MILLIONHERE PRIVACY POLICY

This privacy policy applies to the entire contents of the platform “MILLIONHERE” operated by the Jengatron Gaming Private Limited ["JENGATRON GAMING"] which may be referred to hereon in as "we" or "us" or "our" (as applicable)] including, without limitation,www.millionhere.comincluding any application or software used to access the platform (“Website” or “mobile application”).

Please read the Privacy Policy below carefully before using Millionhere. By using or registering on Millionhere, you accept and agree to the terms of this privacy policy. If you do not accept these terms, you will not be allowed to access Millionhere.

1. Introduction

1.1 Millionhere (“Millionhere, we, us”) recognizes that people who use Millionhere’s Service (“you” or “Users”) value their privacy. This Privacy Policy details important information regarding the collection, use and disclosure of User information collected on Millionhere’s skill based gaming website located at www.millionhere.com, the related mobile app, and any other features, tools, materials, or other services (including co-branded or affiliated services) offered from time to time by Millionhere or its affiliate companies (the “Service”). Millionhere provides this Privacy Policy to help you make an informed decision about whether to use or continue using the Service.

1.2 This Privacy Policy should be read in conjunction with our Terms & Conditions. By accessing the Service, you are consenting to the collection and use of information practices described in this Privacy Policy.

1.3 The User’s use of the Service and any information the User may provide through the Service remains subject to the terms of this Privacy Policy and our Terms & Conditions, as each may be updated from time to time.

1.4 Any questions, comments or complaints that you might have should be emailed to millionhere email or forwarded in writing to: Millionhere’s registered address

2. Information We Collect

By choosing to use our Service and by submitting information to us through your use of our Service then this Privacy Policy will apply. You provide certain personal information to Milllionhere when choosing to participate in the various activities on the Service such as registering for an account, participating in contests, posting messages, taking advantage of promotions, responding to surveys or subscribing to newsletters or other mailing lists. The personal information we collect from you generally may include:

2.1.1 Your name, age or gender;

2.1.2 Email address;

2.1.3 Date of birth;

2.1.4 Credit card billing information;

2.1.5 Contacts you choose to submit;

2.1.6 Profile photo;

2.1.7 Username;

2.1.8 Location;

2.1.9 Your preferences;

2.1.10 Submissions to various competitions and promotions;

2.1.11 Responses to surveys;

2.1.12 Communications sent to us by you;

2.1.13 Your subscriptions to newsletters and services offered by us; and

2.1.14 Any other information you submit to Millionhere when choosing to participate in various activities on the Service.

2.2 In addition to the above, we may need to verify your identity in order for you to use some aspects of the Service. For purposes of verification, we may also collect the following personal information from you:

2.2.1 Aadhar card information;

2.2.2 PAN Card information;

2.2.3 Government-issued residence proof;

2.2.4 User's bank account details and proof of the same; and

2.2.5 Other information as may be required to verify you in accordance with applicable laws and regulations.

2.3 In addition to the aforesaid, we shall require the User to provide certain documents at the time of withdrawing the winnings from Millionhere into the User’s bank account. The said documents are the ‘Mandatory Information Documents’ (please refer to the Terms & Conditions for further information) necessary to be submitted by the User in order to withdraw their winnings from Millionhere and they are:

2.3.1 PAN Card information;

2.3.2 Aadhar Card information;

2.3.3. User bank account details and proof of the same;

2.3.4 Government issued residence proof

2.4 We may require you to furnish information about the payment methods such as credit/debit cards, e-wallets and other online payment methods. We may also require you to furnish additional information about the same including but not limited to billing address, card type, number, expiration date, card security code etc. If you choose to access any Service of Millionhere which require payments, you may be required to furnish the above stated details.

2.5 When you use our mobile app, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device (such as IDFA or an Android Ad ID), device information, default device language, the location of your device (at a GPS level), and app usage information. This data also may be linked to your other information, including your location data.

2.6 In addition, if you choose to log in, access or otherwise connect to Millionhere, or contact Millionhere, through a social networking service or any third party service(such as Facebook, Twitter, Google etc), we may collect your user ID and user name associated with that social networking service or third party service, as well as any information you make public using that social networking service or third party service. We may also collect information you have authorized the social networking service or third party service to share with us (such as your user ID, public profile information, email address, birthday, friends list, and pages you have "liked" or tweeted).

2.7 Cookies Information: When you visit the Millionhere website, we may send one or more cookies - small files - to your computer or other device, which may enable us or others to uniquely identify your browser. Millionhere uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser help file directions. Session cookies are temporary and typically disappear after you close your browser. You may be able to reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Site or Service may not function properly if the ability to accept cookies is disabled.

2.8 Log File Information: When you use our Service, our servers may automatically record certain information that your device sends whenever you visit any website and use certain apps. These server logs may include information such as your web or app request, Internet Protocol ("IP") address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser.

2.9 Clear GIFs Information: When you use our Service, we may employ technology such as "clear GIFs" (a.k.a. Web Beacons) which are used to track the online usage patterns of our users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by specific users.

