available on the
website or digital application forms a legally binding agreement between You and
(“PGPL”, “Our”, “We”,
MOBILE / DIGITAL APPLICATIONS.
participating in the website or its application/s or otherwise using services provided by the
Use the web portal https://www.gullygames.com/, its partner websites, mobile applications and
other portals (collectively, the “Platform”) if You agree to abide by the terms and conditions as
down in this Agreement.
Only people of sound mind who are above 18 years of age may use this Platform.
This Platform may not be used by residents of Assam, Odisha, Nagaland, Sikkim and
Telangana. Further, there may be certain games that may be restricted in some additional
states. To understand more about who may use this platform, please refer to the terms of
each game in detail that is provided with the game.
You may register on the Platform and add cash to Your account by following the registration
procedure laid down in the section on Nature and use of the Platform.
Please note that Your User Details will be accessible to other users on the Platform.
The rules governing Your participation in the Contests available on the Platform are
at the section on Participation. Further, each Mobile Game may be subject to its own Game
Rules and Code of Conduct.
Please note that the company has the sole discretion to determine the terms applicable on
any Contest including the Awards to be given in any Contest. Further, the Entry Fee for any
contest is non-refundable and may only be refunded under the circumstances stated in Our
Return, Refund and Cancellation policy.
Winnings may be withdrawn by You from Your account, subject to the completion of KYC
verification and will be subject to TDS deductions and/or any other conditions that may be
required to be met at the time of witdrawal.
Only skill-based games are available on Our Platform. To understand more about the nature
of games offered on Our Platform please refer to Games of skill section.
We further request that You follow the precautions laid down in Our Safety section while
playing Mobile Games on Our Platform.
While using the various communication channels provided on Our Platform You must abide
by rules stated in Our Community rules and code of conduct section.
You may not use the Platform in ways stated in Our Restrictions section. You will indemnify
Us in the event We suffer any losses on account of Your use of Our Platform or Your failure
to abide by this Agreement.
Circumstances under which Your access to the Platform or this Agreement may be
terminated are stated in the Termination section.
Your use of this Platform is completely at Your own risk. We disclaim all warranties in
relation to the Platform. To understand more please refer to Our Disclaimer section.
Any dispute between You and Us will be resolved by way of Arbitration which will be
conducted in Bangalore by a sole arbitrator appointed by Us. For further details refer to
Governing law and dispute resolution section.
If You have any complaints or grievances over any of the Services offered on the Platform,
please contact our Grievance Officer at firstname.lastname@example.org.
1.1. Pacific Gaming Private Limited is an Indian company incorporated under the Companies Act,
2013. www.gullygames.com and its associated
platforms operates a
mobile gaming portal
India, which offers various skill and learning based digital games developed by itself or
Third-Party Game Developers and other promotional and interactive features (collectively
“Services”) through its web portal https://www.gullygames.com/ partner websites, mobile
applications and other portals (collectively, the “Platform”).
1.2 . Capitalized terms used herein but not defined shall have the meanings ascribed to them under
section 1.9 (Definitions and Interpretation) of this Agreement.
1.3 . This Agreement shall apply to all Persons who visit the Platform, or create a player Account
including any contributors of content over the Platform (the “Users”,
1.4 . By registering on, browsing, downloading, using or accessing any part of the Platform or
utilizing the Services, the Users agree to be bound by this Agreement.
1.5 . If at any time the User does not accept or agree to any terms of this Agreement, on a
basis in relation to any of the Services offered on the Platform, they should not access the
1.6 . PGPL reserves the right to periodically review, update, change or replace any part of these
1.8 . Any Users’ continued usage of the Platform after any such update, change, replacement or
modification in the Agreement constitutes their valid consent to such changes.
1.9 . Definitions
available on the Platform including all other additional or modified terms and conditions and
in relation to the Platform or any current or future services that may be offered by the Company.
This Agreement is published in accordance with the provisions of Rule 3(1) of the Information
Technology (Intermediary Guidelines) Rules, 2011. This Agreement is an electronic record generated
by a computer system and does not require any physical or digital signatures.
1.9.2 . “Applicable Law” means all laws, statutes, common law, regulations,
guidelines, orders, permits, tariffs and approvals, including those relating to health and safety,
governmental authority or self-regulatory guideline that may apply to the Users or is related to the
subject matter of this Agreement as applicable in the territory of India.
1.9.3 . “Contest” is a skill based competition offered by the company on the
Platform in which Users
compete either in a tournament or 1v1 battle by playing the games on the Platform. Contests can be
either ‘paid’ or ‘free to play’. Paid Contests require the Users to pay an Entry Fee for
whereas free to play Contests are open to all Users without ant Entry-Fee.
1.9.4 . “Balance” is the credit (either in the form of cash or Tokens or any form
available in an Account and includes amount added by a User through Deposits or/and earned
through Winnings by participating in Contests on the Platform.
1.9.5 . “Deposit” is the amount added by the User to his/her Account through
payment mode (e-wallet, debit/credit cards, UPI/BHIM, net banking).
1.9.6 . “Entry-Fee” refers to the fee which Users pay either in the form of cash
Balance or Tokens
any other form of digital currency available in their Account to participate in a Contest on the
1.9.7 . “Mobile Games” refers to the digital games of skill including fantasy games
available on the
Platform developed by the Company or Third-Party Game Developers.
1.9.8 . “Person” shall mean any natural person, limited or unlimited liability
partnership (whether limited or unlimited), proprietorship, Hindu undivided family, trust, union,
association, government or any agency or political subdivision thereof or any other entity that may
be treated as a person under the Applicable Law.
1.9.9 . “Sponsored Content” means content distinct from other regular editorial
content provided by
the Company, and displayed on the Platform in the form of audio, video, text and/or image media
which supports a third party’s brand message, promotional offers, discounts and/or views that are
readily identifiable to belong to a third-party upfront through distinct and distinguishable font,
colour, display schemes and/or usage of disclaiming words (such as “Ad”, “Powered by”,
“Sponsored by”, “With”, “Advertorial” and/or such other phrase of similar meaning).
