PRIVACY POLICY

PREAMBLE

This Privacy Policy ("Policy") describes how Real11 Fantasy Sports LLP ("Real11", "we", "us", or "our") collects, uses, processes, stores, retains, safeguards and discloses Personal Information relating to users and individuals who have previously accessed or interacted with Real11's website, applications, platform or related services (collectively, the "Services").

Real11 Fantasy Sports LLP has discontinued its fantasy sports contests and related money-based gaming services. Real11 does not currently operate, conduct, facilitate, promote or authorise any fantasy sports contests or online money gaming services.

The discontinuation of Real11's fantasy sports services has been undertaken in accordance with the applicable legal and regulatory framework, including the Promotion and Regulation of Online Gaming Act, 2025 ("PROGA"), as applicable. The Act extends to the whole of India and also applies to online money gaming services offered within India or operated from outside India. The Act came into force on 1 May 2026.

This Policy therefore primarily governs Personal Information that Real11 may continue to retain or process following the discontinuation of its Services, including information relating to historical accounts, transactions, customer support interactions, legal and regulatory obligations, fraud prevention, dispute resolution, audit and record-keeping requirements.

We are committed to handling Personal Information responsibly, transparently and in accordance with applicable laws. This Policy explains the categories of information that may have been collected during the period in which the Services were operational, the purposes for which such information may continue to be processed, and the rights and controls available to individuals in relation to their Personal Information.

1. YOUR CONSENT AND ACKNOWLEDGEMENT

By accessing or using the Services during the period in which they were operational, you acknowledged and agreed to the collection, use, storage, processing, safeguarding and disclosure of your Personal Information as described in the applicable privacy policy and terms governing those Services.

Following discontinuation, Real11 does not collect or process Personal Information for the purpose of providing or facilitating fantasy sports contests or related money-based gaming services.

Certain Personal Information may continue to be retained or processed where necessary for legitimate purposes, including legal and regulatory compliance, accounting, taxation, audit, fraud prevention, security, dispute resolution, enforcement of legal rights and obligations, and responding to lawful requests from competent authorities.

You are responsible for ensuring that any Personal Information provided by you to Real11 during the operation of the Services was accurate and up to date.

References in this Policy to your use of the Services refer, where applicable, to your historical use of Real11's Services prior to their discontinuation.

2. DEFINITIONS

"Personal Information"

"Personal Information" means information relating to an identifiable natural person, whether directly or indirectly, including information that may reasonably be capable of identifying an individual when combined with other information available to us.

Depending on the nature of your historical interaction with Real11, this may include:

Name
Email address
Mobile number
Date of birth
Residential or contact address
PAN or other identification information, where applicable
Government-issued identity information provided for verification
IP address
Device and browser information
Date and time of access
Account and registration information
Transaction and payment-related information
Customer support and communication records
Historical gameplay and account activity
Other information voluntarily provided by you

"Sensitive Personal Data or Information"

Where applicable under law, Sensitive Personal Data or Information ("SPDI") may include passwords, financial information and other categories of information recognised as sensitive under applicable law.

Real11 will handle such information in accordance with applicable legal requirements and appropriate security safeguards.

3. INFORMATION WE MAY HAVE COLLECTED

Real11 may have collected the following categories of information while its Services were operational.

3.1 Information Provided by You

Registration and Account Information

When you created or maintained a Real11 account, you may have provided information such as:

Name
Mobile number
Email address
Date of birth
Account credentials
Other registration or profile information

This information may be retained where necessary for historical account management, legal compliance, dispute resolution, fraud prevention or other legitimate purposes.

Identity and Verification Information

Where applicable, Real11 may have collected identity or verification information, including information from government-issued identification documents, for purposes such as age verification, identity verification, fraud prevention, compliance and account security.

Financial and Transaction Information

During the period in which Real11's Services were operational, information relating to deposits, withdrawals, payments, refunds, winnings, account balances or other transactions may have been processed through Real11 or its authorised service providers.

Such information may include transaction references, payment identifiers and limited financial information required to process or verify a transaction.

