Legality

Stump11, a premier online fantasy cricket platform, allows users to create virtual cricket teams composed of real-life players. These are available on the Stump11.com web portal as well as partner websites and mobile applications (collectively referred to as the "Portal"). The portal is run in India by Sporta Technologies Private Limited. Hereinafter, Sporta Technologies Private Limited will be referred to as " Stump11," "we," "us," or "our."


The provisions of this privacy policy ("Privacy Policy") apply to anybody using the Portal ("User" or "you" or "your") and any of its features, such as taking part in the different competitions and games (including fantasy games) ("Game") ("Services") offered on the Portal.


By accessing, registering, or using the Stump11 platform, you acknowledge and agree to the terms and conditions set forth in this Privacy Policy. This Policy applies to all users of stump11, including without limitation individuals who are browsers, vendors, customers, merchants, and contributors of content. It is vital that you read this Policy in conjunction with our Terms of Service, as your use of the Stump11 platform constitutes an unequivocal agreement to be bound by both documents. We are committed to protecting your personal information and recognise the value of privacy. To that end, we strictly follow the privacy practices described in the following paragraphs.


By providing us with your personal information, you grant Stump11 explicit consent to process your data as outlined in this Policy. This consent is active from the moment you submit your information and continues throughout your use of our services. You acknowledge that the provision of your personal data is voluntary. However, please be aware that certain services provided by Stump11 may be contingent upon the availability of your personal information.


Stump11 reserves the right to modify this Privacy Policy at any time, and such modifications will be effective immediately upon posting the revised Policy on the platform. You agree to periodically review this Privacy Policy to be aware of such modifications. By continuing to use the Stump11 services after any modifications, you accept and agree to the modified terms.


You are accessing our platform from outside the jurisdiction in which Stump11 operates, please be aware that the information we collect will be processed and stored in our servers located in the jurisdiction of operation. By using our services, you consent to the transfer of information to these servers and acknowledge that the data protection laws of the jurisdiction in which our servers are located may differ from those in your own country.


Stump11 welcomes players from India, except for those residing in Andhra Pradesh, Assam, Nagaland, Sikkim, and Telangana. We apologize, but if you attempt to access our website from any of these states or from outside India, you will be unable to add cash or participate in cash tournaments.

Information We Collect


Comprehensive Data Collection:


Stump11 is committed to providing an unparalleled online fantasy cricket experience, which necessitates the meticulous collection and processing of personal information. This commitment is in strict adherence to the Information Technology Act, 2000, particularly under sections related to the handling and protection of sensitive personal data or information.


Types of Information Collected:


Our platform is designed to collect a spectrum of personal information critical to facilitating and enhancing your engagement with our services. This includes, but is not limited to:


1. Identification and Contact Information: As a fundamental aspect of our service, we collect personal identifiers such as your name, address, email address and contact number. We may also require to collect Government identification documents like Permanent Account Number (PAN), Aadhaar Card, Voter ID etc. where ever required, by Law, to proceed further. This information is pivotal for creating your user profile and ensuring effective communication.


2. Demographic and Behavioural Data: To tailor our services to your preferences, we gather demographic information including age, gender, and location. Additionally, we analyze user engagement data, such as contest selections and interaction patterns, to continuously improve our offerings.


3. Financial Information for Transaction Processing: In compliance with the Reserve Bank of India's guidelines, we collect financial details necessary for processing transactions within the platform. This includes but is not limited to bank account information and credit/debit card details, ensuring smooth and secure financial transactions as per the Payment and Settlement Systems Act, 2007.


4. Technical Data for Service Optimization: We collect technical information related to the devices you use, and your interaction with our platform. This includes IP addresses and device specifications, operating system information, network information which are essential for providing a secure and optimized user experience.


In certain instances, where we are collecting sensitive personal information (“SPI” – Like financial Information or identifications documents) from you on the Portal, these shall not be disclosed to any third-party service provider without your express consent, save as otherwise set out in this Privacy Policy or as provided in a separate written agreement between Stupms11 and you or as required by law. It is clarified that this condition shall not apply to publicly available information, including SPI, in relation to you on the Portal.


Purpose and Method of Data Collection:


Our data collection methods are multifaceted, encompassing direct user inputs, automated technologies like cookies, and, where necessary, data obtained from third parties. The primary objectives for collecting this information are:


• To provide and manage the fantasy cricket contests and other related services you engage with on our platform.

• To enhance user experience through personalized services.

• To provide you with updates on our services and products, as well as those of our group companies and affiliates, and to allow them to         contact you regarding the goods and services they have to offer.

• To ensure a secure environment on our platform, including the prevention of fraud and misuse.

• To fulfill our legal and regulatory obligations, particularly under Indian law, ensuring compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.


In accordance with the principles of the Information Technology Act, 2000, and other relevant Indian data protection laws, users retain significant control over their personal information. You are entitled to access, review, correct, or delete your personal data that we hold. Furthermore, our platform allows you the right to object to certain uses of your data and to seek restrictions on its processing.

Stump11 maintains a stringent data retention policy, ensuring that personal information is not held longer than necessary and is disposed of securely once its purpose has been served, in line with legal and regulatory requirements.


Utilization of Personal Information:


Stump11, in its operation as an online fantasy cricket platform, adheres to the stringent guidelines set forth by Indian laws, including the Information Technology Act, 2000 and its associated rules, particularly those concerning the use of personal digital information. The utilization of personal data collected from our users is conducted with utmost transparency and purpose, ensuring both compliance with legal mandates and enhancement of user experience.