1.9.10 . “Sponsored Content Partner” means a User engaged with Us for the display
Content on the Platform.
1.9.11 . “Third Party Game Developer” refers to any Person (natural or juristic)
whose Mobile Game
is available on the Platform.
1.9.12 . “Bonus Chips/ Free Chips/ Tokens” is an award in the form of digital
currency that may be
given to any User at Company’s sole discretion for participating on the Platform.
1.9.13 “Winnings” are awards (either in the form of cash, Tokens or promotional
gifts) given to a
User for winning or/and performing well in a particular Contest on the Platform.
1.10 . Interpretation
1.10.1 . Any reference to the singular includes a reference to the plural and vice versa, and any
reference to one gender includes a reference to other gender(s), unless explicitly provided for.
1.10.2 . Headings and captions are used for convenience only and not for interpretation of the
1.10.3 . Any reference to a natural Person shall, include his/her heirs, executors and permitted
assignees and any reference to a juristic Person shall, include its affiliates, successors and
assignees, unless repugnant to the context.
2.1 . Any browsing, registering, downloading, using or accessing by any Person of any part of the
Platform or utilization of any of the services offered by the Company will be deemed to constitute a
legal contract between the User and the Company.
2.2 . A User may use the Platform if (a) it is a natural Person, as per any Applicable Law,
generally accepted practices or guidelines applicable in the country of which User is a citizen, in
which User is a resident or from where User uses the Platform; or (b) it is a juristic Person, as
Applicable Law, regulation or generally accepted industry practices and guidelines applicable in the
country where User is registered, where User maintains its principal office or from where User uses
2.3 . Any User who is “incompetent to contract” within the meaning of the Indian Contract Act, 1872
including minors, un-discharged insolvents etc. is not eligible to enter into this Agreement with
2.4 . The Platform should not be used, installed, or played by any Person under the age of 18 years.
2.5 . The Games and the services available on the Platform are open only to Persons currently
residing in India. Persons residing in the state of Assam, Odisha, Nagaland, Sikkim and Telangana
(“Restricted States”) are prohibited from participating in any Games on the
Platform. Further, there
may be certain games that may be restricted in some additional states.
2.6 . Only those Users who have successfully registered on the Platform in the manner prescribed in
section 3 (Nature and Use of the Platform), and who utilize the services of the Platform in
2.7 . Certain services being provided on the Platform may be subject to additional conditions or
applicable to a particular Game or Contest in that respect (“Game Terms”). Such
Game Terms are
deemed to be incorporated herein by reference. Users must agree to these Game Terms before
inconsistent with Game Terms, the Game Terms shall prevail.
2.8 . The Company reserves the right to terminate any User’s Account and/or deny access to the
Platform if it is brought to the Company’s notice that a particular User has violated the Agreement
Nature and use of the Platform
3.1 . The Company provides the Platform to You on which you can play Games either offered by the
Company or independent Third Party Game Developers. The Platform is designed to provide you an
in-app browsing experience through an embedded browser. These Mobile Games run online over
the Platform and do not have to be separately downloaded or installed.
3.2 .Registration: You may register by approving and agreeing to this Agreement and
Your registered mobile phone number on the Platform. You will be verified by the Company using
a one-time password (“OTP”) system. Upon successfully verifying the OTP, an account will be
created for You (“Account”).
3.3 . By registering for an Account, You represent, warrant and agree that:
a) You fulfil the eligibility criteria as detailed in section 2 (Eligibility);
b) You are using Your actual identity and the mobile phone number you have provided is
in Your own name;
c) You will provide only true, accurate, current, and complete information about Yourself,
optional information such as Your profile photograph, cover photograph, user-id, biograph,
status etc., on the Platform (“User Details”);
d) You will maintain and promptly update the User Details and other information that You
on the Platform to keep it true, accurate, current, and complete.
3.4 .The Users acknowledge that their User Details will be accessible to other User on the Platform
and shall be available for the Company to create promotional and interactive content over the
3.5 . Your Account is for Your personal use only. You shall not impersonate someone else. By
creating an Account after providing a mobile phone number and verifying it using an OTP, You
represent, warrant, and agree that You are authorized to use the Platform and will abide by the
Agreement. In case of complaints regarding impersonation, the Company will not be held
and protect Your
privacy when You use the Platform and our Services. By using the Platform, You agree that We can
b) You are responsible for maintaining the confidentiality of passwords associated with any device
You use to access the Platform. Accordingly, You are solely responsible for all activities that
with Your device and your Account. If You become aware of any unauthorized use of Your device,
You are required to notify the relevant authorities as soon as possible.
a) In order to participate in certain Contests, the Users may be required to pay an Entry Fee in the
via any online digital payment mechanism. Users may add money to their Account by using any of
the payment modes available on the Platform.
b) The Deposits may be used to participate in Contests in the manner provided under section 4
(Participation in Contests). There may be certain Contests which allow for payment of the Entry Fee
in the form of Tokens/ Bonus Chips or any other form of digital currency or may allow for part
payment of the Entry Fee in the form of rewards and the remainder of the Entry Fee from the
3.8 .Each User is solely responsible for all activities that occur under their Account, including
of any of the Services on the Platform.
3.9 . The Company grants such Users a non-transferrable, limited, non-exclusive and revocable
privilege to register an Account on and use the Platform.
3.10 . If the Company identifies that the same User Details are being used under multiple accounts,
then the Company at its sole discretion will terminate/deactivate the Account without the Users’
consent and any Deposit in the Account will not be refunded.
3.11 . The Company, at its sole and absolute discretion and without any notice to the Users,
the right to restrict, suspend or terminate any Account or access to the Platform temporarily or
permanently to any User.