Real11 may continue to retain historical transaction records where required for accounting, taxation, audit, fraud prevention, dispute resolution, legal or regulatory purposes.

Communications Information

Real11 may retain records of communications between you and Real11, including customer support correspondence, emails, complaints, queries and other communications.

Where applicable and lawfully obtained, records of telephonic or other communications may also be retained for customer support, quality, security, dispute resolution or compliance purposes.

3.2 Information Collected Automatically

During the operation of the Services, Real11 may have automatically collected certain technical information, including:

IP address
Device ID or similar identifiers
Device type
Operating system
Browser type and version
Application version
Network information
Login and logout information
Technical diagnostics
Usage information

Such information may continue to be retained where necessary for security, fraud prevention, technical investigations, legal compliance, audit or other legitimate purposes.

3.3 Cookies and Similar Technologies

During the operation of its website and applications, Real11 may have used cookies, pixels, web beacons and similar technologies for purposes including:

Maintaining sessions
Improving website and application functionality
Understanding usage patterns
Diagnosing technical issues
Security and fraud prevention
Analytics and performance measurement

Following discontinuation of the Services, such technologies will not be used to facilitate discontinued fantasy sports contests or related money-based gaming activities.

3.4 Information Received from Third Parties

Where applicable, Real11 may have received information from authorised third-party service providers, identity verification providers, payment service providers, fraud prevention services, technology providers or other service partners.

Such information may have been used for identity verification, payment processing, account security, fraud prevention, technical support and compliance purposes.

Real11 may retain relevant historical records where required by law or for legitimate business, security, audit or dispute-resolution purposes.

3.5 Visitor and Non-Registered User Data

Real11 may have collected limited technical and usage information from individuals who visited its website or accessed its Services without creating an account.

This may have included information collected through browser logs, cookies, device information, IP addresses and similar technical mechanisms.

4. HOW WE USE YOUR INFORMATION

Following discontinuation, Real11 does not use Personal Information to provide or facilitate fantasy sports contests or related online money gaming services.

Personal Information may continue to be processed for the following purposes, where applicable and permitted by law:

4.1 Historical Account Management

To maintain, verify or manage historical account records and respond to account-related queries.

4.2 Legal and Regulatory Compliance

To comply with applicable laws, regulations, government directions, judicial orders, regulatory requirements and lawful requests from competent authorities.

4.3 Historical Transaction and Financial Records

To maintain records relating to historical transactions, payments, withdrawals, account balances, taxation, accounting and financial reporting obligations.

4.4 Fraud Prevention and Security

To detect, investigate and prevent fraud, impersonation, unauthorised access, misuse of Personal Information, security incidents and other unlawful activities.

4.5 Dispute Resolution

To investigate and resolve complaints, disputes, claims and other issues relating to historical use of the Services.

4.6 Audit and Record-Keeping

To maintain records required for statutory, accounting, taxation, audit, legal and regulatory purposes.

4.7 Legal Claims and Enforcement

To establish, exercise, defend or enforce legal rights, claims or obligations.

4.8 Law Enforcement and Government Requests

To respond to lawful requests, notices, summons, court orders, investigations or directions issued by government authorities, law enforcement agencies, regulators, courts or other competent bodies.

4.9 Security and Technical Protection

To protect Real11's systems, infrastructure, records and users from unauthorised access, fraud, malicious activity and other security threats.

4.10 Communications

Where necessary, Real11 may communicate with individuals regarding historical accounts, legal or regulatory matters, security concerns, fraud alerts, complaints, disputes or other matters relating to the discontinued Services.

Real11 does not use this provision to solicit users to participate in fantasy sports contests or related money-based gaming services that have been discontinued.

5. DISCLOSURE AND TRANSFER OF YOUR INFORMATION

Real11 does not sell or rent Personal Information.

Personal Information may be disclosed only where necessary and permitted under applicable law, including in the following circumstances:

5.1 Service Providers

Real11 may share information with third-party service providers that assist with legitimate functions such as:

Data storage
Cloud infrastructure
Security
Technical support
Customer support
Fraud prevention
Data analysis
Accounting and audit
Legal or compliance services

Such service providers may access information only to the extent reasonably required to perform their contracted functions.

