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Game of Choice, Not Chance is a branded digital platform using play to empower the choices and voices of young people. The Go Bro game app and its connected website are owned by Howard Delafield International (‘HDI’, we, our or us). HDI is committed to respecting the privacy and security of those visiting or accessing the app. 

 

This Privacy Policy explains how and what information will be collected, used and disclosed through the Go Bro game app and website (support@gobrogame.com) referred to as “Services”.


This Privacy Policy applies only to the Services where you, the user, are accessing this policy. This Privacy Policy also applies to any offline location that makes this Privacy Policy available to you. This Privacy Policy does not apply to the collection, use or disclosure of information through any apps or websites linked from within the Services for which HDI is not the publisher or any information collected offline or via channels other than these Services. This Privacy Policy further extends to any in game privacy pop ups to which the user may agree to separately at various stages of the game.

NON-PERSONAL DATA COLLECTED BY THE GAME

The Game application ‘Go Bro’ expressly does not collect or retain any Personal data. Any non-personal information that is sought is used for non-commercial purposes only. The details of any non-personal information that you are asked to provide, namely age, gender and geographical location (state), are only for purposes of research.

 

Besides this, choices and clicks data in the game is automatically gathered and stored in log files, which are files that record events that occur in connection with your use of the Services. This data is tagged against a unique identifier for the user’s device/user profile. The unique identifier is an alphanumeric code that is autogenerated by the system. This data is stored locally on the user’s phone, as well as on the Game’s database. None of this data is linked to any information that is personally identifiable and is collected for purposes of research only as defined below.

 

Consequently, deletion of the Game app from the phone or formatting of the device will reset the application and delete all locally stored data.

HOW THE INFORMATION IS USED

The non-personal data collected through our Game and Services is used in various ways, including to:

 

  1. track trends, user preferences and movements on our Services;

  2. gather aggregated demographic information of our users;

  3. provide, operate, and maintain our Services;

  4. improve, personalize, and expand our Services;

  5. develop new products, services, features, and functionality;

  6. health-related research and analysis.

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Aggregated Non-Personal data might be shared with funders and related vendors/partners for research and analysis, or to provide extra services (such as coupons) to users to optimize their education in health. We may also analyse collected information relating to your use of the App or microsite in order to help us improve the App or microsite and develop and improve other products and services.

In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving Company, the information we possess, including Personal data, shall be shared with such entity.
 

OTHER PERSONAL DATA COLLECTED BY THE GAME’S SERVICES

You can use many of the Game’s features without providing us with personal data. However, some content and features require us to collect certain information, including personal data, from you. Therefore, while we do not collect any personal data at the start of the game, we will collect personal data for only the following specified lawful purposes as per the mandates of the law. 

 

We only collect as much information about children as is reasonably necessary and mentioned below for them to participate in the Game and its associated Services, and we do not condition their participation on the disclosure of any personal data than is reasonably necessary. In any instance that we collect personal data from a child, we will retain that information only so long as reasonably necessary to fulfil the activity request or as required by law.  In the event we discover we have collected information from a child in a manner inconsistent with Digital Personal Data Protection Act, 2023 (hereinafter known as “DPDPA”) or any other law for the time being in force, we will either delete the information immediately or seek consent of the parent for the data so collected. We also may ask for age information from children to validate their ages. However, we strongly advise children never to disclose any personal data unless it is necessary and obtain the explicit consent as per our process from their parents or guardians before disclosing such information.

 

The only exception to this is in the event you, as the user, choose to get any reward as offered or participate in any research. Accordingly, any and all sections hereunder are aimed to provide you with our policy in reference to primarily these two purposes only.

 

When we do collect or share any personal data for these purposes, we do so with your express consent taken at the point when such an event happens and separately for the specified purposes only. 

