We, Phomo.in (hereinafter referred to as the “Company”) having its registered office at  Gurugram 122018, represented by its members, where such expression shall, unless repugnant to the context thereof, be deemed to include its respective legal heirs, representatives, administrators, permitted successors and assigns. The creator of this Privacy Policy ensures steady commitment to Your privacy with regard to the protection of your invaluable information. This privacy policy contains information about an online website called www.phomo.in (hereinafter referred to as the “Website”). In order to provide You with Our uninterrupted use of services, We may collect and, in some circumstances, disclose information about you with your permission. To ensure better protection of Your privacy, We provide this notice explaining Our information collection and disclosure policies, and the choices You make about the way Your information is collected and used.

This Privacy Policy shall be in compliance with the General Data Protection Regulation (GDPR) in effect from May 25, 2018 and any and all provisions that may read to the contrary shall be deemed to be void and unenforceable as of that date. If you do not agree with the terms and conditions of our Privacy Policy, including in relation to the manner of collection or use of your information, please do not use or access the Site. If you have any questions or concerns regarding this Privacy Policy, you should contact our Customer Support Desk at [email protected]

ANY CAPITALIZED WORDS USED HENCEFORTH SHALL HAVE THE MEANING ACCORDED TO THEM UNDER THIS AGREEMENT. FURTHER, ALL HEADING USED HEREIN ARE ONLY FOR THE PURPOSE OF ARRANGING THE VARIOUS PROVISIONS OF THE AGREEMENT IN ANY MANNER. NEITHER THE USER NOR THE CREATERS OF THIS PRIVACY POLICY MAY USE THE HEADING TO INTERPRET THE PROVISIONS CONTAINED WITHIN IT IN ANY MANNER.

• 1. DEFINITIONS
  “We”, “Our”, and “Us” shall mean and refer to the creators of this privacy policy.
  “You”, “Your”, “Yourself” and “User” shall mean and refer to natural and legal individuals who use the Website.
  “Personal Information” shall mean and refer to any personally identifiable information that We may collect from You. For removal of any doubts, please refer to Clause 2.
  “Third Parties” refer to any website, company or individual apart from the User and the creator of this Website.
• 2. INFORMATION WE COLLECT
  We are committed to respecting Your online privacy. We further recognize Your need for appropriate protection and management of any Personal Information You share with us. We may collect the following information:
  
  Personal data such as, but not limited to, Name, Location, Password, Email ID, high scores, game rankings game challenges, avatars, etc. Tracking Information such as, but not limited to the IP address of your device and Device ID when connected to the Internet. [This information may include the URL that you just came from (whether this URL is on the Website or not), which URL you next go to (whether this URL is on the Website or not), your computer browser information, and other information associated with your interaction with the Site.] This privacy policy also applies to data we collect from users who are not registered as members of this site, including, but not limited to, browsing behaviour, pages viewed etc. We also collect and store personal information provided by you from time to time on the Site. We only collect and use such information from you that we consider necessary for achieving a seamless, efficient and safe experience, customized to your needs including:
  
  To enable the provision of services opted for by you;
  To communicate necessary account and service related information from time to time;
  To allow you to receive quality customer care services;
  To comply with applicable laws, rules and regulations
  Where any service requested by you involves a third party, such information as is reasonably necessary by the Company to carry out your service request may be shared with such third party.
  
  We also do use your contact information to send you offers based on your interests and prior activity. The Company may also use contact information internally to direct its efforts for service improvement, but shall immediately delete all such information upon withdrawal of your consent for the same through our “unsubscribe” button or through an email to be sent to [email protected]
  
  We collect and store your search details on the Website, including your search history, the usage of the website and the features and time you have used the website for. Further, you may from time to time choose to provide payment related financial information (credit card, debit card, bank account details, billing address etc.) on the Site. We are committed to keeping all such sensitive data/information safe at all times and ensure that such data/information is only transacted over secure Site of approved payment gateways which are digitally encrypted, and provide the highest possible degree of care available under the technology presently in use. We shall collect and store all such information in our internal Company servers for a finite period time, as long as you are a User of the Website, and shall immediately delete all such information upon expiry of your Usership. We shall also delete all aforementioned communication you upon withdrawal of Usership of any single Party to the communication. The Company will not use your financial information for any purpose other than to complete a transaction with you. To the extent possible, we provide you the option of not divulging any specific information that you wish for us not to collect, store or use. You may also choose not to use a particular service or feature on the Site, and opt out of any non-essential communications from the Website.
  
