1.1.Rooter Sports Technologies Pvt. Ltd, an Indian company with registered office located at House No. 55, First Floor, East of Kailash, Community Center, New Delhi - 110065, and its technical processors (“Company”,“We”or “Us” or“Our”) are committed to protecting Your privacy and grant importance to the confidentiality of your data over the internet . This privacy policy (“Privacy Policy”) applies to all the content displayed and services offered to persons using or visiting (“Users”,“You” or “Your”) https://www.rooter.gg/; https://www.rootersports.com; https://mobile.rooter.io; (collectively referred to as “Website”) and/or the mobile application under the name and style of Rooter (“App”), altogether collectively known as“Platform”.
1.2.The purpose of this Privacy Policy is to inform the User about the usage/processing of his/her personal data collected when using the services available on the Website/App. For the purpose of this Privacy Policy, we refer to any individual, group of individuals defined under law with whom we have a contractual relationship, including merchants, advertisers, deal partners, brands, businesses etc. as “Business Partners”; to any individual, group of individuals defined under law whose services are used by us in order to provide our intended Services (defined hereinafter) to You through our Platform as “Service Providers” and to our associate, subsidiary, affiliate and/or group companies “Rooter Entities”.
1.3.We believe it is important for You to understand what information we collect from You, how it is used and who will have access to that information. This Privacy Policy sets forth the policy in relation to the collection and usage of all types of Information Collected (specified below) in this Privacy Policy including but not limited to Personal Information (defined hereinafter) including any Sensitive Personal Information (defined below) and User Data (defined hereinafter) that You may provide to us while using our Platform and our related services (collectively “Services”). 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 the User and Us.
1.4.By visiting or using our Platform, domain name and any other linked pages, features, content, or any other services we offer from time to time by in connection therewith, or by using the Services in any manner, You acknowledge that You accept the practices and policies outlined in this Privacy Policy, and You hereby consent to our collection, use and disclosure of Information Collected in accordance with this Privacy Policy. If You are not agreeable to this, please do not use this Platform and/or Services provided by us.
1.5.We collect, use, share, disclose and protect Your personal data provided while using the Services available on the Platform. The data and Information Collected (defined hereinafter) is used only to enhance the operation of the Platform, allowing You to use all the listed features and allowing us to respond to Your requests/queries in an efficient manner. The Personal Information is used strictly in line with our business purposes and to provide You with useful features.
1.6.In this Privacy Policy, “Personal Information” shall mean information through which a User is capable of being identified, directly or indirectly in combination with other information available or likely to be available with us, in particular by reference to User, their name, email address, phone number, username, password, billing address, Internet Protocol (“IP”) address as well as any information associated with the foregoing (“Personal Information”). Personal Information does not include anonymized information that has been appropriately processed to make it non-identifiable in order to irreversibly prevent its identification.
1.7.We respect the privacy of our Users and are committed to protect it in all respects. The information about the User is collected by us as: (i) information supplied by Users; (ii) information automatically tracked during Users navigation on the Platform; and/ or (iii) communicated directly to us via e-mail or telephone or another channel.
1.8.User acknowledges that this Privacy Policy, Terms and Conditions and such other policies as may be framed by us from time to time (as available at our Platform linked above), forms our collective agreement (“Agreement”) with the User in relation to his or her use of the Platform. Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms and Conditions. In the event this Privacy Policy conflicts with the Agreement or any other agreement between You and the Company, the terms of the Terms and Conditions will prevail.
1.9.For any Services that the User may use, we will collect the data that is strictly necessary (i) for the delivery of the Services, (ii) for the performance of a contract for which User is a party, (iii) for which User has given consent for such processing of data, or (iv) for compliance with a legal obligation to which we are subject.
1.10.By using the Platform or by otherwise giving us Information Collected, You will be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and agree to be bound by the Privacy Policy. You hereby consent to our collection, use and sharing, disclosure of Your Information Collected as described in this Privacy Policy. We reserve the right to change, modify, add or delete portions of the terms of this Privacy Policy, at our sole discretion, at any time.
1.11.You further agree that such collection, use, storage, disclosure and/or transfer of Your Information Collected shall not cause any loss to any other person. You acknowledge that anything done, caused to be done, whether expressly or impliedly in contravention of this Privacy Policy may render the User liable for legal action.
2.1.Users (particularly Users outside geographical limits of India) should note that the Information Collected including Personal Information shared with the Company shall be primarily processed in India and such other jurisdictions where a third-party is engaged by the Company which may process the data on Company’s behalf. By agreeing to this Privacy Policy, You are providing the Company with Your explicit consent to collect, share and process Your Information Collected for the purpose(s) defined in this Privacy Policy. The data protection regulations in India or such other jurisdictions mentioned above may differ from those of Your country of residence.