3.12 . The Company may, at its sole and absolute discretion restrict, change, suspend, or terminate
any User’s access to all or any part of the Platform, including but not limited to:
a) reject, move, or remove any material that may be submitted by the User;
b) move or remove any content that is available on the Platform;
c) deactivate or delete an Account and all related information and files on their Account;
d) establish general practices and limits concerning use of the Platform and the services;
e) assign its rights and liabilities with respect to all Accounts hereunder, to any entity.
3.13 . Notwithstanding anything to the contrary herein, the Users acknowledge and agree that they
shall have no ownership or other interest in their Account, and further acknowledge and agree that
all rights in and to their Account are and shall forever be owned by and inure to the benefit of the
3.14 . The Users also accepts to receive news, updates, offers/campaign related SMS, to the mobile
phone number provided by the User, except when prohibited under Applicable Laws.
3.15. Platform Fee Information:
The Company may charge a Platform Fee on its games. Users are advised to review these charges
carefully before playing any of the games. The Platform fee is subject to change as per the
Company’s policy without prior notice.
Participation in contest
4.1 . The Users may use the Platform to participate in a variety of Contests available on the
4.2 . In order to participate in a Contest, each User may be required to pay an Entry Fee to the
Platform which is deducted from the Balance available in the Account of the User.
4.3 . Each Contest has a pre-determined limit on the number of Users that can participate and a
specified time before which entries must be made. A Contest is deemed to be a valid Contest on the
Platform, only if the requisite number of Users register for the Contest before the prescribed entry
time. If a contest is cancelled, the entry fee will be returned to the user.
4.4 . Any amount received by the Company as Entry Fee for participation in a Contest shall be non-
refundable, except in the event that a Contest has been cancelled.
4.5 . Contests shall be announced by the Platform from time to time in any manner that is
convenient to the Company, and the Company reserves the right to extend the participation and
time limit for registration, cancel any Contest, and modify any terms, all with due notice to the
of the Platform.
a) Awards for all Contests shall be pre-declared at the time of registration in the specific
applicable to such Contest. Awards may be in the form of Tokens, cash or promotional gifts.
b) Users are eligible to withdraw only cash Winnings from his/her Account to his/her
bank/wallet account once it is KYC (Know Your Customer) verified.
c) KYC verification is mandatory as a proof of identity for making withdrawals from
to Your bank/wallet account. KYC verification may be done through the Platform by
certain details: (i) photograph of a valid government ID (Aadhaar Card, Driving License,
Voter Card, Driving License etc.); and (ii) other User Details.
d) The Company does not issue receipts for entries in the Contests. The entries are
the Account on the Platform. It is the responsibility of the Users to ensure that the
accurate and the Winnings are duly credited to his Account.
e) Any tax/levies/duty etc., as applicable on material prizes, shall be paid by the winner
of the game.
Based on TDS (tax deducted at source) Rules for any sort of game winning in India, 31.2% TDS
be deducted on any winning above Rs.10,000/- in a single game.
4.7 Return, Refund and Cancellation
a) In the event, that there is an error in the Services provided by us, we may refund the
provided the reasons are genuine and proved after investigation by the Company.
b) Please read the rules of each Game and Contest before participating.
c) We do not cancel registrations once entered, however, in case of exceptional
wherein the fault may lie with the payment gateway or from Our side, We will cancel your
participation on request and refund the Entry Fee to You within a reasonable amount of time.
d) . In case we cancel your participation in any Game or Contest as a result of this, We
Your Entry Fee to You within a reasonable amount of time for You to redeem the same by
other Contests on the Platform.
e) . We will try Our best to create the best user experience for You. If paid by credit
card, refunds will
be issued to the original credit card provided at the time of purchase and in case of
through a payment gateway, payment refunds will be made to the same account.
4.8 . Users must use any money in their Account within 365 days. The Company shall have the
to directly forfeit any such unused amount after 365 (three hundred and sixty five) days.
Balance amount lying in your account may be withdrawn only in exceptional circumstances,
determined on a case to case basis on the sole discretion of the Company.
5.1 . The Platform is operated and designed to provide You an in-app browsing experience through
an embedded browser. The Platform is per-se a platform which offers Services and hosts Mobile
Games by Third Party Game Developers. The Platform does not host, display or transmit any content
owned by third parties on its servers, unless We either have a license or are not prohibited under
the Applicable Laws, to do the same.
5.1.2 . The Mobile Games will have their own rules and code of conduct (“Game Rules”) which shall
be adhered to by all Users at all times.
5.1.3 . When You play a Mobile Game, You agree and acknowledge that the Platform does not create
and/or broadcast any content on its own accord and the Company is not responsible or liable for the
content or accuracy of the Mobile Game, including copyrights, that may be accessed by You through
Games of skill
6.1 . The Mobile Games hosted by the Company on the Platform are all Games of Skill (defined
below). Different Mobile Games will reward different skills, but each game will reward certain
such as knowledge of the game, familiarity with rules, experience, reflexes, experience, practice,
hand-eye coordination etc. Certain games may have pre-determined outcomes (Sudoku,
Crosswords, Brick Breaker), which are achievable by the Users using their skills to play the games.
6.2 . Users must note that all Mobile Games available on the Platform are games where the success
or/and performance of the Users depends predominantly upon their superior knowledge, training,
attention, experience and adroitness (“Games of Skill”) in playing the game. ‘Games of Skill’, under
Indian law, are excluded from the ambit of gambling legislations including, the Public Gambling Act
of 1867 and other state enactments except in the Restricted States.
6.3 . Hence, the individuals residing in the Restricted States should not participate in any Contest
Mobile Games offered on the Platform. Any participation by such individuals shall be at their sole
risk and discretion and the Company shall not be liable to refund or reimburse any injury or damages
suffered by such individuals.
6.4 . The Company reserves the right to monitor all activities from the User’s Account on the
Platform. If any User participates in any Contest or Mobile Games in violation of any central and/or
state law(s) in India, the Company reserves the right to cooperate with law enforcement agencies of
the relevant state and report such participation or/and suspicious activity along with all relevant
details of the concerned User.