5.2 Legal, Regulatory and Government Authorities

Real11 may disclose Personal Information where required or permitted by applicable law or in response to:

Court orders
Summons or notices
Government directions
Regulatory requirements
Law enforcement requests
Investigations
Judicial or quasi-judicial proceedings

5.3 Fraud and Security

Information may be shared with relevant entities where reasonably necessary to investigate fraud, impersonation, security incidents, unlawful activity or threats to Real11, its users or its systems.

5.4 Professional Advisors

Information may be disclosed to lawyers, auditors, accountants, consultants and other professional advisors where reasonably necessary for legal, accounting, taxation, compliance or business purposes.

5.5 Business Transfers

If Real11 undergoes a merger, restructuring, acquisition, sale of assets, change in control, dissolution or similar corporate transaction, Personal Information may be transferred to the relevant successor or acquiring entity, subject to applicable law.

5.6 Affiliates and Group Entities

Where applicable, information may be shared with entities associated with Real11 where reasonably necessary for legitimate legal, security, compliance, accounting, audit or corporate purposes and subject to applicable law.

6. DATA SECURITY, STORAGE AND RETENTION

6.1 Data Security

Real11 maintains reasonable technical, administrative and organisational safeguards designed to protect Personal Information against unauthorised access, misuse, alteration, disclosure, loss or destruction.

These safeguards may include access controls, authentication mechanisms, security monitoring, encryption or other appropriate security measures, depending on the nature and sensitivity of the information.

However, no method of electronic storage or transmission over the Internet can be guaranteed to be completely secure.

6.2 Data Retention

Real11 may retain Personal Information for as long as reasonably necessary for the purposes described in this Policy.

Following discontinuation, certain information may continue to be retained where necessary for:

Compliance with applicable laws and regulations
Tax and accounting requirements
Audit and financial record-keeping
Fraud prevention
Security
Dispute resolution
Legal claims
Enforcement of rights
Responding to government or law-enforcement requests

Information will be retained only for the period reasonably necessary for the applicable purpose or for the period required or permitted under applicable law.

Where Personal Information is no longer required for any lawful purpose, Real11 may delete, anonymise or otherwise dispose of such information in accordance with its applicable retention practices and legal obligations.

6.3 Data Location and Transfers

Personal Information may be stored or processed using infrastructure operated by Real11 or its authorised service providers.

Where Personal Information is transferred or processed outside India, such transfer will be undertaken subject to applicable law and regulatory requirements.

7. YOUR RIGHTS AND CONTROLS

Subject to applicable law, individuals may have certain rights in relation to their Personal Information.

These may include:

7.1 Right to Access

You may request information regarding Personal Information held by Real11, subject to applicable legal restrictions and verification requirements.

7.2 Right to Correction

Where Personal Information is inaccurate or incomplete, you may request correction or updating, subject to applicable law.

7.3 Right to Deletion

You may request deletion of Personal Information where permitted under applicable law.

Deletion may not be possible where Real11 is legally required or otherwise permitted to retain particular information for compliance, taxation, accounting, fraud prevention, dispute resolution, legal claims or other lawful purposes.

7.4 Right to Withdraw Consent

Where processing is based on consent and applicable law provides such a right, you may withdraw consent.

Withdrawal of consent will not affect processing already undertaken lawfully before such withdrawal and may be subject to legal or other lawful grounds for continued processing.

7.5 Right to Raise a Concern

You may raise privacy-related concerns through the official communication channels made available by Real11 from time to time.

Real11 may require reasonable information to verify your identity before processing requests relating to Personal Information.

8. CHILDREN'S PRIVACY

Real11's Services were intended for individuals who were at least eighteen (18) years of age.

Real11 did not knowingly intend to collect Personal Information from individuals below the applicable minimum age.

If Real11 becomes aware that Personal Information relating to a minor was collected contrary to applicable law, appropriate steps may be taken to review and address such information, including deletion where legally required or appropriate.

