Privacy Policy

1. INTRODUCTION

1.1 About Qashpool

Qashpool (“Qashpool”, “we”, “us”, or “our”) operates an online trivia and gaming platform that allows eligible users to participate in quizzes, track their performance, compete on leaderboards, and access related gaming features.

Depending on the services made available, the platform may include user accounts, authentication, gameplay, player profiles, rankings, achievements, rewards, payment processing, and withdrawal facilities.

This Privacy Policy explains how Qashpool collects, uses, stores, shares, protects, and otherwise processes personal data when users visit our website, register for our services, participate in games, communicate with us, or interact with any associated application or service.

For the purposes of this Policy, “Qashpool Services” includes our website, applications, gaming platform, account systems, customer support channels, and other services operated by or on behalf of Qashpool.

1.2 Purpose of This Privacy Policy

We recognise that personal data must be handled responsibly, particularly where a service involves account authentication, age verification, identity documents, financial information, or monetary rewards.

This Policy is intended to explain:

• What personal data we collect.
• Why and how we process personal data.
• How we use information to operate and secure the platform.
• How age and identity verification may be conducted.
• How payment and withdrawal information may be processed.
• When personal data may be shared with third parties.
• How we retain and protect personal data.
• What privacy rights and choices are available to users.
• How users can contact us regarding privacy concerns.

We aim to collect only the information reasonably necessary for specified purposes and to handle that information in accordance with applicable law.

1.3 Scope and Applicability

This Policy applies to individuals who:

• Visit our public website.
• Join a waitlist or submit an enquiry.
• Register for a Qashpool account.
• Access or use our gaming services.
• Participate in quizzes or competitions.
• Appear on leaderboards.
• Apply for rewards or request withdrawals.
• Contact our support or grievance teams.
• Otherwise interact with Qashpool Services.

This Policy also applies to personal data processed by service providers acting on our behalf, to the extent that such processing falls within our responsibility.

This Policy does not automatically govern third-party websites, payment services, identity verification services, or other external services that operate under their own privacy policies.

1.4 Our Commitment to Privacy

We aim to process personal data in a manner that is transparent, proportionate, secure, and consistent with applicable law.

Our privacy practices are guided by the following principles:

• Transparency: Explaining what information we collect and why.
• Purpose limitation: Using information for specified and appropriate purposes.
• Data minimisation: Avoiding unnecessary collection of personal information.
• Accuracy: Taking appropriate steps to maintain accurate information where required.
• Security: Implementing appropriate technical and organisational safeguards.
• Accountability: Maintaining processes to address privacy concerns and comply with applicable obligations.

Nothing in this Policy excludes or limits a right or obligation that cannot lawfully be excluded or limited.

2. INFORMATION WE COLLECT

The information we collect depends on the features a user accesses, the information voluntarily provided, and the verification or legal requirements applicable to the service.

We do not necessarily collect every category described below from every user.

2.1 Personal Identification Information

We may collect personal information such as:

• Full name.
• Username or GamerTag.
• Email address.
• Phone number.
• Date of birth.
• Country or state of residence.
• Other information voluntarily supplied through account forms or support communications.

We use this information to create and manage accounts, communicate with users, personalise the service, and determine eligibility where applicable.

2.2 Account and Authentication Information

Qashpool may use phone-number-based authentication, including one-time passwords (OTPs).

For account creation, login, and security, we may process:

• Phone number.
• OTP verification status.
• Account identifier.
• Username and profile information.
• Account creation and modification timestamps.
• Login timestamps.
• Authentication and security logs.
• Account recovery information.
• Account status and verification status.

We may also maintain technical records necessary to detect suspicious login attempts, prevent unauthorised access, and protect accounts.

We do not intend to request or store a user’s email password, bank password, UPI PIN, or payment-card security credentials as part of ordinary account registration.

Authentication codes and other temporary security information will be handled according to the security and retention requirements of the systems used.

2.3 Age and Eligibility Information

Qashpool is intended for individuals aged 18 and above.

We may collect or process:

• Date of birth.
• Age eligibility declarations.
• Confirmation that a user meets the minimum age requirement.
• Age-verification results.
• Verification timestamps.
• Information about eligibility restrictions.
• Records of failed or incomplete age verification.

This information may be used to prevent ineligible individuals from accessing age-restricted services and to comply with applicable legal requirements.

A user’s self-declared date of birth may not, by itself, be sufficient to establish eligibility for a feature requiring stronger verification.

2.4 Identity Verification Documents and Information

Where identity verification is required, we may collect or arrange the verification of information such as:

• Full legal name.
• Date of birth.
• Government-issued identification information.
• Identity document images, where necessary.
• Document validity and verification results.
• Address information, where required.
• Verification reference numbers.
• Information needed to resolve discrepancies or suspected identity fraud.