6.5 . The Company does not support, endorse or offer to any User ‘games of chance’ for money.
Each Mobile Game and Contest available on the Platform has clearly defined rules and code of
conduct. All Users are encouraged to read, understand and follow these rules to be successful in
these games. The Company shall not be liable if Users do not adhere to the Game Rules or otherwise
engage in gambling or betting activities on the Platform.
Safety precaution and responsible gaming
7.1 . The Company suggests that Users adopt a balanced approach while engaging with any of
Mobile Games on the Platform and safeguard themselves against any adverse effects. If played
responsibly, Mobile Games (like other forms of sports) aim to encourage Users to develop their
mental prowess, hand-eye co-ordination, competitiveness and encourage teamwork.
7.2 . You should take certain standard health and safety precautions while playing any Mobile Game,
including taking adequate breaks, sitting at a reasonable distance from the screen, playing in a
lit environment, and avoiding playing when tired, drowsy, intoxicated or under the influence of
drugs Avoid playing without breaks over long periods of time as this could affect Your performance
and could negatively impact hand-eye coordination, balance, and multi-tasking ability.
7.3 . The Games offered on the Platform may contain flashing lights, realistic images,
simulations which may cause certain side effects. If Your hands, wrists, arms, eyes or other
of Your body become tired or sore while playing, or if You feel symptoms such as tingling,
numbness, burning or stiffness, stop and rest before playing again. If You continue to have any
these above symptoms, please stop playing IMMEDIATELY and consult a doctor.
7.4 . If You play any Mobile Games on the Platform, give Yourself plenty of room to play and always
be aware of Your surroundings. While playing any Mobile Game You may be moving around the play
area and using Your hands to control gameplay. You must ensure that You are not near other
people, objects, stairs, balconies, windows, walls, furniture or other objects that may pose a
to You or could be damaged during the play. Never handle sharp or dangerous objects while playing
any Mobile Game on the Platform.
7.5 . It is Your responsibility to control Your surroundings and movements at all times when
playing the game to ensure that You don’t injure Yourself, any other persons, damage any
property etc. Playing of the Mobile Games is at Your own risk and the Company shall not be liable
for any death, injury or health complications resulting from Your use of the Platform.
7.6 . You agree that Your use of the Platform and to play the Mobile Games is at Your own risk, and
is Your responsibility to maintain such health, liability, hazard, personal injury, medical, life,
other insurance policies as You deem reasonably necessary for any injuries that You may incur while
using the Platform.
Community rules and code of conduct
8.1 . The Platform may provide Users with different communication channels such as forums, live
audio sessions, live audio chat with other players participating in any Contest, community groups,
chat-rooms or chat areas (“Communication Facilities”) designed to enable You to communicate with
other Users on the Platform.
8.2 . The platform only provides Users with the technical environment for an exchange of
information. The Company does not initiate, select the receiver and/or modify any information
exchanges inter se amongst the Users through the Communication Facilities. Further, the Company
has no obligation to and does not monitor these Communication Facilities except when required to
do so under the provisions of Applicable Law
8.3 . The User may use the Communication Facilities as made available to them by the Platform. The
Platofrm may provide certain additional features or Communication Facilities to a select group of
Users at its sole discretion. The Users do not have the right to claim any Communication Facilities
8.4 . The Company may enable audio sessions and live chat-rooms on the Platform for the Users
from time-to-time. These sessions or/and chat rooms will be conducted by other users to (i) organize
trainings; (ii) provide tips to play Mobile Games; (iii) provide educational content; or (iv)
other interactive sessions on the Platform. The sessions or/and chat rooms may have an open entry
or may be restricted to a limited number of Users at the Company’s sole discretion. Users might be
required to pay an ‘Access fee’ to participate in any of these live sessions or/and chat rooms
by the Company on the Platform. The ‘Access Fee’ shall be subject to levy of applicable Goods &
Services Tax and the Fee collected shall be inclusive thereof.
8.5 . You understand that, by using these Communication Facilities, You may be exposed to
communications (including in written, verbal, electronic, digital, machine-readable or other form)
that You might find objectionable. You understand that any content sent or appearing through the
Communication Facilities is the sole responsibility of the User(s) transmitting such content and the
Company is not liable for any content posted on the Communication Channels.
8.6 . All Users of the Platform must comply with Applicable Law at all times while using the
of Platform, including our Community Guidelines (refer to Annexure III for more details) and
Communication Facilities and must not publish or distribute any content which: (a) violates an
Applicable Law, goes against common decency, or breaches the general terms and conditions of the
Agreement; or (b) violates any trademarks, patents, utility or design patterns, copyrights, trade
secrets, or other proprietary rights of third parties; or (c) impersonate any real person, including
without limitation the Company or any other Company agent or employee; or (d) is obscene, racist,
violent, pornographic, of adult content, or otherwise threatening to the development of children
and adolescents, or of a detrimental nature; or (e) is of an abusive, harassing, threatening or
defamatory nature; or (f) seeks to unlawfully obtain login information or access to Accounts
belonging to other Users; (g) contains personal data of third parties without their explicit
(h) seek to collect, misuse, or disseminate any other User’s content or non-public personal
information; or (i) is commercial, in particular promotional, in nature; (j) encourages or promotes
gambling or money-laundering.
8.7 . All Users of the platform shall read and fully understand our Community Guidelines before
posting any content on our platform. By accepting the Terms and Use, the Users agree and
acknowledge that they have read and fully understood the terms of the Community Guidelines. The
Company has a right to take appropriate and strict actions against any User violating such
8.8. Under no circumstances will the Company or its third-party providers shall be liable for any
errors, objections or omissions in any content or for any loss or damages of any kind incurred as a
result of the content posted on its Platform.