Parents or legal guardians who believe that a minor's Personal Information has been provided to Real11 may raise the matter through Real11's official communication channels.

9. FRAUDULENT COMMUNICATIONS AND IMPERSONATION

Real11 has discontinued its fantasy sports contests and related money-based gaming services.

Accordingly, any person, website, application, social media account or other platform currently claiming to offer fantasy sports contests, online money gaming services, deposits, withdrawals, winnings or similar services in the name of Real11 should be treated with caution unless independently verified through an official Real11 communication channel.

Real11 does not authorise unauthorised individuals or entities to:

Offer fantasy sports contests in the name of Real11
Collect deposits or payments on behalf of Real11
Promise winnings or returns
Offer bonuses or promotional rewards in the name of Real11
Request OTPs, passwords, PINs or banking credentials
Request remote access to a user's device
Ask users to install unknown applications
Request sensitive financial or identity information through unauthorised channels

If you receive a suspicious communication claiming to represent Real11:

Do not make any payment.
Do not share your OTP, PIN, password or banking credentials.
Do not click suspicious links.
Do not install applications at the request of unknown persons.
Do not provide remote access to your device.
Preserve relevant screenshots or other evidence where appropriate.
Verify the communication through an official Real11 channel.

Real11 shall not be responsible for transactions, communications, representations or losses arising from unauthorised persons or entities falsely claiming to represent Real11, except to the extent liability cannot lawfully be excluded.

Real11 reserves the right to investigate suspected impersonation, fraud or misuse of its name and to cooperate with relevant authorities where appropriate.

10. THIRD-PARTY WEBSITES AND SERVICES

Real11's website or historical Services may have contained links to websites, applications or services operated by third parties.

Real11 does not control the privacy practices, security practices or content of third-party websites or services.

Users should review the privacy policies and terms applicable to any third-party website or service before providing Personal Information.

The inclusion of a third-party link does not constitute an endorsement, representation or guarantee by Real11 regarding that third party's practices.

11. LEGAL AND MISCELLANEOUS

11.1 Limitation of Liability

Real11 takes reasonable measures to safeguard Personal Information. However, no system or method of electronic transmission or storage can be guaranteed to be completely secure.

To the maximum extent permitted by applicable law, Real11, its affiliates, directors, officers, employees and service providers shall not be liable for indirect, incidental, consequential, special or punitive losses arising from unauthorised access, security incidents or third-party acts, except where such liability cannot lawfully be excluded or limited.

Nothing in this Policy is intended to exclude or restrict any liability that cannot be excluded or restricted under applicable law.

11.2 Changes to This Policy

Real11 may update or amend this Policy from time to time to reflect changes in applicable law, regulatory requirements, business practices, security measures or data-processing practices.

Any updated version will be published through the appropriate official Real11 communication channel, together with the revised effective or updated date.

11.3 Severability

If any provision of this Policy is found to be invalid, unlawful or unenforceable by a competent court or authority, such provision shall be interpreted or modified to the maximum extent permitted by applicable law, and the remaining provisions shall continue to remain in effect.

11.4 No Revival of Discontinued Services

Nothing in this Policy should be interpreted as an offer, invitation or representation that Real11 currently operates or intends to operate fantasy sports contests or online money gaming services.

Real11's references to historical accounts, transactions, gameplay or Services are solely for privacy, legal, compliance, security, record-keeping and related purposes.

12. IMPORTANT NOTICE

Real11 Fantasy Sports LLP has discontinued its fantasy sports contests and related money-based gaming services.

Real11 does not currently operate, conduct, facilitate, promote or authorise fantasy sports activity or related money-based gaming services on the web, through applications or through any other platform.

Any website, application, social media account, individual or entity claiming to currently offer such services in the name of Real11 should not be assumed to be affiliated with or authorised by Real11.

Users should exercise caution and should not make payments or disclose personal, financial, identity or security information to unauthorised persons claiming to represent Real11.

Please rely only on communications issued through official Real11 channels.