2.1.In case You have any concerns in the processing of Your personal data, please refer to Section 10 (Withdrawal of Consent and Permission) of this Privacy Policy.
In the course of providing Services to You through the Platform, we may collect the following information (collectively “Information Collected”):
3.1.Personal Information such as Your name, phone number, username, password, e-mail address when You register on the Platform, the URL of both the websites You came from and one You go to next when You visit or leave our Services and/or Platform is available to us through Your use of our Services and/or Platform. This type of information is primarily used to maintain security, operation of our Platform along with its use for our internal analytics and reporting purposes.
3.2.Information provided by You on Your e-mail/social media accounts, which will be linked with the account created by You on our Platform, information disclosed therein including but not limited to username as provided by You at the time of sign-up and any other information that may be required or be related to rendering the Services in an efficient and timely manner.
3.3.Information about Your hardware devices may be automatically collected with your permission when You access or register on the Platform. For example, when You utilize our Platform, we may collect Your IP address and the type of mobile device/computer/laptop You use and Your geographic location. We may also collect information about Your activity on the Platform, such as information about Your account usage, as well as information about how You interact with the Platform (collectively, “User Data”). We may combine this User Data with other information, including Personal Information we have collected about You.
3.4.All communications between You and the Company, and related information such as contact details. If the User communicates with us, for example, via e-mail, registers with us, any information provided in such communication may be collected by us.
3.5.Personal Information collected from You by the Company may constitute ‘Personal Information’ as pertaining to “Sensitive Personal Data or Information” , which term is defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”). As defined under SPDI Rules, “Sensitive Personal Data or Information” of a person means “Personal Information” about that person relating to:
3.5.1.passwords;
3.5.2.financial information such as bank accounts, credit and debit card details or other payment instrument details;
3.5.3.physical, physiological and mental health condition;
3.5.4.sexual orientation;
3.5.5.medical records and history;
3.5.6.biometric information;
3.5.7.information received by us or Rooter Entities under lawful contract or otherwise; and
3.5.8.visitor details as provided at the time of registration or thereafter.
3.6.It is clarified that Company will be free to use, collect and disclose information that is freely available in the public domain without Your consent.
3.7.In order to provide Services through the Platform, we may require the User to provide us with certain information that personally identifies himself. This Personal Information includes the following categories of information: contact data (such as email address and/or phone number); and demographic data (such as time zone, postal address and location details), that User may have provided us while using the Services provided by the Platform.
3.8.Information that You upload to, or choose to share through, our Services and/or Platform including profile information, pictures, Your interests, likes and dislikes or any other personal information in data that You upload. For instance, when You get registered on our Platform, You can share with us additional information, such as details of Your personality, lifestyle, interests and other details about You by choosing to provide this information, You consent to our processing of that information.
3.9.All such Information Collected is stored or used for processing Services and under no circumstance are any of these details made available in the public domain, subject to any disclosure(s) made in accordance with this Privacy policy. However, we may use this Information Collected to share with You additional and/ or upcoming information regarding the Services offered by us on the Platform.
3.10.We do not collect or access your contact list without your explicit consent. If you choose to grant permission for our app to access your contact list, we will only use it to enhance your experience with our app, such as to enable you to easily connect with your friends and family who also use the app. We do not share your contact list with any third-party entities, and we do not use it for any marketing or advertising purposes. You have the right to revoke our access to your contact list at any time, and we will immediately cease any collection or use of this data upon your request. Please note that our app may still function without access to your contact list, and we will not penalize or limit your use of our app if you choose not to grant this permission.
4.1.The Platform may transmit Information Collected to the data servers, to ensure the security of data storage collected by us. Accordingly, the User is also subject to the terms of data server’s policy. 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.
4.2.Our Platform may contain links to third party websites or applications. The User agrees and understands that privacy policies of these websites are not under our control and the User understands that once he or she leaves our servers, use of any information provided by the User shall be governed by the privacy policy of the operator of the website used by them.
4.3.Prior to any direct marketing or commercial operation (for example for sending the newsletters or commercial offers), we will first obtain User’s consent, either when creating an account on the Platform or later by indicating Your choice in account settings. Users will always have the right to withdraw his or her consent at any time, directly by clicking on the unsubscribe link available on each email received, by modifying his account settings, or by contacting us at the following email address ‘support@rooter.io’ .