Restrictions on your use of the Platform
9.1 . You will not use the Platform, or any content provided thereof for any purpose that is
unlawful or prohibited by this Agreement or under Applicable Law.
9.2 . You will not use the Platform, or any content provided thereof:
9.2.1 . to host, display, upload, modify, publish, transmit, update or share any information that
belongs to another Person and to which the User does not have any right to;
9.2.2 . is grossly harmful, harassing, blasphemous, defamatory, obscene, pornographic, paedophilic,
libellous, invasive of another’s privacy, hateful, or racially, ethnically objectionable,
9.2.3 . that is relating to or encourages money laundering or gambling, or is otherwise unlawful in
any manner whatsoever;
9.2.4 . that harms minors in any way;
9.2.5 . that infringes any patent, trademark, copyright or other proprietary rights; violates any
Applicable Law for the time being in force;
9.2.6 . that deceives or misleads the addressee about the origin of such messages or communicates
any information which is grossly offensive or menacing in nature;
9.2.7 . which impersonates another Person; contains software viruses or any other computer code,
files or programs designed to interrupt, destroy or limit the functionality of the Platform or any
other computer resource;
9.2.8 . that threatens the unity, integrity, defence, security or sovereignty of India, friendly
with foreign states, or public order, or causes incitement to the commission of any cognisable
offence or prevents investigation of any offence or is insulting any other nation; threatens public
health or safety; promotion of cigarettes or any other tobacco products or consumption of
intoxicant including alcohol and Electronic Nicotine Delivery System (ENDS) and like products that
enable nicotine delivery except for the purpose & in the manner and to the extent, as may be
approved under the Drugs and Cosmetics Act, 1940 and Rules made thereunder; threatens critical
9.3 . You will not redistribute, sublicense, rent, publish, sell, assign, lease, market, transfer,
otherwise make the Platform or any component or content thereof, available to third parties
without the permission of the Company.
9.4 . You will not circumvent or disable any digital rights management, usage rules, or other
features of the Platform; remove, alter, or obscure any proprietary notices (including copyright
notices) on any portion of the Platform; and not use the Platform in a manner that threatens the
integrity, performance, or availability of the Platform.
9.5 . You will not attempt to or engage in any activity that may:
9.5.1 . reverse engineer, decompile or otherwise extract the source code related to the Platform or
any part thereof, unless it is expressly permitted by the Company to You in writing or is required
the Applicable Law;
9.5.2 . use any robot, spider, retrieval application, Heads Up Displays or other device to retrieve
index any portion of the Platform or content thereof;
9.5.3 . collect information about Users for any illegal or unlawful purpose;
9.5.4 . create any Account by automated means or under false or fraudulent pretences for using the
9.5.5 . transmit any viruses, worms, defects, trojan horses, or any items of a destructive nature
through the Platform;
9.5.6 . use the Platform in any manner that could damage, disable, overburden, or impair, or
undertake any action which is harmful or potentially harmful to, any of the servers, networks,
computer systems or resources connected to any of the servers connected, directly or indirectly to
the Platform, or interfere with any other Users’ use and enjoyment of the Platform;
9.5.8 . forge headers or otherwise manipulate identifiers to disguise the origin of any content
transmitted through the Platform; and/or
9.5.9 . obtain any materials or information through any means not intentionally made available, in
the opinion of the Company, through the Platform.
9.6 . You will not impersonate another Person or impersonate, guide or host on behalf of, or falsely
state or otherwise misrepresent Your affiliation with any Person or entity, including, but not
to Our officials, employees, agents, partners, affiliates, dealers and franchisees.
9.7 . If We detect any activity from Your User Account that is fraudulent, suspected to be
the Platform, or if You are found colluding or participating in any kind of fraudulent activity on
Platform in any manner, then You shall be debarred from participating in any Contest available on
9.8 . We reserve the right to deactivate or delete Your Account and all related information on it
forfeit related Balances and/or take any other appropriate action, at our sole and absolute
discretion, in the event of any fraudulent, illegal or suspicious activities from Your Account on
9.9 . Any deductions or forfeiture of Balances made from Your Account shall be made at Our sole
and absolute discretion and shall not result in any liability on the Platform whatsoever. We may
choose to provide a right of appeal to the User after deleting, closing or forfeiting the balances
his/her Account. However, such right shall be provided at the sole and absolute discretion of the
Company and the User shall not claim such right or any other recourse from the Company.
9.10 . Indemnification You shall defend, indemnify and hold the Company, and its
directors, employees, representatives and agents harmless from and against any claims, actions,
demands, liabilities, judgments, and settlements, including without limitation, reasonable legal fee
that may result from or alleged to result from (a) Your use of the Platform or any content thereof,
including the Game/s; or (b) Your breach of any rules, regulations and/or orders under any
9.11 . You are also responsible for any breach of Your obligations under the Agreement and/or for
the consequences of any such breach.
10.1 . Your access to the Platform may be terminated if:
10.1.1 . You voluntarily uninstall the Platform from Your device;
10.1.2 . You knowingly or unknowingly cause direct or indirect breach, as ascertained by the
10.1.3 . You do not pay the requisite fee, if any, should the Company charge for use of the
10.2 . We may have to terminate Your access to the Platform if:
10.2.1 . We are required to do so by law (for example, where the access to and/or provision of the
Platform to You becomes, unlawful);
10.2.2 . The third-party Person, if any, with whom We offered the Platform to You has terminated its
relationship with Us or ceased to offer the related services to Us or to You;
10.2.3 . The provision of the Platform to You, is no longer commercially viable or feasible for Us;
10.2.4 . You are a repeat infringer of this Agreement.
10.3 . We may terminate this Agreement at any time, with or without notice and may disable Your
access to the Platform and/or bar You from any future use of the Platform.
10.4 . You may terminate this Agreement at any time by terminating Your access to the Platform.
