Privacy Policy

Your Privacy is of utmost importance to us and the protection of your Personal Data is a key commitment for us.

This privacy policy forms part of our Website's Terms of Service, by accepting the Terms of Service and the Privacy Policy on the registration page, you consent to provide sensitive personal data or personal information and are aware of the purpose of sharing such information. The following policy applies to your use of First Game’s website and/or Services, and covers information collected in connection with your access to and use of our website and/or Services. Please read this Privacy Policy carefully.

We collect and generate various data points about you. Data by which you are identified is termed as “Personal Data”. Personal Data does not mean information that is freely available or accessible in the public domain. We are governed by the provisions of applicable law in India including the Information Technology Act 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 to maintain the privacy of your Personal Data.

1. Personal Data
   The Personal Data we may collect from you are as under:
   1. Personal details (e.g. name, contact details including, residential address, date of birth, documents such as identity card/passport details/PAN/Voter ID/driving license, and/or education details) provided by you to us to avail various products/services from us;
   2. Your details including transaction history, balances, payment details for effecting the transfer of monies through various payment channels provided by us;
   3. Financial details (e.g. income, expenses, and/or credit history) as part of a request for some of our products/ services;
   4. Images of documents/ photos required to avail any of our products/services;
   5. Voice recordings of conversations with our customer care agents to address your queries/grievances;
   6. Employment details (e.g. occupation, positions held, employment history, salary and/or benefits) as part of our record retention for credit/ various product evaluations required under applicable law including Prevention of Money Laundering (Maintenance of Records) Rules, 2005;
   7. Specimen signature(s) for processing of your instructions received by us through our various payment and delivery channels;
   8. Opinions provided by you to us by way of feedback or responses to surveys;
   9. Information obtained from your mobile device by way of using our app like device location, communication information including contacts and call logs, device information (including storage, model, mobile network), transactional and promotional SMS/app notifications.
2. Sharing of your Personal Data
   

   Any Personal Data that we have access to shall never be shared without your consent.

   In various processes/submission of applications/ availing of product/ service offerings, we even seek your explicit consent to use/ share your Personal Data.

   In our business and operational processes, we only share the data on a partial and “need-to-know” basis to designated personnel or partners or service providers.

   We will share your data with competent/ legal/ statutory/ regulatory agencies/ authorities or partners/ service providers acting on our behalf (as the case may be) in the following cases:

   1. Only for enabling the provision of the products/ services availed by you, strictly on a “need to know” basis and subject to applicable laws.
   2. It is directed or required by legal/ regulatory/ statutory/ governmental authorities under applicable laws/regulations though a legally obligated request.
   3. It is required by financial institutions to verify, mitigate or prevent fraud or to manage risk or recover funds in accordance with applicable laws/regulations.
3. Usage of Your Personal Data
   We use your Personal Data in our business activities for providing our or our partners’ products/ services and to perform, among other actions, the following:
   1. to facilitate the transactions or report on these transactions;
   2. to undertake research and analytics for offering or improving our products/ services and their security and service quality;
   3. to check and process your requirements submitted to us for products/ services and/or instructions or requests received from you in respect of these products/ services;
   4. to share with you the updates on changes to the products/ services and their terms and conditions;
   5. to take up or investigate any complaints/ claims/ disputes;
   6. to respond to your queries or feedback submitted by you;
   7. to verify your identity for us to provide products/ services to you;
   8. to carry credit checks, screenings or due diligence checks as lawfully required by us;
   9. to monitor and review products/ services from time to time;
   10. to undertake financial/ regulatory/ management reporting, and create and maintain various risk management models;
   11. for conducting audits and for record-keeping purposes;
   12. for selective offers and promotions.
4. External Processing:
   We also use your Personal Data to fulfil the requirements of applicable laws/ regulations and / or court orders/ regulatory directives received by us. If you click on content from third party advertisers and content owners, based on your acceptance criteria provided to them, they may collect some information from you while you play their games or are redirected to their site. Some examples of usage by them are:
   1. monitor, evaluate, and optimize your game experience and operation of the games;
   2. provide useful features to simplify your experience when you return to our sites and applications etc.
5. Updating / Purging of your Personal Data
   1. You shall be entitled to update the information provided by you by contacting us at [email protected]. Your personal data shall be updated subject to reasonable checks and validation done by First Games.
   2. Users on First Games Platform entitled to withdraw consent for use of their Sensitive Personal Data or Other Personal Information by emailing a specific request to [email protected]. Withdrawal of consent of all or any part of Sensitive Personal Data and Other Personal Information may result in immediate withdrawal of any right to avail the services provided by First Games.
   3. You may delete your First Games account at any point in time by making such a choice in desktop website, mobile WAP site or mobile application. With this, we will no longer share your data with any new partners. However, we retain your Personal Data as long as the purpose for its usage exists, after which the same is disposed of by us except for any record retention required as per applicable law.
   4. The provisions of various laws require your transaction logs to be stored for longer periods post the deletion of an account. Further, in the event of the pendency of any legal/ regulatory proceeding or receipt of any legal and/ or regulatory direction to that effect, we may be required by the law of the land to retain your Personal Data for longer periods.
6. Cookie Policy
   1. Please note that a "cookie" is a small piece of information stored by a web server on a web browser so it can be later read back from that browser.
   2. We may use cookies and tracking technology depending on the features offered.
   3. No Personal Data will be collected via cookies and other tracking technology; however, if you previously provided Personal Data, cookies may be tied to such information.
7. Links to other websites

