PRIVACY POLICY

This policy discusses in detail how the information that we collect from the Users is used by STUPA and how we intend to protect this information in accordance with or beyond any Regulations applicable in relation to your privacy protection.

At STUPA, we carry out an in depth analysis to help in performance enhancement of the Users. Since the STUPA Application (hereinafter “the App”) is an interactive platform, we will ask for certain information to help us perform our services. We, at STUPA, honour the privacy concerns of our Users and should we ask you to provide certain information when utilizing the App, You can be guaranteed that it may be utilized as per this Privacy Policy.

 It is advisable to read this policy with utmost attention along with our End User License Agreement.  By using the App, you agree that we may collect and use your information in accordance with this policy. If you do not want STUPA to collect, store, process, use or share your information in the ways described in this privacy policy, we suggest that you stop using the App immediately.

WHAT IS A PRIVACY POLICY ?

At the outset, it is important to clarify what exactly is a privacy policy. A privacy policy is a statement contained on a website or an application that details how we being the operator of the site will collect, store, protect, and utilize personal data provided by its users. The basic aim of this Policy is to enable you to understand how your privacy is protected by our business practices.

WHAT TYPES OF INFORMATION DO WE COLLECT?

In order to give you the best possible experience, we collect data from your interactions with our network. Some of this information would be actively provided by you (for example, your name, email address, contact information, videos you voluntarily upload etc.) while other information may be collected based on your interactions with the App.

All the information that You provide to us, You agree that we may process such information for not only analyzing and enhancing your game but also for the operation and enhancement of the App.

We collect the following information from you:

1. INFORMATION DIRECTLY PROVIDED BY YOU:

• Personal information: This includes the information required to create an account on our App like your name, gender, date of birth, location, e-mail address and your communication details, the city that You live in, your game preferences etc.
• Login Credentials: We save the information that You use every time You log into the App, that is, your username and password.
• Contact information: We shall ask for your phone number and other communication details and it will be used by us for the purpose of verification.  
• Communication with STUPA: We keep a record of your interactions with our Executives including a record of any complaints we receive by or against you or pertaining to you, your game and the material you upload in STUPA App. We may track your IP address as well as the information you send to us to help resolve your query or to assist You in the desired manner.
• Content: We shall also make use of and process the content that you have send us, or you otherwise create, publish and share with us. This content would include the photos, videos, and other materials that you share with the App for performance analysis. You give us the permission to access information that you share about or owned by any third party and You hereby confirm that You have the third party’s clear and tacit consent in sharing such information.  
• Additional Information: We shall preserve any additional information that you may provide us.
• Payment Details: Your payment information shall be retained by us if you purchase any of our premium services.  
• ‘Confirmation: You confirm that you are an adult and capable of entering into a contractual relationship on behalf of yourself or your minor ward on whose behalf you have logged in to use our STUPA App.

By using the App, You agree to provide accurate, current, and complete information about yourself on the App and to promptly update this information to maintain its accuracy. 

2. DEVICE INFORMATION:

• We may collect certain information about your mobile phone or other device that you use to access the App, including IP address, device signals, network and connections, geolocation information, unique device identifiers, browser type, browser language, and other transactional information. We may also access the data from cookies stored on your device.
• We may also use the data from your device based on the device settings that you choose (for example, we may access your GPS location, camera or photos). If you do not enable the location based services on your device then we will not be able to collect location based information from you.

3. USAGE INFORMATION

We gather information about how you use the App, the features that you use and the actions that You take. We keep a record of your interactions with other Users as well as the time span of your activities on the App.

4. INFORMATION BY USERS

We may also receive and have access to information that others may share about You on the App. We analyse and collect data, content, and communications that other Users provide when they use our services. This may include information about You that other Users share when they import/sync your contact details, or post photos, videos or comments about You on the App.

5. THIRD PARTY DATA PROVIDERS

We may also access and use information provided about you provided by third-party data providers including websites, our affiliate partners and public databases.  This helps us to supplement the information contained in our database and to better understand and customize your experience with the App.

6. SOCIAL MEDIA LOGIN: You may be able to use your social media login (such as Facebook Login or Google Accounts) to create and log into your STUPA account. By doing so, you allow us to access information related to your social media account.

HOW DO WE USE THE INFORMATION?

We utilize the data we collect about You to:

• Operate and improve the App
• Assist us with customizing and consistently improving your experience with the App
• Assist with your requests, complaints and enquiries
• Manage and run your account on the App
• Track your behaviour and usage of the App to improve the App
• Detect, investigate, and prevent activities that may violate our policies or be illegal
• Carry out actions for which we have obtained your prior consent
• Select and personalise advertisements, offers and other sponsored content that we show on the App
• Record your interactions with the App
• Communicate and inform You about new offerings, services and updates
• Conduct product research and development
• Administer contests, sweepstakes, promotions, and surveys.