However, certain obligations of Yours under this Agreement shall continue to prevail even on such
10.5 . When this Agreement comes to an end, all of the legal rights, obligations and liabilities
You and the Company have benefited from, been subject to (or which have accrued over time whilst
the Agreement has been in force) or which are expressed to continue indefinitely, shall be
unaffected by this cessation, and shall continue to apply to such rights, obligations and
11.1 . No warranties The Contents provided through the Platform may include
inaccuracies or typographical errors. The Company may make changes or improvements to the
Platform at any time. The Contents or any information available on the Platform is provided “as is”
and “as available” and without warranties of any kind either expressed or implied, to the fullest
extent permissible pursuant to Applicable Laws, including but not limited to:
11.1.1 . any implied warranty or merchantability, fitness for a particular purpose;
11.1.2 . that the contents of the Platform will be uninterrupted or error-free;
11.1.3 . that defects, if any on the Platform will be corrected;
11.1.4 . the Platform being constantly available or available at all;
11.1.5 . installation or uninstallation choices in relation to the Platform being successfully
in all cases;
11.1.6 . Your personal ability to use the Platform;
11.1.7 . Your satisfaction with the use of the Platform;
11.1.8 . the accuracy of the data provided by the Platform;
11.1.9 . the security and privacy of Your data;
11.1.10 . that all bugs or errors in relation to the Platform will be corrected;
11.1.11 . that the Platform will be compatible with all devices and all networks;
11.1.12 . that the Platform is fit for a particular purpose or use;
11.1.3 . that the Platform and the contents thereof are accessible in every location; or
11.1.4 . that the Platform and the contents would be perpetually secure and not prone to breaches
of security anywhere in the world.
11.2 . The Company, its officers, directors, employees, affiliates and agents and any other service
provider(s) responsible for providing access to the Platform in connection with this Agreement will
not be liable for any acts or omissions, including of a third party Person, and including those
participating in the Platforms’ offerings made to You, or for any unauthorized interception of data
breaches of this Agreement attributable in part to the acts or omissions of third parties Persons,
for damages that result from the operation systems, equipment, facilities or services provided by
third parties Persons that are interconnected with the Company.
11.3 . The Platform may include links to other mobile applications and/or websites (some of which
may be automated search results) which may contain materials that are objectionable, unlawful, or
inaccurate. We do not endorse or support these links or the products and services they provide;
these links are provided for Your convenience only. We are not responsible or liable for the content
or accuracy of such links.
11.4 . We may stop provision of the Platform (or any part thereof), permanently or temporarily, to
You or to Users generally or may modify or change the nature of the Platform and/or these Terms of
Use at Our sole discretion, without any prior notice to You. Your use of the Platform following any
such modification constitutes Your deemed acceptance to be bound by the Agreement (or as it may
11.5 . You agree that You are responsible for all data charges You incur through use of the
11.6 . Sponsored Content:
11.6.1 . You agree and acknowledge that the Company may, pursuant to its engagement with certain
Sponsored Content Partners, place certain Sponsored Content on, about, or in conjunction with the
other content within the Platform. The manner, mode and extent of display of such Sponsored
Content is subject to change without a specific notice to You.
11.6.2 . The content displayed on the Platform is for Your non-commercial and personal use.
However, Sponsored Content Partners may use the Platform to display their respective Sponsored
Content for commercial purposes. You are not allowed to copy, reproduce, alter, modify, create
derivative works of, or publicly display any content displayed on the Platform.
11.7 . Limitation of liability Your use of the Platform, or any content, including
available thereof is entirely at Your own option and risk and We shall be held harmless and not be
liable for any direct, indirect, incidental, consequential, special, exemplary, punitive, monetary
any other damages, fees, fines, penalties or liabilities whatsoever arising out of or relating to
use of the Platform or any content thereof, including Mobile Game. To the maximum extent
permitted by Applicable Law, Our total liability to You for any damages (regardless of the
for the action) shall not exceed in the aggregate the Balance in your Account.
11.8 . You may terminate Your access to the Platform if You are not satisfied with the Platform or
11.9 . Force Majeure: The Company shall not be liable for any damages whatsoever arising out of
Force Majeure Event or other similar circumstances, directly or indirectly to the Users as a result
playing Mobile Games or using the services offered by the Company on the Platform. A Force
Majeure Event is a real or potential labour disputes, governmental actions, war or threat of war,
sabotage, civil unrest, demonstrations, fire, storm, flooding, explosion, earthquake, provisions or
limitations of materials or resources, inability to obtain the relevant authorization, accident, and
defect in electricity or telecommunication network that affects the Company’s ability to offer the
services or/and the Mobile Games on the Platform. Force majeure or other event beyond the
Company’s control hindering, delaying or complicating the maintenance of the Platform entitles the
Company to suspend or limit the Platform until further notice.
Governing law and dispute resolution
12.1 . The Platform may be controlled and operated through any country and will be subject to the
laws of that state in which they are controlled and operated by the User. If You use the Platform
from any location, then, You are responsible for compliance with the local laws applicable to You.
12.2 . All or any disputes arising out of or touching upon or in relation to this Agreement
the interpretation and validity of the terms thereof and the respective rights and obligations of
parties shall be settled through arbitration. The arbitration shall be governed by the Arbitration
Conciliation Act, 1996 (India) or any statutory amendments/modifications thereto for the time being
12.3 . The arbitration proceedings shall be held at Bangalore, Karnataka by a sole arbitrator who
shall be appointed by the Company and whose decision shall be final and binding upon all the
12.4 . Subject to the arbitration clause, the courts at Bangalore, Karnataka alone shall have the
jurisdiction. The language of the arbitration proceedings shall be in English.
12.5 . You and the Company agree that any cause of action arising out of Your use of the Platform
must be commenced within 2 (two) months after the cause of action accrues or You become aware
of the facts giving rise to the cause of action, whichever is later. Otherwise, such cause of action
be permanently barred.