 

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us and any other information you may choose to provide. Any such information shall only be used to communicate with you and will not be forwarded to any third parties. The elements of personal data and purposes are as hereunder:

LIST OF PERSONAL DATA COLLECTED WITH PURPOSE

Full Name
for Research and Rewards

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Email
for Research and Rewards

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Phone Number 
for Research and Rewards

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Your current address, state, city and postal address, pin code
Rewards

Contents of messages and/or attachments 
Research and Website

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Any such information shall only be used to communicate with you and will be only forwarded for the specific purpose as mentioned above to our partners supporting in research and rewards.

As mentioned above this policy is primarily directed towards these two use cases:

Rewards Platform

In the case that a user voluntarily opts-in to redeem rewards, we will collect some Personal data such as name and address to send rewards to the players who win at certain levels of the game. Separate consent will be obtained from the parents or guardians of users who are below 18 years of age at the time such data is collected. A proper process is defined and is specified at the time such data is collected. This data will be used only for the purpose of sending rewards as obligated under the DPDPA or any other law for the time being in force in India and nothing else.

Research Chatbot

We may also collect certain information for conducting research in the event that the users opt to participate in the voluntary research programme. Separate consent will be obtained from the parents or guardians of the users who are below 18 years of age at the time the user opts to participate in the research. A proper process is defined and is specified when the users opt in to participate in the research. This data will be used only for the purpose of conducting research as obligated under the DPDPA or any other law for the time being in force in India and nothing else.

LEGAL BASIS

Before using the Services, it is essential to read and accept this Privacy Policy. By using the Services or interacting, online or offline, you provide your consent to our Privacy Policy, the collection, use and disclosure practices, and other activities described therein. If you do not agree, please discontinue any use of our Services. Your consent is maintained internally according to our established consent framework.

CONSENT AND NOTICE

LEGAL BASIS

In line with the DPDPA, we process personal data for legitimate uses as and when applicable. Some of the more used ones are:

  1. With Your Deemed Consent: We process your data for the specific purpose you voluntarily provided it for, as long as you have not indicated that you do not consent to its use.

  2. Government Functions: We process data when required for the performance of any function by the State or its agencies under Indian law, or for the sovereignty, integrity, or security of India.

  3. Legal Obligations: We process data to fulfil any legal obligations to disclose information to the State or its agencies, in accordance with applicable laws.

  4. Legal Compliance: We process data to comply with judgments, decrees, or orders under Indian law, or any judgments or orders related to contractual or civil claims under laws outside of India.

  5. Medical Emergency: We believe that disclosing such data will save the life of an individual or will result in a medical aid to an individual.
     

LEGITIMATE USE

WITHDRAWAL OF CONSENT 

  1. We keep Personal data as long as the specified purpose requires us to do so. 

  2. You have the right to withdraw your consent at any time. We will make it easy for you to do so as per the process defined in the section Your Rights.

  3. The consequences of this withdrawal will be on you as the Data Principal. However, this withdrawal will not affect the legality of processing of the personal data based on your consent before your withdrawal.

  4. If you withdraw your consent to the processing of personal data we will, within a reasonable time, cease and cause our third parties to cease processing of your personal data unless such processing without your consent is required or authorised under the law. 

  5. In the event, you want us to delete the personal data you will need to make a request to us for erasure of your personal data, and upon receipt of such a request, we will erase your personal data unless retention of the same is necessary for the specified purpose or for compliance with any law for the time being in force.

  6. We will keep this Personal Data archived or delete the same as per the mandate of the law.

DISCLOSURE & TRANSFER

Disclosure to Third Party Service Provider: 

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We may share your contact data with third party service provider for the purpose of fulfilment of any obligations under the terms.  

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We also reserve the right to disclose your Personal Data if required to do so by Applicable Law or if we believe that it is necessary to do so to protect and defend the rights, property, the Services, or our Users. 

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You understand that once you leave our servers, any personal data you provide to third party websites or application shall be governed by the privacy policy of the operator of the site used by you. You agree and understand that privacy policies of third-party websites or application are not under our control.
 

