive essential service-related communications even after opting out of promotional communications.

15FRAUD PREVENTION AND PLATFORM SECURITY

Real11 takes measures to protect the integrity and security of its Platform and Users.

We may process information to:

Detect fraudulent activity;

Identify duplicate Accounts;

Detect Account sharing;

Identify suspicious transaction patterns;

Detect Contest manipulation or collusion;

Prevent unauthorised access;

Investigate technical exploitation;

Protect Platform infrastructure; and

Maintain the fairness and integrity of Fantasy Cricket Contests.

Where we reasonably suspect fraud, abuse, prohibited conduct or other unlawful activity, we may investigate the relevant Account and information and take action permitted under applicable law and the Real11 Terms & Conditions.

16DATA RETENTION

We retain User information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

Retention periods may depend on:

The nature and purpose of the information;

The duration of the User relationship;

Legal and regulatory requirements;

Tax and accounting obligations;

Fraud-prevention requirements;

Dispute resolution;

Enforcement of contractual rights; and

Security and legitimate business requirements.

When information is no longer required, we may delete, anonymise or securely dispose of it in accordance with applicable law and our internal policies.

17DATA SECURITY

We implement reasonable technical, administrative and organisational measures designed to protect User information against:

Unauthorised access;

Unauthorised disclosure;

Loss;

Misuse;

Alteration;

Destruction; and

Other unlawful or unauthorised processing.

Security measures may include access controls, authentication mechanisms, encryption or equivalent safeguards, monitoring, logging and other appropriate controls.

However, no electronic transmission, storage system or method of communication can be guaranteed to be completely secure.

Users are responsible for maintaining the confidentiality of their Account credentials and must immediately notify Real11 if they suspect unauthorised access.

18CHILDREN’S PRIVACY

Real11 Fantasy Cricket is intended only for individuals who are 18 years of age or older.

We do not knowingly permit persons below the applicable minimum age to register for or participate in Real11 Fantasy Cricket.

If we become aware that information has been collected from an individual who is not eligible to use Real11, we may take appropriate steps to restrict or terminate the relevant Account and delete or otherwise process the information in accordance with applicable law.

If you believe that an underage individual has provided information to Real11, you may contact us through the grievance or support channels specified below.

19USER RESPONSIBILITIES

Users are responsible for ensuring that information provided to Real11 is:

Accurate;

Complete;

Current; and

Not misleading.

Users must promptly update relevant information where it changes.

Users must also maintain the security of their Account credentials and must not share their Account with another person.

Real11 shall not be responsible for consequences arising from inaccurate information or Account-security failures attributable to the User, except where otherwise required by applicable law.

20USER RIGHTS

Subject to applicable law and any applicable limitations, Users may have rights relating to their personal information, which may include:

The right to access information held about them;

The right to request correction of inaccurate information;

The right to request deletion of information where legally permissible;

The right to withdraw consent where processing is based on consent;

The right to raise a grievance or complaint;

The right to request information regarding the processing of their personal information; and

Other rights available under applicable data-protection laws.

Certain requests may be subject to identity verification and legal or regulatory limitations.

Real11 may not be able to delete or provide access to certain information where retaining or restricting disclosure is required by law, necessary for fraud prevention, required for legal proceedings, or otherwise permitted under applicable law.

21HOW TO EXERCISE YOUR RIGHTS

If you wish to exercise any privacy-related right or request, you may contact Real11 through the support or grievance channels made available on the Platform.

To process a request, we may require sufficient information to verify your identity and ensure that the request relates to the relevant User Account.

We will endeavour to respond to valid requests within the time periods prescribed by applicable law.

Where we are unable to fulfil a request, we may provide an explanation to the extent required by law.

22GRIEVANCE REDRESSAL

If you have any concern, complaint or grievance relating to the collection, processing, storage or use of your personal information, you may contact the designated grievance contact of Real11 through the contact details provided on the Platform.

For faster resolution, you should include relevant information such as:

Your name;

Registered mobile number;

Registered email address;

Nature of the complaint;

Relevant Account or transaction details; and

Supporting information, where applicable.

We will make reasonable efforts to investigate and resolve privacy-related complaints in accordance with applicable law and our internal grievance-handling process.

Grievance Officer / Privacy Contact:

Name: [●]

23INTERNATIONAL DATA TRANSFERS

Real11 may use service providers or infrastructure located in jurisdictions other than the jurisdiction in which you reside.

Where User information is transferred, stored or processed outside India or another applicable jurisdiction, such processing shall be undertaken in accordance with applicable data-protection laws and any requirements relating to cross-border transfers.

Where required, appropriate contractual, technical or organisational safeguards may be implemented.

24ACCOUNT CLOSURE

Users may request closure of their Real11 Account through the applicable Account or customer-support process, subject to applicable requirements.

Closing an Account does not necessarily result in the immediate deletion of all information.

Certain information may need to be retained for:

Legal compliance;

Tax and accounting purposes;

Fraud prevention;

Security;

Dispute resolution;

Enforcement of contractual rights; or

Other legitimate or legally required purposes.

After the applicable retention period expires, information may be deleted, anonymised or securely disposed of.

25LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Real11 may contain links, integrations or references to third-party websites, applications, payment services or other external services.

This Privacy Policy does not apply to the privacy practices of such third parties.

Users should review the privacy policies and terms of the relevant third-party services before providing personal information or using those services.

Real11 is not responsible for the independent privacy practices, policies or security measures of third parties except to the extent required by applicable law.

26CHANGES TO THIS PRIVACY POLICY

We may update or modify this Privacy Policy from time to time to reflect:

Changes to Real11 services;

Changes in technology;

Changes in applicable law or regulatory requirements;

Changes in our data-processing practices; or

Other operational or business requirements.

The updated Privacy Policy will be published on the Platform with the revised “Last Updated” date.

Where required by applicable law, we may provide additional notice or obtain consent for material changes.

Your continued use of Real11 after the effective date of an updated Privacy Policy constitutes acknowledgement of the updated Privacy Policy to the extent permitted by law.

27GOVERNING LAW

This Privacy Policy shall be governed by and interpreted in accordance with the laws applicable in India, subject to any mandatory data-protection rights or protections applicable to the User based on their location.

Nothing in this Privacy Policy is intended to exclude or limit any rights or remedies that cannot legally be excluded or limited.

28CONTACT US

For questions, requests or concerns regarding this Privacy Policy or the processing of your personal information, you may contact Real11 through the customer support and privacy/grievance channels made available on the Platform.

Real11 Fantasy Cricket

Owned and operated by Orvantis Technologies

Email: [●]

29USER ACKNOWLEDGEMENT

By accessing or using Real11 Fantasy Cricket, you acknowledge that:

You have read and understood this Privacy Policy;

You understand the categories of information that may be collected and processed;

You understand the purposes for which your information may be processed;

You understand that certain information may be shared with service providers and other third parties as described in this Privacy Policy;

You understand that identity, age, location and transaction verification may be required to access certain Real11 services;

You understand that certain information may be retained where required or permitted by law; and

You agree to the processing of your information in accordance with this Privacy Policy and applicable law.