In accordance with the Information Technology Act 2000 and rules made thereunder, We have a
Grievance Officer to address Your concerns regarding data safety, privacy, and the Platform usage
concerns including complaints You have against other users on the Platform. We will resolve these
issues raised by You within 30 (thirty) days from receiving them. You may contact the Grievance
Officer at the following coordinates:
Name: Kshitij Anilkumar
We have a Compliance Officer to ensure compliance that the games offered on our platform comply
with applicable gaming laws. You may contact the Compliance Officer at the following coordinates:
Name: Archit Narayan
1.The Company may offer referral programs (“Referral Program”) on the Platform to allow all its
Users to receive certain rewards in the form of Tokens or cash (“Rewards”) for each player that they
refer to play on the Platform
2. All active Users of the Platform are eligible to participate in the Referral Program except in
where an Account has been suspended or has otherwise been disallowed by the Company from
participation in the Referral Program.
3. Only ‘successful referrals’ will be counted and eligible to receive the Rewards. A successful
is an event in which a new User will register on the Platform and complete the sign-up by clicking
the referral link of the referrer or by putting the referrer’s unique referral code.
4. Additional terms applicable to all Referral Programs
1. The nature and value of Rewards to be credited will be based on the Referral Program
offered by the Platform at any given point in time to an individual User.
Referral links will be generated from each User’s Account on the Platform.
Rewards and their types are subject to change at the Company’s discretion without notice.
Users found to have been committing fraud will be blocked from the Platform.
The reward amount/type is based on the applicable reward on the day a user’s referral signs
up on the platform.
A user can refer up to 1000 friends.
The Company reserves the right to change rules and regulations without notice.
Please contact Customer Support in case of further queries. The nature and value of
Rewards to be credited will be based on the Referral Program offered by the Company at
any given point in time to an individual User.
6. Disqualification from Referral Programs
1. Users will not receive credit for referring themselves by creating multiple Accounts.
2. The Company reserves the right, in its sole discretion, to suspend or disqualify an
from the Referral Program or nullify the referral Rewards.
7. Taxes – The Users are responsible for paying any and all taxes or commissions
related to the
Rewards earned by them through the Referral Programs on the Platform. The Company reserves the
right to withhold taxes as appropriate and as required under Applicable Laws.
4. GAME OF SKILL
4.1 . In providing the Rummy and Poker game on the Platform, the Company takes great care to
comply with all central and state legislations in India to ensure that the Users are fully
Rummy and Poker are carefully designed to comply with all applicable statutes and regulations in
4.2. Rummy offered on the Platform is a ‘game of skill’. According to a 1967 Supreme Court
judgment in State of Andhra Pradesh v. K. Satyanarayana, In the game of Rummy is a game of mere
skill and playing Rummy does not amount to gambling.
4.3. Over the past few decades, various High Courts have quoted the apex court’s decision and
stated that law enforcement authorities cannot interfere with the game of Rummy played with
stakes. In 1996, a three-judge bench of the Supreme Court affirmed its 1967 judgment and ruled
that games involving substantial and preponderant degree of skill fall within the definition of
of mere skill’.
4.4. By virtue of its classification as a game of skill, the game of Rummy and Poker does not
the Public Gambling Act, 1867, and is excluded from the ambit of most state gaming legislations.
However, Users should note that owing to legislative/court restrictions in the Restricted States,
hence residents of such Restricted States are prohibited from participating in Rummy and Poker.
Anti-Money Laundering Policy
This Anti-Money Laundering Policy (“AML Policy”) is testimony to the Company’s commitments
against money laundering, financing of terrorism, and related illegal activities. It describes the
Company’s policies and procedures instituted in an attempt to ensure that the Services offered by
the Company are not being used by the Users to facilitate commission of any criminal offences or
violating any Applicable Laws, including but not limited the Prevention of Money Laundering Act
2002 and the Unlawful Activities Prevention Act 1967. Although under the said laws, the Company
does not qualify as an entity obligated to follow the procedures prescribed herein, the Company has
prepared this AML Policy to ensure transparency in the activities conducted from the Account and to
prevent money laundering and other illegal activities over the Platform in consonance with the
This AML Policy applies uniformly to any User desirous of availing the Services or otherwise using
imperative that You read this AML Policy before using the Platform or submitting any personal
and consequently this AML Policy.
1.1 . “Beneficial Owner” means: In case of companies, the natural person who has
over 25% (twenty five per cent) of the shares; is entitled to over 25% (twenty five percent) of the
profits; or has the power, directly or indirectly, to appoint or elect more than half of the board
directors of such company, as the case maybe. In case of partnership firms/limited liability
partnerships, the natural person who has ownership of over 15% (fifteen per cent) of the capital; or
is entitled to over 15% (fifteen per cent) of the profits of such firm, as the case maybe;
1.2 . “Identification Document(s)” refers to: (i) Permanent Account Number (PAN)
(iii) Driving License; (iv) Government issued identity cards; or (v) such other document as may be
notified by the Company from time to time;
“Regulated Entity” shall mean banks, financial institutions or intermediaries who are mandated by
law to maintain records under the provisions of the Prevention of Money-laundering (Maintenance
of Records of the Nature and Value of Transactions, the Procedure and Manner of Maintaining and
Time for Furnishing Information and Verification and Maintenance of Records of the Identity of the
Clients of the Banking Companies, Financial Institutions and Intermediaries) Rules, 2005
1.3 .“Suspicious Transactions” refers to the following activities, whether attempted or executed:
(i) Terrorist financing: transactions which to a Person acting in good faith appear to have
in order to collect funds, in full or in part, by any terrorist or related organization, or
in order to carry
out any of the activities relating to terrorism, or terrorist acts;
(ii) Unusually Complex: transactions which to a Person acting in good faith appear to have
structured in a manner of unusual or unjustified complexity;
(iii) Mala-fide Purpose: transactions which to a Person acting in good faith appear to have
transacted for bona-fide purpose or do not have a sound economic rationale.
