Privacy Policy

1. Introduction

1.1. This Privacy Policy (“Policy”) explains how Indibid Private Limited(“Provider”, “we”, “us”, “our”) collects, stores, uses, discloses and protects your personal data when you access or use the free-to-play, skill-based Game(s) (as defined in the T&C) offered via www.indibid.in and the INDIBID mobile application (the“Platform”). The Platform is currently offered to Users in Great Britain(England, Wales, Scotland) and is not available in Northern Ireland, the Channel Islands or the Isle of Man.
1.2. This Policy should be read with our Terms & Conditions (“T&C”). Capitalised terms not defined here have the meanings in the T&C.

2. Legal Effect

Your use of the Platform signifies your acceptance of this Policy and the T&C. We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018). Nothing in this Policy limits your statutory rights. If you do not agree, please do not use the Platform.

3. Collection Of Personal Data And Purpose

3.1. “Personal Data” in this Policy means information relating to an identified or identifiable natural person and includes the data in Clauses 3.2 and 3.3 (as applicable).
3.2. We collect the following account, usage and device data during use of the Game(s) and Platform (tailored for free-to-play):

(a) Name
(b) Mobile number (optional; used only for personalization)
(c) User ID/username
(d) Gender(if you choose to provide it)
(e) Full address and GB nation (if you choose to provide it for delivery of any non-monetary rewards or customer support)
(f) Email address (if you choose to provide it or sign in with email)
(g) Date of birth (if you choose to provide it or where required to confirm 18+ eligibility)
(h) Profile picture (if you choose to provide it)
(i) Gameplay statistics, scores, achievements, and leaderboard positions (no cash winnings apply in GB free-to-play)
(j) UserAccount activity related to free features and non-monetary rewards (no paid“Indibid Credits” at UK launch)
(k) User-generated content and communications (e.g., in-app messages to support)
(l) Technical and analytics data such as IP address, device identifiers, OS, browser type,referring/exit pages, pages or screens viewed, and cookie/SDK identifiers
(m) General location (e.g., IP-based region) and time zone
(n) Other data generated by your use of the Platform or that you voluntarily provide
(o) Evidence reasonably requested to verify your eligibility (e.g., 18+ and GB location)

3.3. Special category or sensitive data: We do not seek to collect special category data (e.g., health, biometrics). As the GB app is free-to-play,we do not collect payment card data for entry/deposit. If, in future,you make optional cosmetic purchases, limited payment data may be processed by our payment providers (controller/processor roles and notices will be provided then).
3.4. Purposes& lawful bases (UK GDPR): we use Personal Data to:

(a) Create and manage your account; provide and maintain the Platform and Game(s); ensure eligibility (18+, GB) (contract/legitimate interests)
(b) Ensure safety, integrity and fair play; detect/prevent fraud, abuse, bots and exploits (legitimate interests)
(c) Provide customer support and service communications (contract/legitimate interests)
(d) Perform analytics, quality, debugging, and improvement of features (legitimate interests)
(e) Run non-monetary promotions/leaderboards and display results, where applicable (contract/legitimate interests)
(f) Comply with law, handle requests from regulators or authorities, and exercise/defend legal claims (legal obligation/legitimate interests)
(g) Send marketing communications only where permitted (e.g., with your consent or soft-opt-in where applicable) with opt-out options (consent/legitimate interests)

3.5. Processors and service providers. We use trusted third parties for hosting, analytics, security/anti-abuse, content moderation, customer support, and (if introduced) delivery of any physical non-monetary rewards. These providers act under contracts consistent with UK GDPR.
3.6. Choice. If you decline to provide data that is necessary to create an account, verify eligibility (18+ and GB), or deliver core features, you may be unable to use the Platform.

4. Use, Sharing and Disclosure of Personal Data

4.1. We may share Personal Data with:

(a) Delivery/fulfilment partners (only if a physical non-monetary reward is offered) — name, delivery address,contact details
(b) Geo-IP/ geo location providers to enforce GB-only access and restrict access from excluded regions (NI, Channel Islands, Isle of Man)
(c) Payment providers(only if optional cosmetic purchases are introduced later)
(d) Analytics and security vendors(anti-abuse, bot detection, crash/diagnostics)
(e) Aggregated/anonymous statistics for insights and service improvement (no re-identification)
(f) Insurers or legal advisors if reasonably necessary to manage a claim or legal risk