4.4.We may disclose any information we may deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any personal or as otherwise required by law. Such transfer or disclosure shall be for lawful purposes only. Further, such transfer or disclosure of Your Personal Information to other third parties shall only be done once it is ensured that the third party receiving such information has implemented the same level of security practices as we have.
4.5.We take Your right to privacy very seriously and other than as specifically stated in this Privacy Policy, will only disclose Your Personal Information in the event it is required to do so by applicable law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or when Company, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms and Conditions.
5.1.We may use Your Personal Information and User Data including, payment details which includes the cardholder name, credit/debit card number (in encrypted form) with expiration date, banking details, wallet details, etc. as shared and allowed to be stored by You including the information as available in or linked with Your account. This information is presented to the User at the time of making using our Services to enable You to complete Your transactions expeditiously.
5.2.We (and third-party data processors, vendors and hosting partners who may be acting on our behalf including Service Providers, Business Partners and Rooter Entities) may collect, store and process Information Collected for reasons including in particular:
5.2.1.to send confirmations regarding Services either via SMS or WhatsApp or any other messaging service; including sending any updates or changes thereto
5.2.2.to allow our customer service to contact You, if necessary;
5.2.3.to customize the content of our Platform;
5.2.4.to request for reviews of our Platform and/or Services or any other improvements thereto;
5.2.5.send verification message(s) or email(s);
5.2.6.validate/authenticate Your account and to prevent any misuse or abuse;
5.2.7.contact You on Your birthday/anniversary to offer a special gift or offer;
5.2.8.to resolve disputes; troubleshoot problems; help promote a safe service; collect money; measure consumer interest in our products and services or detect and protect us against error, fraud and other criminal activity; enforce our Terms and Conditions; and as otherwise described to You at the time of collection;
5.2.9.to analyse demographic and profile data about our Users' activity on our Platform;.
5.2.10.to help diagnose problems with our data server, and to administer our Platform. Your IP address is also used to help identify You and to gather broad demographic information;
5.2.11.responding to the judicial process and providing information to law enforcement agencies or any government agency in connection with a query/investigation on matters as permitted by law;
5.2.12.allow third parties to contact with You in relation to Services availed/requested by You on our Platform (for the purposes defined in this Privacy Policy) or through third party links;
5.2.13.to identify security breaches and attacks, investigating, preventing and taking action on illegal or suspected fraud or money laundering activities and conducting forensic audits as part of internal or external audit or investigation by any of the Rooter Entities or government agencies located within India or outside jurisdictions;
5.2.14.sharing, disclosing and transfer of data in case of any major event such as merger, acquisition, sale or transfer of assets in case of any force majeure event to any other Rooter Entities or third party;
5.2.15.for data processing, statistical or risk analysis and for analytics and review for improvement of the product/services;
5.2.16.for designing and marketing, our Services and our Rooter Entities products/services;
5.3.In addition, for Marketing Promotions, Research and Programs
5.3.1. Marketing promotions, research and programs help us to identify Your preferences, develop programs and improve User experience. The Company frequently sponsors promotions to give its Users the opportunity to win prizes. Personal Information collected by us for such activities may include contact information and survey questions. We use such Personal Information to notify contest winners and survey information to develop promotions and product improvements. As a registered User, You will also occasionally receive updates from us about fare sales in Your area, special offers, new services, other noteworthy items like merchandise, posters, tshirts, gaming coupons, etc… and marketing programs.
5.3.2.In addition, You may look forward to receiving periodic marketing emails, newsletters and exclusive promotions offering special deals.
5.3.3.We may from time to time launch reward programs by way of which Users may stand to win rewards. We may use Your Personal Information to enroll You in the rewards program and status of the same will be visible each time You log in to the Platform. Depending on the reward program, each time You win a reward, Company may share Your Personal Information with a third party that will be responsible for fulfilling the reward to You. You may however choose to opt out of such reward programs by writing to us. For various purposes such as fraud detection, offering bookings on credit etc., we at times may verify information of customers on selective basis, including their credit information. Additionally, we may share Your Personal Information, anonymized and/or aggregated data to a third party that the Company may engage to perform certain tasks on its behalf, including but not limited to payment processing, data hosting, data processing and assessing credit worthiness for offering bookings on credit.