(iv) Money Laundering: transactions which to a Person acting in good faith appear to involve
proceeds of any offence listed in the Schedule to the Prevention of Money Laundering Act,
1.4 . The capitalized terms used herein, but not defined, shall have the meaning given to our terms
2. AML Policy Is Part Of Our Terms – This AML Policy is a part of and incorporated within, and is to
3. Policy Changes – The Company may change and update this AML Policy from time to time. Such
changes may be made without prior notice, but any changes will only apply to activities and
information going forward, and not on a retroactive basis. You are encouraged to review this AML
Policy whenever you access the Platform.
4. Your Obligations
4.1 . You acknowledge that it is Your duty to ensure compliance with the terms and conditions
described in this AML Policy and accord Your consent to not using the Services and the Platform in
any manner which results in committing/attempting to commit any criminal offences.
4.2 . You must ensure that any personal information and/or Identification Documents submitted by
You belong to You.
4.3 . You must update any information provided by You basis your Identification Documents within
30 (thirty) days of any change or modification thereof.
4.4 . In case You are acting on behalf of a juridical person, You must identify the Beneficial Owner
and also assist in verification of the identity of such Beneficial Owner and any individual who
purports to act on behalf of such juridical person.
5. Purpose of this Policy – In order to mitigate its risks relating to money laundering and other
activities, the Company intends to put in place this policy which has the following elements:
(i) Customer Acceptance and Verification Terms;
(ii) Risk Management Procedure; and
(iii) Transaction Monitoring Terms
6. Customer Acceptance and Verification Terms
6.1 . The Platform may only be used by Persons who fulfill our eligibility criteria as laid down in
6.2 . Money may be deposited or withdrawn from the concerned Account by a User only by means
of an account maintained with a Regulated Entity. It is clarified that only those Users whose
accounts with the Regulated Entity have been verified by the Regulated Entities in accordance with
the Verifications Rules may deposit or withdraw money from their Account.
6.3 . Users are further required to undergo a KYC verification process whenever they seek to
verification of any User’s identity, the Company will rely on appropriate third-party service
to authenticate the Identification Documents and other incidental details provided by the User.
Users must ensure that they have adhered to the KYC requirements applicable to them with such
third-party service providers (including payment partners) on the Platform.
6.4 . Notwithstanding the foregoing, the Company reserves the right to seek further information
from the Users, including Identification Documents.
6.5 . The Company may, in its sole discretion, refuse to open any new Account, terminate existing
Account after giving due notice, or refuse to process any transactions on the Platforms if it is
to ensure Your compliance with this AML Policy, either due to non-cooperation by the User or due to
the details provided by the User being found unreliable or unverifiable to the Company’s
7. Risk Management Procedure
7.1 . The Company may categorize its Users including You into low, medium or high-risk categories,
after undertaking an appropriate risk assessment of each User based on the following factors
(including without limitation):
(i)Sufficiency and adequacy of identification information submitted by the User;
(ii) User’s social and/or financial status;
(iii) Nature of User’s business/vocational activities; or
(iv) Guidance notes circulated by various governmental and inter-governmental organizations.
7.2 . You acknowledge that in order to maintain the integrity of the risk management procedure, the
Company will keep Your risk categorization and any data related thereto confidential. You will not
entitled to seek disclosure of Your risk categorization. However, the Company may disclose the
User’s risk categorization data to the competent enforcement authority if it finds that a particular
User has executed or is likely to execute any Suspicious Transaction.
8 . Transaction Monitoring Terms
8.1 . All transactions executed and/or attempted to be executed from the Account are regularly
monitored by the Company, both manually and through use of software-based algorithms, in order
to promptly identify and highlight certain kinds of transaction including without limitation, the
following kinds of transactions:
(i) High value transactions of such amounts as may be specified by the Platform from time to
as may be required under Applicable Law;
(ii) Low value but repetitive transaction of such amounts as may be specified by the
time to time or as may be required under Applicable Law; and
(iii) Suspicious Transactions.
8.2 . The Company may, from time to time, undertake necessary investigation in order to identify
and examine transactions inconsistent with any User’s risk profile (determined in accordance with
Clause 7 (Risk Management Procedure) above), sophistication, and expected usage pattern.
8.3 . The extent of monitoring shall depend on various factors including upon each User’s risk
8.4 . The Company may, from time to time, undertake necessary investigation in order to identify
and examine transactions inconsistent with any User’s risk profile (determined in accordance with
Clause 7 (Risk Management Procedure) above), sophistication, and expected usage pattern.
9. Maintenance of Records – The Company will maintain and preserve the following:
(i) Records of all transactions executed on the Platform, for a period of at least 3 (three) years
the date of each transaction.
(ii) Records of all transactions identified under Clause 8 (Transaction Monitoring Terms) above for
period of at least 3 (three) years, including but not limited to the information about the nature,
value and parties to such transactions, and their date of remittance.
(iii) Identification records of Users during the subsistence of and for a period of at least 3
years from the date of termination of such Account.
10 . Compliance, Disclosure, and Notices
10.1 . The Company may share, from time to time, information regarding transactions identified
under Clause 8 (Transaction Monitoring Terms), identification information of such Users, or any
other information mandated under the Applicable Law, with the appropriate enforcement
10.2 . In order to improve the integrity and transparency of transactions on the Platform, You are
encouraged to report any information You are privy to or become privy to in the future regarding
any Suspicious Transactions or transactions You have find or have reason to believe are dubious in
nature, to our Grievance Officer by writing to them at email@example.com
10.3 . In order to ensure compliance with this AML Policy and/or the Applicable Law, the Company
may be required to send You notices from time to time. All such notices will be sent to such
address as provided by You under Clause 6 (Customer Acceptance and Verification Terms) of this
AML Policy. Where You are required to share any information according to the procedures
contained in this AML Policy, such communication may be made by You electronically by sending
an email to firstname.lastname@example.org .