  Further, transacting over the internet has inherent risks which can only be avoided by you following security practices yourself, such as not revealing account/login related information to any other person and informing our customer care team about any suspicious activity or where your account has/may has been compromised.
  
  At every stage prior to, during or after information collection, you have the right to access all personally identifiable information provided, rectify or alter all personally identifiable information provided, restrict the level of information to be retained as per your sole discretion and object to the retention, use and potential disclosure of the personally identifiable information.
• 3. LOGIN SYSTEM
  We use our own login system and facebook login system. We are incorporated and headquartered in India. However, Our login system is hosted by servers in the India. Personal information may be accessed by Us or transferred to Us in the India or to Our affiliates, business partners or service providers located elsewhere in the world. By providing Us with information We receive about You, You consent to such transfer. We will use our best endeavors to protect the privacy and security of this information according to Our Privacy Policy, regardless of where it is processed or stored.
• 4. OUR USE OF YOUR INFORMATION
  The information provided by You shall be used to Contact You when necessary and is also used for targeted marketing campaigns i.e. email marketing, remarketing, look alike campaigns etc., to conduct surveys, learn more about You by linking Your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers; Improve and develop new products, services, and features; c. Analyze purchase, usage and traffic data. For more details about the nature of such communications, please refer to our Terms of Service. Further, Your personal data and Sensitive Personal data may be collected and stored by Us for internal record.
  
  We use Your tracking information such as IP addresses, and or Device ID to help identify you and to gather broad demographic information. We will not sell, license or trade Your personal information. We will not share your personal information with others unless they are acting under our instructions or we are required to do so by law. Information collected via Our server logs includes users IP addresses and the pages visited; this will be used to manage the web system and troubleshoot problems. We also use third-party analytics, tracking, optimization and targeting tools to understand how users engage with our website so that we can improve it and cater personalized content/ads according to their preferences.
• 5. HOW INFORMATION IS COLLECTED
  Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. If the same is not identified to you, you have the right to request the Company to elucidate the purpose of collection of said personal information, pending fulfilment of which you shall not be mandated to disclose any information whatsoever.
  
  We will collect and use your personal information solely with the objective of fulfilling those purposes specified by us, within the scope of consent of the individual concerned or as required by law. We will only retain personal information as long as necessary for the fulfilment of those purposes. We will collect personal information by lawful and fair means and with the knowledge and consent of the individual concerned.
  
  Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
• 6. COOKIES
  We use data collection devices such as “cookies” on certain pages of our Websites. “Cookies” are small files sited on your hard drive that assist us in providing customized services. We also offer certain features that are only available through the use of a “cookie”. Cookies can also help us provide information, which is targeted to your interests. Cookies may be used to identify logged in or registered users. Our Website uses session cookies to ensure that you have a good experience. These cookies contain a unique number, your “session ID” , which allows our server to recognize your computer and “remember” what you have done on the site. The benefits of this are:
  
  You only need to log in once if you are navigating secure areas of the site Our server can distinguish between your computer and other users, so you can see the information that you have requested.
  
  You can choose to accept or decline cookies by modifying your browser settings if you prefer. This may prevent you from taking full advantage of the Website. We also use various third-party cookies for usage, behavioural, analytics and preferences data. The following are the different types of Cookies used on the Website:
  
  Authentication cookies
  To identify the user and share the content that he or she requested for.
  