   Our website may contain links to other websites which are not maintained by us. This privacy policy only applies to us. You are requested to read the other websites’ privacy policies when visiting these websites.

8. Reasonable Security Practices and Procedures

   We take various steps and measures to protect the security of your Personal Data from misuse, loss, unauthorized access, modification or disclosure. We use the latest secure server layers encryption and access control on our systems. Our safety and security processes are audited by a third-party cybersecurity audit agency from time to time.

   We have provided multiple levels of security to safeguard your app by Login/ Logout option and AppLock feature that can be enabled by you. We also ensure device binding so that the same login cannot be used on a different device without any additional authentication/ OTP. Please do not share your account login, password and OTP details with anybody.

9. SECURITY
   

   The security of the information we collect is important to Us and hence we will follow generally accepted industry standards to protect this information. You should understand that there is no such thing as complete security, and all information gathered by us shall be maintained in secure manner. However, we do not guarantee that there will be no unintended disclosures. Due to constant technological development we shall endeavour to provide you with uninterrupted and continuous use of your account, and for which we might need to take assistance from our subsidiaries, affiliates, and other third parties. If you become aware that Your Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify as soon as reasonably possible and as permitted by law

10. Restriction of Liability
    
    1. We make no claims, promises or guarantees about the accuracy, completeness, or adequacy of the contents available through the App and expressly disclaims liability for errors and omissions in the contents available through the App.
    2. No warranty of any kind, implied, expressed or statutory, including but not limited to the warranties of non-infringement of third party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus, is given with respect to the contents available through the App or its links to other internet resources as may be available to Your through the App.
    3. Reference in the App to any specific commercial products, processes, or services, or the use of any trade, firm or corporation name is for the information and convenience of the public, and does not constitute endorsement, recommendation, or favoring by PFG.
11. Contact us

    You may contact us on any aspect of this policy or for any grievances with respect to your Personal Data by writing to our Grievance Officer at [email protected].

    If You have questions or concerns, feel free to email Us or to correspond at [email protected] and We will attempt to address Your concerns.

12. Policy Review & Updates

    This policy will be reviewed by us as and when required and the same may change at any time. The latest & most updated policy can always be found at privacy-policy

    While we will make reasonable efforts to keep you posted on any updates to this privacy policy. To make sure that you are aware of any changes, we recommend that you review this policy periodically.

    This Privacy Policy shall apply uniformly to First Games desktop website, mobile WAP site & mobile applications (“App”)

    All services are rendered by us through “First Games Platform” which included First Games website named https://paytmfirstgames.com/ or at https://firstgamesapp.com/ and/ or Paytm Mobile application run by Paytm First Games Private Limited (“PFG”) under the brand name “First Games”.

    In this policy, the words “we”, “ours” and/or “us” refer to First Games and “you” and/or “your” refer to our customers.