1.GENERAL

1. VBMT SPORTS Gaming Pvt. Ltd. (“VBMT SPORTS”, “We”, “Our”, “Us” ) is committed to protecting and respecting your privacy and the protection of personal information provided by the users (“You”, “Your”, “User”) to VBMT SPORTS. This Privacy Notice explains how and why your personal information is collected, through the use of our website www.tambolastar.com and all variants thereof, including our mobile apps (the “Platform”), why it is collected and how it is kept secure. You agree that Your use of the Platform implies Your consent to the collection, retention and use of Your personal information in accordance with the terms of this Privacy Policy (“Privacy Policy”).
2. This Privacy Policy is an electronic record in the form of an electronic contract formed under the information Technology Act, 2000 and the rules made thereunder and the amended provisions pertaining to electronic documents / records in various statutes as amended by the information Technology Act, 2000. This Privacy Policy does not require any physical, electronic or digital signature and is a legally binding document between You and VBMT SPORTS.
3. We take the privacy of Our Users seriously. We are committed to safeguarding the privacy of Our Users while providing a personalized and valuable service.
4. No User information is rented or sold to any third party. When You use the Platform, the Platform may collect Your device number and other personal information. A high standard of security is maintained by Us for Our Users. However, the transmission of information via the internet or telephone networks is not completely secure. While We do Our best to protect Your information, particularly with respect to protection of Your personal data, VBMT SPORTS cannot ensure the security of Your data transmitted via the internet, telephone or any other networks.
5. Access to the contents available through the Platform is conditional upon Your approval of this Privacy Policy which should be read together with the Terms and Conditions of use (“Terms”). You acknowledge that this Privacy Policy, together with our Terms, forms Our agreement with You in relation to Your use of the Platform (“Agreement”).

2.WHAT TYPES OF INFORMATION WE COLLECT

We collect personal information when you interact with us and use our services (the "Services"). Sometimes, this information is provided to us by you – like when you register for the first time and when you make use of our products or get in touch with us. Sometimes third parties or publicly available sources provide us information about you.

Information you provide to us

1. At registration:

• Your personal details, such as your name, email address, postal address, telephone or mobile number, gender or date of birth;
• Photographic identification and proof of address documents (to carry out due diligence)
• Banking and financial details (to establish the source of funds  where a transaction is involved)
• Your account login details, such as your username and password

1. Through your use of our Services:

• Information about how you interact with our products
• Information about your online browsing behaviour on the Platform – please see our Cookies Policy (Section 6) for more details;
• Information about any devices you have used to access our Services (such as model, operating system, IP address, browser type, mobile device identifier)
• Recording phone calls – we may monitor or record phone calls with you. We might do this to check that we have carried out your instructions correctly; to resolve queries or issues; for regulatory purposes; to help improve our quality of service; to help us train our staff; or to help detect or prevent fraud or other crimes.

Information you shared with us voluntarily or else, made public, like social media profiles.

1. Other sources of personal data

• Where we provide personalized services, we may use third party data about you, for example, your Twitter or Facebook feeds, to get to know you better and to provide more effective personalization.
• Data received from our business partners and from other organizations, such as specialist companies providing verification services, credit reference agencies, and fraud prevention agencies.
• Publicly available sources, like pin code lookup.

1. Information about third parties

If you give us personal information about someone else (for example via a Refer a Friend scheme), then you should not do so without their permission. Where information is provided by you about someone else, or someone else discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this Privacy Policy. This list of personal data types collected by VBMT SPORTS is not exhaustive and further information may be requested from you when VBMT SPORTS considers it fair and necessary to do so.

1. Our Platform may contain links to third party websites or applications. You agree and understand that privacy policies of these websites are not under Our control. You understand that once You leave Our servers, use of any information You provide shall be governed by the privacy policy of the operator of the site used by You.
2. Our Platform may transmit Your Personal Information to Our internal servers. This Personal Information is immediately deleted once You delete the Platform, except to the extent it is necessary to store the same under applicable laws. Further, We have implemented commercially reasonable physical, managerial, operational and technical

security measures to protect the loss, misuse and alteration and to preserve the security of the Personal Information in Our care. Finally, this information is used strictly in line with Our business purposes and to provide You with useful features.