  Functionality cookies
  For customized user experience and resuming past course progress.
  
  Tracking, optimization and targeting cookies
  To capture usage metric on device, operating system, browser etc. To capture behavioral metrics for better content delivery. To cater and suggest most suited products and services.
  
  Performance
  We use these cookies in order your experience on our website and performance. These cookies Collect information about how our website used, for example which pages you visited more often and where error came. Such data not give any personal details.
  
  Security and integrity
  These cookies help us to keep our website safe and secure, for example the help us to protect us from your unauthorized access or unauthorized alteration, disclosure or destruction of information we hold.
  
  Third Party Cookies
  We use number of third party services that they may also set cookies on our behalf when you visit our websites to allow them to deliver the services they are providing, for example we are using we are using third party cookies for statistical purposes. More information about these cookies are available on the corresponding third party website.
  
  We use two types of cookies –
  
  1. Session cookies
  These are temporary cookie files which are erased when You close Your browser.
  
  2. Persistent cookies
  These stay in one of Your browser sub-folders until You erase them or they expire.How 
• can I control or disable cookies?
  You may disable or clear cookies anytime. Please beware that because cookies are used throughout Our Websites, disabling or clearing cookies may prevent You from using certain parts of Our Websites and Services. If you are using Google Chrome, to disable cookies: Go to “Tools Menu”
  Click on “Options”
  Click on “Under the Hood”
  “Cookie Setting” should be selected. Once done select “Block all Cookies”
  Now all cookies should be blocked on your Google Chrome
  
  To clear existing cookies:
  Go to “Tools Menu”
  Click on “Options”
  Click on “Under the Hood”
  Under “Privacy” section select “Show Cookies”
  A new window should open called “Cookies” In here you can see all the cookies within your Google Chrome Browser.
  Click on “Remove All” to remove all traces of cookies
  If you wish to only remove a certain cookie, simply highlight and click “Remove”
  
  Other browsers
  For other browsers, please see the relevant browser support resources or guidelines.
• 7. GOOGLE ANALYTICS
  We use Google Analytics to help us to understand how you make use of Our content and work out how we can make things better. These cookies follow your progress through our website, collecting anonymous data on where you have come from, which pages you visit, and how long you spend on the site. This data is then stored by Google in order to create reports. These cookies do not store your personal data.
  
  The information generated by the cookie about your use of the Website, including your IP address, may be transmitted to and stored by Google on servers in the United States. Google may use this information for the purpose of evaluating your use of the website, compiling reports on website activity for us and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
  
  The Google website contains further information about Analytics and a copy of Google privacy policy pages.
• 8. EXTERNAL LINKS ON THE WEBSITE
  The Website may include advertisements, hyperlinks to other websites, applications, content or resources. We have no control over any websites or resources, which are provided by companies or persons other than Us. You acknowledge and agree that We are not responsible for the availability of any such external sites or resources, and do not endorse any advertising, services/products or other materials on or available from such websites or resources. You acknowledge and agree that We are not liable for any loss or damage which may be incurred by you as a result of the availability of those external sites or resources, or as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, products or other materials on, or available from, such websites or resources. These external websites and resource providers may have their own privacy policies governing the collection, storage, retention and disclosure of Your Personal Information that You may be subject to. We recommend that You enter the external Website and review their privacy policy. If you require a list of third-party links on our Website, please write to us at [email protected] and we will provide you with the same.
• 9. YOUR RIGHTS
  Unless subject to an exemption, you have the following rights with respect to your personal data:
  The right to request a copy of your personal data which we hold about you;
  The right to request for any correction to any personal data if it is found to be inaccurate or out of date;
  The right to withdraw Your consent to the processing at any time;
  The right to object to the processing of personal data;
  The right to lodge a complaint with a supervisory authority
  The right to obtain information as to whether personal data are transferred to a third country or to an international organization.
• 10. CONFIDENTIALITY
  You further acknowledge that the Website may contain information which is designated confidential by Us and that you shall not disclose such information without our prior written consent. Your information is regarded as confidential and therefore will not be divulged to any third party, unless if legally required to do so to the appropriate authorities. We will not sell, share, or rent your personal information to any third party or use your e-mail address for unsolicited mail. Any emails sent by us will only be in connection with the provision of agreed services, and you retain sole discretion to seek for discontinuation of such communications at any point of time.
• 11. OTHER INFORMATION COLLECTORS
  Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are on our Websites or on other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. To the extent that we use third party advertisers, they adhere to their own privacy policies. Since we do not control the privacy policies of the third parties, you are subject to ask questions before you disclose your personal information to others.
• 12. OUR DISCLOSURE OF YOUR INFORMATION
  Due to the existing regulatory environment, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting and foregoing), we may be forced to disclose information to the government, law enforcement agencies or third parties. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personally identifiable information or private communications would always remain private. We do, however assure you that any and all disclosure of your personally identifiable information shall be personally intimated to you through an email sent to your provided email address. As a matter of policy, we do not sell or rent any personally identifiable information about you to any third party. However, the following describes some of the ways that your personally identifiable information may be disclosed.
  