HOW THE INFORMATION IS STORED AND PROTECTED

Data collected through our Services is stored on servers that are leased by HDI, located in India. Access to these servers is limited to authorized personnel from HDI. HDI manages and monitors access and security of these servers. The Personal Data provided by you are stored on our cloud servers with whom we have appropriate agreements and technical safeguards. The data is stored in a Web hosting server managed by the third party and the data protection measures are managed by them.

 

We make our best effort to ensure security on our systems and take reasonable steps to protect our Services and data collected from theft, alteration or unauthorised inspection.

 

All your Personal Data provided by you, except upon withdrawal of your consent as above provided to us, shall be retained by us as long as it is required to be retained under Applicable Law. Upon withdrawal or termination of your playing the game with us, we will delete information based on a request received from you within a reasonable period and latest within 30 days of receiving a deletion request. In the event we do not receive a request from you for deletion of your Personal Data, your Personal Data will be available with us and maybe used by us for analytics on an anonymized basis.

SECURITY

We use industry standard technical and organizational measures to secure the Personal Data we collect from you. The app stores your Personal Data in servers which have reasonable security practices and procedures as per Applicable Law. 

 

We follow generally accepted industry standards to protect your Personal Data submitted by you to us. Although we make reasonable efforts to store and collect your Personal Data in a secure operating environment that is not open to the public, you should understand that there is no such thing as complete security. If in the unfortunate circumstance the Personal Data is compromised, we will notify you of the nature and extent of such disclosure (to the extent of the Personal Data compromised) as soon as reasonably possible and as prescribed by the DPDPA.

USE OF COOKIES AND TRACKING

We do not use cookies to collect information which might identify you personally on our Services.  We do not engage in tracking, targeted advertising or behavioural monitoring on our Services.

AGE VERIFICATION

We do not knowingly allow individuals under the age of 15 to use the Go Bro game app. The Go Bro game app is designed to cater to individuals who are aged 15 years and above. By downloading the Go Bro game app, you confirm that you are aged 15 years or above and agree to the Terms of Service of the Game.

 

By downloading the Go Bro app, you confirm that you are aged 15 years or above. If you are in the age group of 15-18 years, you agree to obtain your parent/guardian's consent to play the Game. In the game, Levels 3, 4 and 5 deal with content related to consent, fertility awareness and contraception, with the purpose of improving knowledge and awareness on sexual and reproductive health for adolescents and youth. Parental guidance is essential for users who are under 18 years of age. If you have any questions, you may contact us at support@gobrogame.com. Users below 18 years of age should seek parental guidance and obtain parental consent for downloading the game. You must obtain a written consent and upload it in the format specified.

 

If you are a parent/guardian of a child who is under the age of 15, and do not consent to your child’s access/use of our Services, please contact us at support@gobrogame.com to learn how to restrict access at your end. For any other questions, or further support, you may also contact us at support@gobrogame.com.

THIRD-PARTY LINKS

The Go Bro game app contains links to other partner sites that are not under our control. These partner sites do not follow our privacy policy, and we recommend that you read their privacy policies carefully. HDI does not assume any responsibility or any risk for your use of the Go Bro app or the Internet. The Go Bro app contains links to other sites but does not necessarily endorse these sites. 

 

Once you leave the “Go Bro” app, you will not have the same privacy or other protections. HDI assumes no liability for any diagnosis, treatment, decision made, or action taken in reliance upon information contained in the Go Bro app or any other internet sites linked to it in any way. HDI does not warrant, endorse, guarantee, or assume responsibility for any product or service advertised or offered by a third party through the website and app, or any hyperlinked website or featured in any banner or other advertising, and HDI will not be a party to or in any way be responsible for monitoring any transaction between you and third-party providers of products or services.

 

HDI partners and staff work very hard to ensure that the information presented on Go Bro app is accurate. However, the materials on Go Bro app are provided “as is” and HDI disclaims responsibility for any errors or omissions or for unintended technical inaccuracies or typographical errors in the materials. HDI does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its website or app. Further, HDI does not make any express or implied warranties, representations, or endorsements whatsoever in connection with the Go Bro app, other Web sites accessed by "hyperlink," or the Internet generally.