3.WHAT WE DO WITH YOUR PERSONAL INFORMATION

We recognize the trust and confidence our customers place in us as a service provider. In return, VBMT SPORTS is open about why we collect your data. First and foremost, collecting your information is essential for providing you the services and products you want. In addition, your data is used to personalize and improve your experience using our services, and to contact you from time to time with important information. In some cases, we need to collect and use your information to comply with the law. Under data protection laws, we also need to identify a specified lawful basis upon which we are processing your personal information. We rely on different bases for different processing activities.

1. Under the contract – It is necessary for the performance of an Agreement to which you are a party. Our Terms, which you have accepted at registration, set out the terms of the Agreement and the services we will provide:

To make our services available to you as part of our Agreement

• to provide gaming services, activities or online content, to provide you with information about them and to deal with your requests and enquiries;
• for 'service administration purposes', such as password reminders, service messages, such as site maintenance, updates to our Privacy and Cookies Policy or Terms, to let you know if your VBMT SPORTS account has become dormant and to ask if you would like to use it again before we close it;
• to process your transactions;

1. Under legitimate interests - It is necessary to process your data for the purposes set out below, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine if we can process your data on this basis, we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.

To personalize your experience

• to offer a more relevant, tailored service; for instance, we could use your playing history to provide personalized recommendations and products;
• If you are signed-in or subscribed to our marketing offers, you will receive a personalized service. If you don’t want to receive these services you can unsubscribe from marketing offers, or disable personalization by contacting our Customer Service or sending an email to info@tambolastar.com

To improve our services and products

• to provide you with the most user-friendly online navigation experience;
• for analysis and research purposes so that we may improve the services offered by VBMT SPORTS;
• testing new systems and checking upgrades to existing systems;
• evaluating the effectiveness of marketing, market research and training;
• customer modelling, statistical and trend analysis, with the aim of developing and improving products and services.

To contact and interact with you

• Contact you about our services, for example by phone, by post, email, or social media.
• Manage promotions and game you choose to enter;
• Invite you to take part in and manage customer surveys, questionnaires and other market research activities carried out by VBMT SPORTS and by other organizations on our behalf (We carry out market research to improve our services, however, if we contact you about this, you do not have to take part in the activities. If you tell us that you do not want us to contact you for market research, we will respect this choice and this will not affect your ability to use our services);
• Respond to your queries and complaints.

To make your game safer and more enjoyable

• to deter, prevent or detect the use of third party software;
• to deter, prevent, or detect any activities conducted in breach of our Terms & Conditions.

1. Under the legal obligation – when it is necessary in order to comply with mandatory legal obligations to which we are subject to under law:

o to determine where you are accessing the services from to redirect you to the correct site, in accordance with our license conditions;

• to make sure we offer our services to eligible persons;
• crime detection, prevention, and prosecution;
• to verify your identity and establish the source of funding in any transaction;
• to carry out appropriate anti-fraud checks (by conducting online searches using a third party identity provider). Please note that this will not affect your credit rating;
• to ensure your personal information remains accurate. In connection with these obligations we may periodically re-verify the personal data we hold about you to ensure it remains accurate and current (including by disclosing your personal data to and receiving personal data about you from third party identity and address verification services). If we update your personal data as a result of these verification processes, we will take reasonable steps to inform you. If you believe any of the personal data we hold about you is not accurate, please contact our Customer Service or send an email to info@tambolastar.com

3.4Under your consent Marketing and market research

We will send you relevant offers and news about our products and services in a number of ways including by email, sms, phone call, post, social media targeted advertising, but only if you have previously agreed to receive these marketing communications. When you register with us we will ask if you would like to receive marketing communications, and you can change your marketing choices online, over the phone or in writing at any time.

We may use information which we hold about you to show you relevant advertising on third party sites (e.g. Facebook, Google, Instagram, Snapchat and Twitter). If you don’t want to be shown targeted advertising messages from us, some third party sites allow you to request not to see messages from specific advertisers on that site in future. If you want to stop all personalized services from us, including targeted advertising messages on third party sites you can contact our Customer Service or send an email to info@tambolastar.com to disable personalization. We also like to hear your views to help us to improve our services, so we may contact you for market research purposes. You always have the choice about whether to take part in our market research.

3.5Special categories of data

We will only process such data if:

• you have given us your explicit consent;
• it relates to personal data which you have made public;
• it is necessary for the establishment, exercise or defense of legal claims;
• is necessary for reasons of substantial public interest, on the basis of the law.