  External Service Providers
  There may be a number of services offered by external service providers that help you use our Websites. If you choose to use these optional services, and in the course of doing so, disclose information to the external service providers, and/or grant them permission to collect information about you, then their use of your information is governed by their privacy policy.
  
  Law and Order
  We cooperate with law enforcement inquiries, as well as other third parties to enforce laws, such as: intellectual property rights, fraud and other rights. We can (and you authorize us to) disclose any information about you to law enforcement and other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability.
• 13. ACCESSING, REVIEWING AND CHANGING YOUR PROFILE
  Following registration, You can review and change the information You submitted at the stage of registration, except Email ID. An option for facilitating such change shall be present on the Website and such change shall be facilitated by the User. If You change any information, We may or may not keep track of Your old information. We will not retain in our files information you have requested to remove for certain circumstances, such as to resolve disputes, troubleshoot problems and enforce our terms and conditions. Such prior information shall be completely removed from our databases, including stored “back up” systems. If you believe that any information we are holding on you is incorrect or incomplete, or to remove Your profile so that others cannot view it, the User needs to remediate, and promptly correct any such incorrect information.
• 14. CONTROL OF YOUR PASSWORD
  When you sign up to become a Member, you will also be asked to choose a password. You are entirely responsible for maintaining the confidentiality of your password. It is important that you protect it against unauthorized access of your account and information by choosing your password carefully, and keeping your password and computer secure by signing out after using our services.
  You agree not to use the account, username, email address or password of another Member at any time or to disclose your password to any third party. You are responsible for all actions taken with your login information and password, including fees. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password. You agree to notify us immediately if you suspect any consistent unauthorized use of your account or access to your password even after changing it.
• 15. SECURITY
  We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by members inside and outside the Company. We follow generally accepted industry standards to protect the Personal Information submitted to Us and information that we have accessed.
• 16. SEVERABILITY
  Each paragraph of this privacy policy shall be and remain separate from and independent of and severable from all and any other paragraphs herein except where otherwise expressly indicated or indicated by the context of the agreement. The decision or declaration that one or more of the paragraphs are null and void shall have no effect on the remaining paragraphs of this privacy policy.
• 17. AMENDMENT
  Our Privacy Policy may change from time to time. The most current version of the policy will govern our use of your information and will always be at the Website.
• 18. AUTOMATED DECISION MAKING
  As a responsible company, we do not use automatic decision-making or profiling.
• 19. CONSENT WITHDRAWAL, DATA DOWNLOAD & DATA REMOVAL REQUESTS
  
  To withdraw your consent, or to request the download or delete your data with us for any or all our products & services at any time, please email to [email protected] from your registered email address.
• 20. CONTACT US
  If you have any questions or concerns regarding this privacy policy, you should contact us by sending an e-mail to [email protected]