You Authorise us to use the information provided by you for the following purposes:

• For processing of information, we may avail the services of any third party and you agree that we may do so for the purposes indicated in this policy. All such parties shall be bound contractually to protect your data in accordance with this Policy.
• You allow us to disclose your personal data to public authorities if requested or in connection with improper use or possible legal action in Court or otherwise.
• We may use your information and process it only for those purposes for which we have expressly received your consent.
• We may also ask you to provide information that is not stated in this policy, in accordance with law.

WHAT HAPPENS IF YOU DO NOT PROVIDE US CERTAIN INFORMATION?

In case you do not provide us with certain information, it will not be possible for us to provide you our services.

For example, if we do not get access to your phone’s photo gallery or camera, we will not be able to upload your photographs or videos on the App.

FOR HOW LONG WILL THE DATA BE RETAINED?

We retain the data on the basis of the purpose for which it is used. But there are certain limitations that we follow to protect your privacy:

• We hold your information for the time period required to carry out the activities mentioned in this Policy
• We retain your information as long as we have a valid reason or Regulatory requirement to keep it
• Our services are designed in a manner that does not require us to hold any information longer than what is necessary
• We also consider the type of information collected, the amount of information collected, sensitivity of the information, legal requirements (if any) when we decide the time period for which the information shall be retained by us.
• Your personal Information shall be deleted when you delete your Account on the App. However, your certain Information comprising of your photos and videos of your game may be retained for a few months following account deletion.

CAN WE DISCLOSE YOUR PERSONAL INFORMATION AT ANY TIME?

We may have to disclose your personal information in certain situations which have been detailed as below:

• We provide general demographic and interest information to Marketing and Advertising Teams or third persons for creating marketing materials, customised ads, offers and services.
• We use and share the Information and Analytics obtained from such Information for the purposes of sharing the efficacy of our App.
• In case we merge, amalgamate, dissolve, restructure or reorganise STUPA with any entity, your personal information will form a part of the assets transferred.
• Vendors and Service Providers who enable us to operate the App, and help us in restructuring, improving the App and its experience by any or all users.
• Subsidiaries and Affiliates of STUPA
• For the purposes required by law or for law enforcement
• We may share your information with third parties with your prior consent.

DO YOU HAVE ANY CONTROL OVER SHARING OF INFORMATION?

You can control the amount and kind of information that you share with us in the following ways:

• You can change the settings of your software and your device as per your preference.
• You can change the setting of your Account on the App to control who all can view the information shared by you on the App.
• You also have the option of changing your device settings including the permission to access device data. However, if you choose to do so, we might not be able to provide certain services to you.
• We suggest that you act cautiously while sharing sensitive information like your address, personal details, credit card information and so on which may be open to abuse by others.
• You additionally have the option of deleting your account. Information assortment of all types can be halted totally by uninstalling the App.

WHAT ARE YOUR RIGHTS?

The ultimate control of your information is in your hands and we strive to respect your rights at all times. You have the following rights over the information that you provide us:

• You can request for a copy of your information
• You can ask us to correct information which is wrong, to delete it or to request that we only use it for certain purposes
• You can ask us to stop using your information for certain purposes. For example, unsubscribing from any marketing emails.

 You can ask for review and rectification of your information in the following manner;

• You can direct your query to us at info@stupaanalytics.com and we shall respond to your request within a period of thirty (30) days from the date of the request.
•  You can update or change your Account information by editing your profile on the App or by contacting support@stupaanalytics.com for more detailed instructions.

• To make a request to have personal information maintained by us returned to You or removed, please email support@stupaanalytics.com. Requests to access, change, or remove your information will be handled within thirty (30) days.

CHANGES TO THIS POLICY

We reserve the right to make changes to this Policy from time to time, and any such changes shall be duly updated and posted on this page. You should continue to update yourself about this Policy as it be updated or changed.

DISCLAIMER

We can't guarantee fool-proof security of your personal information. The very nature of the internet is such that the data travels through a loose constellation of networks making it extremely difficult, if not impossible to regulate. In a world-wide chain of data exchange, there is likelihood that weak links may be present. It would not be practically possible to secure every computer connected to the Internet around the world. Therefore, You agree and acknowledge that that there are risks associated with using Internet-based identity services, including, but not limited to, the risk of failure of hardware, software, and Internet connections of malicious software introduction, and the risk that third parties may obtain unauthorized access to information stored in your account and on the block chain. You also acknowledge that STUPA shall not be liable or responsible for any loss or damage caused due to the risks of data loss, server failure, and unauthorized third party activities including viruses, phishing, or other means of attack.

YOU NOTE THAT STUPA DOES NOT ASK FOR SENSITIVE INFORMATION LIKE CREDIT OR DEBIT CARD DETAILS, MEDICAL CONDITIONS AND REPORTS, INFORMATION ABOUT BIOMETRICS OR BANK ACCOUNT DETAILS. IT IS STRONGLY RECOMMENDED THAT YOU EXERCISE PRUDENCE WHILE SHARING INFORMATION ON THE APP.

QUESTIONS AND COMPLAINTS

In case of any queries, you can write to us at: support@stupaanalytics.com and we will try to handle your request as soon as possible.

EFFECTIVE DATE:

This Policy was last updated on 1stMarch, 2021