Key Areas of Data Utilization:


Our utilization of your personal information encompasses several critical areas, each aligned with our goal of providing a seamless and engaging fantasy cricket experience, as well as our legal obligations:


Service Delivery: Foremost, your personal information is employed to facilitate the core functionalities of the Stump11 platform. This includes but is not limited to account registration, team creation and management, contest participation, and transaction processing. These activities are essential to fulfilling the contractual obligations between Stump11 and its users.


1. User Experience Personalization and Improvement: We analyze demographic and behavioural data to tailor our services to your preferences, ensuring a more engaging and personalized experience. This includes the development of new features, enhancement of existing services, and customization of content and recommendations.


2. Communication and Marketing: In line with the legal allowances under the Information Technology (Guidelines for Intermediaries and Digital Media Ethics Code) Rules, 2021, we use your contact information to send updates, promotional offers, and other relevant communications. These communications are designed to keep you informed about new opportunities, features, and developments on our platform.


3. Security and Fraud Prevention: Protecting the integrity of our platform is paramount. Your data is crucial in helping us identify and prevent unauthorized access, fraud, and other malicious activities. This aligns with our obligation to ensure a secure online environment, as mandated under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.


4. Legal and Regulatory Compliance: Stump11 is committed to upholding its legal responsibilities. We may use your information in compliance with legal requirements, including responding to lawful requests from regulatory bodies or law enforcement agencies and other applicable laws.



Consent and User Control:


Your consent to the use of your personal information for these purposes is deemed given upon your acceptance of our Privacy Policy and continued use of our services. We provide you with options to control the use of your data, including opting out of marketing communications and modifying your privacy settings. Our platform ensures that these rights are easily accessible and executable by all users, in accordance with the rules and regulations laid down in the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.


While offering the Services, Users may utilise any social media platform, such as Facebook, Instagram, WhatsApp, and others, to invite other users or current Users ("Invited Users") to take part in any of the Services. After that, we might utilise this information to get in touch with the invited user, extend an invitation to sign up with Stump11 (if the invited user isn't already registered) and get involved in the game that you invited them to. The rules of this privacy policy and the terms and conditions for using the portal will apply to the Invited User's participation. By using this representation, you acknowledge that the Invited Users have given their permission for us, our affiliates, and/or our group businesses to share their information.


Disclosure of Information:


Stump11 acknowledges the importance of safeguarding your sensitive personal information (SPI), including financial details and other confidential data. In compliance with the Information Technology Act, 2000, and other relevant Indian laws, we disclose your information only under stringent conditions. Our sharing of data is primarily with trusted third-party service providers and business affiliates, necessary for enhancing our platform's functionality and service delivery. In the event of a merger, acquisition, reorganization, bankruptcy, or sale of company assets, personal information may be part of the transferred assets. This information is shared under strict confidentiality agreements, ensuring compliance with data protection standards. Additionally, in situations necessitating legal compliance or in response to lawful government requests, we may disclose necessary user information, always prioritizing user privacy and legal obligations.


User Rights and Control:


In alignment with best industry practices, Stump11 empowers you with comprehensive control over your personal information. You have the right to access, modify, or request deletion of your data from our platform. Additionally, we offer options for account suspension or temporary deactivation, allowing you to manage your presence on our platform effectively. These requests can be made through our dedicated support channels. We also commit to a transparent process of handling such requests, ensuring that any changes to your data or account status are processed in a timely and secure manner, in accordance with relevant Indian laws and regulations.


Data Security and Breach Response:


We rigorously enforce comprehensive data security protocols, closely aligned with the best practices recommended under the Information Technology Act, 2000. Our approach includes the deployment of state-of-the-art encryption and sophisticated firewall systems, meticulously designed to protect against unauthorized access and data breaches. In the event of a security incident, we adhere to a stringent breach response protocol. This protocol involves immediate action to contain and assess the situation, notification to impacted users, and relevant authorities as mandated by law, and implementation of

corrective measures to prevent future occurrences. Our commitment extends to continuous evaluation and enhancement of our security infrastructure, ensuring resilience against evolving cyber threats.


Data Retention Policy:


Our Data Retention Policy is meticulously crafted to ensure compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. We retain personal data only as long as necessary for the purposes outlined in our Privacy Policy, or as mandated by legal and regulatory requirements. Following the expiration of this period, we engage in a secure data deletion process, where data is either irreversibly anonymized or permanently erased, ensuring that it is beyond recovery. This process is integral to our commitment to protect user privacy, maintaining the integrity of personal data while adhering to our legal obligations for data retention and disposal.


Children's Privacy:


We are dedicated to protecting the privacy of children. Our platform does not knowingly collect, use, or disclose personal information from children under the age of 18. We implement age verification measures to prevent underage (below the age of 18) users from accessing our services. If we become aware that we have inadvertently collected personal data from a child under 18, we will take immediate steps to delete such information from our records. Our commitment to children's privacy ensures a safe and responsible online environment for all users.


Amendments in Policy:


We reserve the right to amend this policy in response to evolving legal requirements or changes to our business practices. Users will be duly informed of any significant changes to our data handling policies. Continued use of our services post-notification of such changes will be deemed as your acceptance of these revised terms.

By utilizing the our platform, you explicitly consent to the collection, use, and sharing of your information as outlined in this detailed policy, reaffirming our commitment to upholding the highest standards of data privacy as mandated by Indian law.

We reserve the right to amend this policy as required to remain compliant with changes in law or to better serve our users. All amendments will be communicated to users through appropriate channels, and continued use of our services following such modifications will constitute acceptance of the new terms.