5.4.Further, the same shall be collected, stored and processed for following reasons:
5.4.1. to make this Platform customized; to provide content tailored to individual requirements; to understand Your needs and provide You with improved Services, newsletters and other communications and to enable others to view submissions/posts and blogs of Users;
5.4.2.to maintain any registered accounts that You may hold with us and to provide You with updates or notifications of changes to Your account;
5.4.3.for our internal record keeping requirements including collection of anonymized details about visitors to our Platform to compile aggregate statistics or produce internal reports;
5.4.4.for any purposes related to the above or where we have a legal right or duty to use or disclose Your Personal Information (including for abuse, crime and fraud prevention and related purposes);
5.4.5.To better understand how the Users access and use our Services, both on an aggregated and individualized basis; and
5.4.6.User posted content may be reused by us to aggregate data about a particular activity or location and include it in consolidated formats.
5.5.If we become aware that we have collected or been sent Personal Information/User Data from a person who is under 18 (eighteen) years of age, without the consent of the parent or guardian, we will deactivate the relevant account as soon as is reasonably practicable by us.
5.6.Your User Data may be disclosed as part of any merger, sale of company assets or acquisition, as well as in the event of insolvency, bankruptcy or receivership, in which Personal Information would be transferred as one of the business assets of the Company.
5.7.Further, in an ongoing effort to better understand and serve the users of our Services, we also often conduct research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents, advertisers, and business partners. This aggregate information does not identify You personally. We may also disclose aggregated User statistics in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes (including providing advertising use cases to actual or potential advertisers).
6.1.Your Information Collected shall be shared with the parties mentioned below who are responsible for fulfilling Services requested by Users on the Platform. You may note that while making use of our Platform with the Company, You authorize us to share Your Information Collected with the said parties in the manner described below:
6.2.In general, we may share:
a) Your Personal Information with our Business Partners / Service Providers / Rooter Entities and relevant third parties only for purpose(s) defined under this Privacy Policy;
b)Personally identifiable information and/or Personal Information provided by You to Business Partners or Service Providers in the course of making transactions;
c)Your Usage Data and other data shall be shared with Service Providers that we work with for services not limited to communication, marketing, data and information storage, transmission, security, analytics, fraud detection, risk assessment, academics.
d)Your data may be shared with the internal investigation department within Rooter Entities or agencies appointed by Rooter Entities for investigation purposes located within or outside India and other jurisdictions.
e)We may share/disclose Personal Information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to court orders, or other legal process. We may disclose the same to law enforcement offices, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to: enforce our Terms and Conditions or Privacy Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our Users or the general public.
f)To the extent permitted by law, we may share information with Rooter Entities for specific purposes not limited to investigation or forensics. The information so provided by You may be shared to Rooter Entities and the third-parties in relation to Services on a need to know basis
6.3.It is pertinent to note that the Company does not authorize the Service Providers / Business Partners to use Your information for any other purpose(s) except as may be for fulfilling their part of Services or as mentioned in this Privacy Policy. However, the manner and purpose for which the said parties use the information shared with them is beyond the purview and control of the Company as they process Personal Information as independent data controllers, and hence we cannot be made accountable for the same. You are therefore advised to review the privacy policies of the respective party whose services You choose to avail.
6.4.Company does not sell or rent individual customer names or other Personal Information of Users to third parties except sharing of such information with our Service Providers / Business Partners and for sharing promotional and other benefits to our customers from time-to-time.
6.5.In the interests of improving personalization and service efficiency, we may, under controlled and secure circumstances, share Your Personal Information with our Rooter Entities. This will enable us to provide You with information which might interest You in relation to the Services; or help us address Your questions and requests in relation to Your use of the Platform.
6.6.If assets of the Company are acquired, our customer information may also be transferred to the acquirer depending upon the nature of such acquisition. In addition, as part of business expansion/development/restructuring or for any other reason whatsoever, if we decide to sell/transfer/assign our business, any part thereof and any of our Rooter Entities, then as part of such restructuring exercise customer information including the Personal Information collected herein shall be transferred accordingly.
6.7.We may also share certain filtered Personal Information with our Service Providers and Business Partners and other corporate affiliates or business partners who may contact the Users to offer certain products or services so as to enable the Users to have better experience with our Platform or to avail certain benefits specially made for our Users. Examples of such partners are entities offering co-branded credit cards, banking cards, etc. If You choose to avail any such services offered by said parties, the services so availed will be governed by the privacy policy of the respective party providing such service.
6.8.We use non-identifiable Personal Information of Users in aggregate or anonymized form to build higher quality, more useful online services on the Platform by performing statistical analysis of the collective characteristics and behavior of our customers and visitors, and by measuring demographics and interests regarding specific areas of the Platform. We may provide anonymous statistical information based on this data to current and potential Business Partners/ Service Providers/ Rooter Entities. We may also use such aggregate data to inform these third parties as to the number of people who have seen and clicked on links to their websites. Any Personal Information which we collect and which we may use in an aggregated format is our property. We may use it, in our sole discretion and without any compensation to You, for any legitimate purpose including without limitation the commercial sale thereof to third parties.