3. The Way Millionhere Uses Your Personal Information

3.1 We may use your personal information to operate andmaintain the Service. The information may also be used to provide to you the features and functionality of the Service, including but not limited to the following:

3.1.1 Providing you with our products, services, games including their updates;

3.1.2 Processing and responding to your enquiries or feedback;

3.1.3 Personalizing your use of the Service,

3.1.4 Alerting you to new features, special events, products and services, or certain third-party products or services in which we think you will be interested;

3.1.5 Enforcing the legal terms and conditions that govern your use of the Service;

3.1.6 Investigating and protecting the integrity of Millionhere’s Games and/or Tournaments and/or Leagues and/or Challenges; and

3.1.7 Contacting you about your account or profile

3.2 We may use your information (both personal and non-personal information) to send you marketing and advertising content, including sending you advertising through multiple channels, such as direct mail, email, push notifications and display media. We may send you advertising or content regarding our products and services, or products and services that we market on behalf of another company or any other entity.

3.3 We may use your information to communicate with you about:

3.3.1 Our products and services in which you may be interested provided that you have not requested otherwise;

3.3.2 Newsletters and information for which you have signed up; and

3.3.3 non-marketing or administrative purposes (such as notifying you of major changes to the Service or for customer service purposes).

3.4 We use your information to improve the quality and design of our Service and to create new features, promotions, functionality, and services such as by storing, tracking, and analyzing user preferences and trends.

3.5 We may use your information in order to implement sufficient credit fraud protection and risk reduction measures.

3.6 We also use cookies, clear gifs, log file information, and mobile app information such as device identifiers for purposes such as (a) remembering information so that you will not have to re-enter it during your visit or the next time you visit our Service; (b) providing custom, personalized content and information; (c) monitoring the effectiveness of our marketing campaigns; (d) monitoring aggregate metrics such as total number of visitors, pages viewed, etc.; and (e) tracking your entries, submissions, and status in promotions, sweepstakes, and contests. You can learn more about how these technologies are used in the Section below, Third Party Advertising and Analytics.

3.7 We may anonymize, de-identify, or aggregate your information for any legitimate business purposes, including for reporting and research, or advertising. Such anonymized and/or aggregated data does not personally identify you. Sometimes, this information may be used to target more relevant content or offers to you across different devices – for instance, we may provide you with offers and content on your mobile device, based on your web-based activity.

4. When Millionhere Discloses Information

4.1 We may disclose the information we collect or receive from you to our subsidiaries, affiliated companies, agents, or other businesses, or service providers who process your information on our behalf in order to provide or operate the Service. For instance, these entities may have access to your information for purposes including (but not limited to) billing and accounting, hosting, marketing, promotional and email services, customer and technical support, and for the purpose of accepting deposits and paying withdrawals and processing such information on our behalf, and in each case, may use the information to make improvements to the services they provide to us. Our agreements with these service providers limit the kinds of information they can use or process and require them to use reasonable efforts to keep your personal information secure.

4.2 When you choose to share information with social media services about your activities on Millionhere by, for example, connecting your social media account to our Service, then Millionhere may share your personal information and information about your use of the Service with such social media sites. Please make sure to read the terms and privacy statements of such sites prior to connecting to our Service in this way.

4.3 In the event that you win a prize we may contact use your personal information (such as your name and photo) in connection with publicity purposes.

4.4 We may publish a profile page that includes your username, the date you became a member, your stats from previous Games and/or Tournaments and/or Leagues and/or Challenges and, if you uploaded one, your profile picture. Where you post personal information about yourself through our Service to public areas of our Service, you acknowledge and agree that this personal information will be publically available.

4.5 When you participate in a contest, we may publish your username on a list of the contest participants, along with a link to your profile page.

4.6 Where you have provided your consent, we may share your personal information with selected third parties for their commercial or marketing use in conjunction with your relationship with Millionhere or as part of a specific program or feature.

4.7 In addition, we may disclose to third parties various types of your information for targeted online or mobile advertising, as further described in the Section titled “Third Party Advertising and Analytics.”

4.8 We also may share personal information in other situations with your consent.

4.9 Millionhere also reserves the right to disclose personal information that Millionhere believes, in good faith, is appropriate or necessary to enforce our Terms of Use, take precautions against liability or harm, to investigate, prevent and/or respond to third-party claims or allegations, suspected illegal activities, fraud, to respond to court orders or official requests, to comply with state and federal regulations, including but not limited to sharing with appropriate tax authorities, to protect the security or integrity of our Service, to report violations of Millionhere’s eligibility rules to third parties or safety of Millionhere, our users or others.

4.10 If you elect to participate in any promotions, surveys, questionnaires, or other events during your usage of Millionhere, the rules or terms and conditions for those events may indicate that your information will be shared with third parties with your consent. You are advised to review the applicable rules and/or terms and conditions for any promotions, surveys, questionnaires or events.