4.WHEN DO WE SHARE YOUR PERSONAL INFORMATION

We do not share your personal information to third parties outside the VBMT SPORTS Group for marketing purposes. However, there are circumstances when we share your personal data with other companies in the VBMT SPORTS Group, with third parties that provide services to you on our behalf, and with other third parties in the course of complying with our legal obligations. Other examples of when we share your personal information include when we enter any kind of merger or business sale, as customers’ personal information is likely to be included in the sale/transfer. We would inform you prior to affecting such transfer of personal data. Even when it is shared, we ensure that your personal information will only be used for the purposes outlined in this Privacy Policy.

1. Except as otherwise provided in this Privacy Policy, We will keep Your Personal Information private and will not share it with third parties, unless We believe in good faith that disclosure of Your Personal Information or any other information We collect about You is necessary for Permitted Use or to:
   1. Comply with a court order or other legal process;
   2. Protect the rights, property or safety of VBMT SPORTS or another party;
   3. Enforce the Agreement, including Terms; or

1. Respond to claims that any posting or other content violates the rights of third-parties.

5.COOKIES POLICY

1. What are Cookies?
   1. Cookies are small pieces of data that sit on your computer that remember what you enter while you're browsing a website. We use cookies to help us customize your experience to show you the most relevant information when you return to our site.
   2. For more information about cookies and how they work, please visit: www.aboutcookies.org.
   3. If you'd prefer to change cookie preferences for VBMT SPORTS, or any other website, you can use your browser to do this. Each browser is different so please go to the 'Manage your cookies' section for more info.
   4. By using the Platform, you are consenting to VBMT SPORTS using cookies for the purposes outlined below in order to provide you with a fully functional experience.
2. To improve the responsiveness of the sites for Our Users, We may use ?cookies?, or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (User ID) to understand the User’s individual interests using the Identified Computer. Unless You voluntarily identify yourself (through registration, for example), We will have no way of knowing who You are, even if We assign a cookie to Your computer. The only personal information a cookie can contain is information You supply. A cookie cannot read data off Your hard drive. Our advertisers may also assign their own cookies to Your browser (if You click on their ads), a process that We do not control.
3. Our web servers automatically collect limited information about Your computer’s connection to the Internet, including Your IP address, when You visit Our site. (Your IP address is a number that lets computers attached to the Internet know where to send You data — such as the web pages You view.) Your IP address does not identify You personally. We use this information to deliver Our web pages to You upon request, to tailor Our site to the interests of Our Users, to measure traffic within Our site and let advertisers know the geographic locations from where Our visitors come.

6.UPDATES AND CHANGES TO PRIVACY POLICY

1. We reserve the right, at any time, to add to, change, update, or modify this Privacy Policy so please review it frequently. If We do, then We will post these changes on this page. In all cases, use of information We collect is subject to the Privacy Policy in effect at the time such information is collected.

7.SECURITY

1. The security of Your Personal Information is important to Us. We follow generally accepted industry standards to protect the Personal Information submitted to Us, both during transmission and once We receive it. All information gathered on Our Platform is securely stored within Our controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited.
2. Although We make best possible efforts to store Personal Information in a secure operating environment that is not open to the public, You should understand that there is no such thing as complete security, and We do not guarantee that there will be no unintended disclosures of Your Personal Information. If We become aware that Your Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, We will use reasonable efforts to notify You of the nature and extent of such disclosure (to the extent We know that information) as soon as reasonably possible and as permitted by law.

8.YOUR RIGHTS

1. You have a right to correct any errors in Your Personal Information available with Us. You may request Us in writing that We cease to use Your Personal Information.

RESTRICTION OF LIABILITY

1. VBMT SPORTS makes no claims, promises or guarantees about the accuracy, completeness, or adequacy of the contents available through the Platform and expressly disclaims liability for errors and omissions in the contents available through the Platform.
2. No warranty of any kind, implied, expressed or statutory, including but not limited to the warranties of non-infringement of third party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus, is given with respect to the contents available through the Platform or its links to other internet resources as may be available to You through the Platform.
3. Reference in the Platform to any specific commercial products, processes, or services, or the use of any trade, firm or corporation name is for the information and convenience of the public, and does not constitute endorsement, recommendation, or favoring by VBMT SPORTS.

If You have   questions   or   concerns,   feel   free   to   email   Us   or   to   correspond at info@tambolastar.com and We will attempt to address Your concerns as quickly as reasonably possible.

10.CUSTOMER SUPPORT CORRESPONDENCE

When You ask for help from our customer support team, we will collect and store the contact information you give them. We will also store the communications You have with Our customer support team and any additional information in those communications in order to provide support and improve our services.