4.2. We may disclose Personal Data: to comply with a legal obligation, regulator or court order; to protect the rights, property or safety of the Provider, Users or the public; to enforce the Policy and T&C; to investigate suspected unlawful activity (e.g.,fraud/abuse).
4.3. We may share Personal Data with our affiliates and successors (e.g.,in connection with a corporate transaction), subject to this Policy and UK GDPR safeguards.
4.4. We share Personal Data with our staff and professional advisers (lawyers,accountants) on a need-to-know basis under confidentiality obligations.
4.5. Use of names/scores/UGC for platform features: We may host, display and publish your username, avatar, gameplay statistics and leaderboard positions within the Platform, and use limited excerpts of UGC for in-app community displays or to announce competition results. For any marketing outside the Platform, we will rely on legitimate interests or consent (with opt-out/withdrawal options). This aligns with the CAP Code’s transparency requirements for announcing winners where applicable.
4.6. Content you post in publicly accessible areas (e.g., leaderboards or community spaces, if enabled) may be visible to other Users or internet users.
4.7. International transfers:If we transfer Personal Data outside the UK (e.g., to a processor in another country), we will use an appropriate transfer mechanism (e.g., UK adequacy regulations, International Data Transfer Agreement (IDTA) or the UK Addendum to the SCCs), and conduct transfer risk assessments where required.
4.8. Where we share Personal Data, we require recipients (by contract) to keep it confidential and to apply security standards commensurate with UK GDPR.

5. Updation Of Personal Data

You can view and update key account details in the app or by contacting support. We will take reasonable steps to ensure data is accurate and, where appropriate, kept up to date (UK GDPR accuracy principle).

6. Storage And Deletion Of Personal Data

6.1. We retain Personal Data for as long as necessary to provide the Platform and Game(s), to comply with legal obligations, and to resolve disputes. Retention is based on the storage limitation principle (we keep data no longer than necessary for the purposes for which it was collected).
6.2. On termination or closure of your account, we will delete or anonymise Personal Data, except that we may retain:

(a) Basic system logs, fraud/abuse markers and evidence necessary to protect our service and Users
(b) Data necessary to comply with legal obligations or to respond to lawful requests
(c) Data necessary to establish, exercise or defend legal claims.

7. Use Of Cookies

We use cookies/SDKs and similar technologies for essential functions (security, load balancing, session management) and, with consent, for analytics and (if enabled) marketing. Under PECR, we must tell you about cookies and obtain consent for non-essential cookies; consent must be active and informed. You can change preferences at any time via the in-app or website cookie controls. Some essential cookies cannot be disabled.

8. Security Procedures

We implement technical and organisational measures to protect Personal Data, including encryption in transit, access controls, and network safeguards. However, no system is 100% secure; residual risks remain on the open internet. We limit personnel access on a need-to-know basis and require processors to implement appropriate security.

9. Limitation Of Liability

Nothing in this Policy limits or excludes liability where unlawful (e.g., fraud,death or personal injury caused by negligence, or other non-excludable rights). To the extent permitted by law, we are not liable for indirect or consequential losses arising from the processing of Personal Data. In any event, our aggregate liability relating to privacy claims is capped at £100or the amount you paid for any optional cosmetic purchases in the preceding 12months (whichever is higher), without limiting your statutory rights. (The former INR figure is replaced with a GBP amount suitable for UK consumer context.)

10. Amendment

10.1. This Policy supersedes previous versions.
10.2. We may update this Policy to reflect legal or service changes. If we make material changes, we will notify you within the app or by email. Your continued use signifies acceptance, without prejudice to your rights under UK law.

11. Customer Support

11.1. For privacy questions or to exercise your rights, contact support@indibid.inor use the in-app support tool.
11.2. Please include enough detail for us to identify you and your request (e.g., account ID, request type).
11.3. We aim to acknowledge within 48 hours and resolve within 15 working days where feasible.

12. Grievance Redressal

12.1. Data Protection Contact:Please write to our Data Protection Contact at support@indibid.in(subject line: “Data Protection”). We will provide our latest postal correspondence details upon request or as listed on the website.
12.2. Applicable UK laws include the UK GDPR and DPA 2018. If you are unhappy with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO)12.3. We aim to acknowledge complaints within 48 hours and to provide a substantive response within 15 working days, where feasible.

13. Governing Law and Jurisdiction

13.1. This Policy and any non-contractual obligations are governed by the laws of England and Wales.
13.2. The courts of England and Wales shall have exclusive jurisdiction, without prejudice to any non-waivable consumer forum rights.

14. Miscellaneous

14.1. If any provision of this Policy is found unlawful or unenforceable, it shall be severed and the remainder shall continue in force.
14.2. This Policy governs our relationship regarding privacy and does not create rights for third parties, save as required by law.
14.3. Third-Party Content and links may appear in the Platform. We don’t endorse third-party sites; their privacy practices apply when you visit them. Review their privacy policies carefully.
14.4. You consent to receive service notices (e.g., privacy updates) by email or in-app message; marketing requires your consent or another lawful basis and is always opt-outable.
14.5. We may monitor account activity to protect Users and the Platform; we cooperate with competent GB authorities where required by law.