7.1.Company will retain Your Information Collected on its servers for as long as is reasonably necessary for the purposes listed in this Privacy Policy. In some circumstances we may retain Your data for longer periods of time, for instance where we are required to do so in accordance with any legal, regulatory, tax or accounting requirements.
8.1.The security of Your Personal Information and User Data is important to us. We follow generally accepted industry standards to protect the User Data and Personal Information submitted to us, both during transmission and once we receive it. The Website/App may transmit User Personal Information to amazon web services or “AWS” cloud servers and the “Google Cloud Platform” cloud servers, to ensure secure storage of data. Accordingly, the User is also subject to the terms of the AWS and Google Cloud privacy policy. 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 Possession. Finally, this information is used strictly in line with Our business purposes and to provide You with useful features. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. The Information Collected is stored in electronic form but may also be converted to physical form from time to time, if deemed necessary. We take all necessary precautions to protect Your Personal Information both online and off-line and implement reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of our business.
8.2.Although We make best possible efforts to store Personal Information in a secure operating environment that is not open to the public, User must understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of Personal Information. If we become aware that User’s Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify such User of the nature and extent of such disclosure as soon as reasonably possible and as permitted by law.
8.3.For security from Your part, You should:
8.3.1. if using a computer in a public location, always log out and close the website browser when You complete Your online session;
8.3.2.keep Your account details and passwords private;
8.3.3.frequently change Your password;
8.3.4.avoid using the same password for multiple online accounts.
8.4.Depending on the processing of Personal Information, the data may be subject to a different storage period.
8.5.We do not sell User’s Personal Information to any advertisers or any third party. We use User’s Personal Information to display relevant advertisements, based on his preferences. We make reports related to the advertisement campaigns, in particular statistics, without any reference or information related to the Personal Information of visitors or Users of the Platform.
9.1.You may withdraw Your consent to submit any or all Personal Information or decline to provide any permissions on the Platform as covered above at any time. In case, You choose to do so then Your access to the Platform may be limited, or we might not be able to provide the Services to You. You may withdraw Your consent by sending an email to ‘support@rooter.io’
9.2.We also provide all Users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us on behalf of our Service Providers and Partners, and from us in general, after setting up an account. To the extent we use Your Personal Information to market to You, we will provide You the ability to opt-out of such uses.
9.3.You may also review Your Personal Information including any Personal Information shared by You by logging into Our Platform using Your secure login credentials and may notify us in case of any change by contacting us in the manner provided below.
10.1.Company may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way Company treats User’s Personal Information, or in the Privacy Policy itself, Company will display a notice on the Platform or send Users an email, as provided for above, so that You may review the changed terms prior to continuing to use the Services.
10.2.If You object to any of the changes to our Privacy Policy, and You no longer wish to avail the services, You may contact us at email address or address provided hereinbelow to deactivate Your account and for any other issues related to this Privacy Policy. Unless stated otherwise, Company’s current Privacy Policy applies to all information that the Company has about You and Your account.
10.3.If a User uses the Platform, after a notice of changes published on the Platform, such User hereby consents to the changed terms.
10.4.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 from time to time. This Privacy Policy does not require any physical, electronic or digital signature and is a legally binding document between the User and the Company. This document is published in accordance with the relevant provisions of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 which mandates an intermediary to publish rules and regulations, privacy policy and the user agreement for access of its computer resource by any person on its website, mobile based application or both and in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 that require publishing of the privacy policy for collection, use, storage, transfer/ disclose of personal information including Sensitive Personal Information.
The grievance officer shall acknowledge any grievance or complaint received from You within 24 (twenty-four hours) and communicate You regarding the resolution of the same within a period of 15 (fifteen) days from the date of receipt of such grievance or complaint from You. You are expected to provide the grievance officer with all necessary information and/or documents to enable the grievance officer to resolve the issue. You can lodge the Grievance Officer Mr. Akshay Kothari at ‘resident.grievance@rooter.io’
In case You have any queries pertaining to the Privacy Policy or our use of Your Personal Information, You can direct any questions or complaints to us by contacting our designated grievance officer through e-mail at ‘resident.grievance@rooter.io’
We will investigate and attempt to resolve any queries regarding the use or disclosure of Your Personal Information as soon as possible. We try to respond to all legitimate requests within 15 (fifteen) days from date of receipt of the query. Occasionally it may take us longer than the same if Your request is particularly complex or You have made a number of requests. In this case, we will notify You and keep You updated.