4.11 In the event that Millionhere is involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, or other change of control, there may be a disclosure of your personal information to another entity related to such event.

5. Monitoring of Transactions

5.1 All gaming and account transactions are recorded on our computer system. We also carry out routine monitoring of all transactions as they take place, to assist us in improving the service that we provide to you.

5.2 All telephone conversations from the Users to our Customer Support Centre may be recorded both to assist us in training and in quality management, and to allow for the speedy resolution of the queries.

6. Your Choices

6.1 Millionhere will process your personal information in accordance with this Privacy Policy, and as part of that Millionhere provides you with certain choices about how we process your personal information. These choices are set out below.

6.2 You can access and update certain personal information Millionhere holds about you at any time by logging into your account via the Service. You can update your marketing preferences and whether or not you would like us to send you newsletters in your account. You can also unsubscribe to marketing emails and newsletters by using the 'unsubscribe' feature in the communication.

6.3 We may occasionally send you push notifications to your mobile device. You can turn off certain push notifications in the account settings of your Millionhere App. You can also turn off push notifications specific to our Service in the settings on your mobile device.

7. Third Party Advertising and Analytics

7.1 Certain ads appearing on our Service are delivered by our advertising partners. Our advertising partners may use cookies and other similar technologies, often in conjunction with unique (anonymous) cookie identifiers, to collect data about your activities and interests, including the technologies described above. Some of these partners may use mobile device identifiers, such as Apple IDFAs and Google/Android Advertising IDs. Doing this allows the ad companies to recognize your computer or device each time they send you an online or mobile advertisement. In this way, the ad companies may compile information about where you, or others who are using your computer or device, saw their advertisements and measure your interaction with each advertisement. This information allows advertisement companies to deliver targeted advertisements that may be of increased interest to you, both on our Service and elsewhere online. Just as these technologies may be used to target ads on our websites and apps, we, or our advertising partners, may use these same technologies and data points (e.g., mobile identifiers, cookie identifiers, location-based data), through our Service or through other services, to target advertising (for ourselves or other companies) on other sites or mobile apps. Sometimes, these identifiers may be derived from a hashed or encrypted version of personal information such as your email address. We may use this information to measure the performance of our advertising as well, for instance, to evaluate which ads or content our users prefer, or which are most effective. In addition, sometimes we or an advertising partner may tailor advertising to you across different devices.

7.2 To learn more and to opt out of the collection of data on our website by third parties (including those described above) for interest-based advertising purposes, please visit www.aboutads.info/choices or www.youronlinechoices.com. Note that because this opt out method may be cookie-based, you will need to opt out again if you update or change your browser, or delete your cookies.You can also control interest-based advertising on apps on your mobile device with the AppChoices app, available for iOS and Android. Note that opting out will not affect the quantity of ads you see online but likely will cause the ads to be less relevant to you.

7.3 We also work with third-party analytics companies to collect data on our Service through cookies and other automated means. In some cases, the third parties mentioned in this section may maintain the information they collect in personally identifiable form.

8. Information Security

8.1 We are committed to protecting the security of your personal information. Protection of the User Information, including the registration details and any debit or credit card information the User provides to us, is a priority for us. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.

8.2 Any personal information which identifies the User will be encrypted at all times whilst in transit over the internet. The technology used by us encrypts any information sent by the User on secured pages. Our server then reads the information using a private key. This means that your information, be it debit or credit card information or any other personal details, is turned into a code that can only be decoded with the private key or password.

8.3 Whilst neither we, nor any other organization, can guarantee the security of information processed online, we do have appropriate security measures in place to protect your personal information. For example, we store the personal information you provide on computer systems with limited access that are located in facilities to which access is limited.

8.4 To further protect your privacy and security, we reserve the right to take reasonable steps (such as requesting your password) to verify your identity before granting you profile access or making corrections.

8.5 Additionally, you should ensure your password is kept secret at all times. You will be responsible for maintaining the secrecy of your password and account information.

9. Privacy Measures for Minors

9.1 Millionhere is intended for persons who are 18 years of age or above. If the User is under 18 years of age, he/she shall not be permitted to use the platform ‘Millionhere’

. 9.2 If the User is a parent and/or guardian and believe that we may have inadvertently collected personal information from their child, they can notify us immediately by sending an email to support@millionhere.com.

10. Changes and updates

10.1 This Privacy Policy may be revised periodically and this will be reflected by the "Last update posted" date above. Please revisit this page to stay aware of any changes. If a revision to this Privacy Policy, in our sole discretion, is material, we will notify you by contacting you through the email address associated with your account.

10.2 Contact Information: Please contact Millionhere with any questions or comments about this Privacy Policy by emailing support@millionhere.com.

10.3 The User is responsible for keeping his/her information current. The User may update his/her information by contacting us at compliances.millionhere.com, and we will use reasonable efforts to process any change the User makes; provided, however, that requests to delete information are subject to our internal reporting, processing and retention policies and all applicable legal obligations.

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