 

In no event shall HDI be liable for any injury, loss, claim, damage, or any incidental or consequential damages arising either directly or indirectly out of or in any way connected with the Go Bro app or any failure or delay in updating or including any materials on the or any use or inability to use any materials on the Go Bro app, even if HDI has been advised of the possibility of such damages.

YOUR RIGHTS

You have the right to:

 

  1. Manage, access, confirm, review, correct, your Personal Data available with us.

  2. To object to or restrict processing. You have the right to seek erasure of the Personal data

  3. Right to withdraw your consent.

  4. to seek redressal of any grievances for any acts or omissions of the Data fiduciary and exercising your rights under the policy. 

 

You also shall at any time have the option to withdraw your consent. In case you withdraw your consent we shall have the option not to provide our Services to you.

 

In case you want to exercise any of the above rights you can request for this by writing to us on support@gobrogame.com.

 

The right to Grievance Redressal is discussed below.

YOUR OBLIGATIONS

It is your responsibility to protect your details to help prevent anyone from accessing your account in an unauthorised manner. Your duties and obligations as a User are as follows:

 

  • You need to comply with the Digital Personal Data Protection Act, 2023

  • You must not impersonate any other

  • You must not suppress material information

  • You must not register false and frivolous cases

  • You must furnish information that is verifiably authentic

NOTIFICATION OF BREACH

Our security and technological and organizational measures are robust. However, in the unfortunate circumstances that we are hit by one we have an internal process to manage and notify the breaches appropriately.

GRIEVANCE REDRESSAL MECHANISM

HDI will acknowledge receipt of your complaints or grievances within 24 hours of receipt of your complaint or grievances. HDI will redress your complaint or grievances within 15 (fifteen) days from the date of receipt of your complaints or grievances. 

 

In accordance with the DPDPA, Information Technology Act, 2000 and the Rules made thereunder, if you have any complaints or grievances, relating to our privacy or data related practices, at the contact details support@gobrogame.com. 

 

In accordance with the Information Technology Act, 2000 and the Rules made thereunder, if you have any discrepancies or grievances, relating to our privacy or data related practices, please contact us at the following:

QUERIES AND FEEDBACK

If you have any questions or concerns relating to our Privacy Policy or how we capture, store or use information or regarding deletion of game data, please contact us at  support@gobrogame.com.

CONTACT US

If You have any questions concerning the Privacy Policy, please contact us at by e-mail at support@gobrogame.com.

UPDATES AND CHANGES TO PRIVACY POLICY

We may amend or update or change this Privacy Policy from time to time entirely at our own discretion to reflect new practices or technologies that impact the provision of our Services. We recommend that you review this Privacy Policy on a routine basis to view any changes. The date of the last revision or update appears on the bottom of the title.

 

We shall periodically and once in a year inform you of the following:

  • Any changes to our Privacy Policy; and 

  • Any non-compliance by you of Privacy Policy, you agree that we have the right to terminate the access or usage of Our Platform or remove such non-compliant information.  

GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by the laws of India. Any dispute arising out of or as a result of this Privacy Policy shall be tried and settled by a court of competent jurisdiction located in New Delhi.

ENTIRE AGREEMENT

This Privacy Policy and the Terms and Conditions of Service constitutes the entire agreement between you and HDI and governs the collection, use and disclosure of your Personal Data and your use of our Services and/or the Website.

IF YOU DO NOT AGREE WITH THE TERMS OF THE PRIVACY POLICY AND TERMS AND CONDITIONS OF SERVICE, PLEASE DO NOT ACCESS OR USE OUR SERVICES.

 

PLEASE TICK THIS BOX IF YOU AGREE TO OUR TERMS OF USE AND PRIVACY POLICY.

Last Updated on July 15, 2024

Privacy Policy

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