Depending on the verification method, an authorised identity verification provider may collect and process these details directly.

Where possible, Qashpool will seek to receive only the information necessary to establish the required verification outcome instead of retaining complete copies of identity documents.

We will describe any material verification requirements at the relevant point in the user journey.

Users should not submit identity documents through unofficial channels or send sensitive documents to personal email addresses or social media accounts claiming to represent Qashpool.

2.5 Financial and Payment Information

Where payment or reward features are legally available and offered, Qashpool may process information relating to financial transactions, including:

• Bank account holder name.
• Bank account details required for an authorised payout.
• IFSC or equivalent payment-routing information.
• UPI ID or other supported payout identifiers.
• Payment transaction references.
• Payment status.
• Reward amounts.
• Withdrawal requests and their status.
• Refund and reversal information.
• Relevant tax information.
• Records of required deductions and statutory reporting.

We may receive this information directly from users or through payment providers.

Where possible, payment credentials and sensitive payment operations will be handled by the relevant payment provider rather than stored directly by Qashpool.

Qashpool will not request a user’s UPI PIN, banking password, or OTP for the purpose of receiving a payout.

2.6 Gameplay and Activity Information

When a user accesses gameplay features, we may collect and process:

• Quiz participation records.
• Questions presented to the user.
• Answers submitted.
• Correct and incorrect answers.
• Answer submission timestamps.
• Response times.
• Scores and scoring calculations.
• Round completion status.
• Game history.
• Leaderboard positions.
• Experience points (XP).
• Streaks and achievements.
• Lives or hearts used.
• Progress through game stages.
• Competition participation records.
• Reward eligibility and results.

We use this information to operate gameplay, calculate results, maintain rankings, investigate disputes, detect manipulation, and improve the user experience.

Where relevant, gameplay records may be retained as evidence of how a score or reward was calculated.

2.7 Device and Technical Information

When users access Qashpool, our systems and service providers may automatically collect certain technical information, including:

• IP address.
• Browser type and version.
• Operating system.
• Device type.
• Device and application identifiers, where available and appropriate.
• Language and regional settings.
• Session information.
• Referral source.
• Access timestamps.
• Error reports.
• Performance and diagnostic information.
• Security events.

We may use this information to maintain platform functionality, troubleshoot technical problems, monitor security, and investigate suspicious activity.

We will apply appropriate restrictions to the use of technical information and will not use it for unrelated purposes without an appropriate basis.

2.8 Location and Regional Information

We may process approximate location or regional information derived from information such as an IP address, device settings, or information voluntarily supplied by a user.

Where necessary and lawful, we may use regional information to:

• Determine whether a service is available in a particular location.
• Apply geographical eligibility restrictions.
• Identify suspicious access patterns.
• Support security and compliance checks.

We will not assume that an approximate IP-based location establishes a user’s legal residence or identity.

We do not intend to collect precise device location unless a specific feature requires it and the applicable legal requirements are satisfied.

2.9 Communication and Support Information

When users contact us, we may collect:

• The content of emails, messages, or support requests.
• Contact details.
• Complaint references.
• Information supplied to investigate a dispute.
• Relevant account and transaction identifiers.
• Support correspondence.
• Records of actions taken to resolve a complaint.

This information is used to respond to enquiries, investigate issues, maintain service records, and address legal or operational concerns.

Users should avoid including unnecessary identity documents, financial credentials, or other sensitive information in ordinary support messages.

2.10 Cookies and Similar Technologies

Qashpool and its service providers may use cookies, local storage, session identifiers, and similar technologies to support website functionality.

These technologies may be used for:

• Maintaining sessions.
• Remembering preferences.
• Supporting authentication.
• Protecting against malicious activity.
• Understanding website performance.
• Measuring the effectiveness of permitted marketing activities.

The specific technologies used will depend on the website and services implemented.

Where consent or another legal requirement applies, we will provide appropriate notices and controls before using the relevant technologies.

2.11 Information Received from Third Parties

Depending on the services used, we may receive information from:

• Authentication providers.
• Identity verification providers.
• Payment and payout providers.
• Fraud prevention and security services.
• Analytics providers.
• Customer support platforms.
• Other service providers acting on our behalf.

Information received may include verification outcomes, transaction statuses, security indicators, or other information necessary to provide the relevant service.

We will handle such information in accordance with this Policy and applicable law.

3. HOW WE COLLECT INFORMATION

3.1 Information Provided Directly by Users

We collect information when users voluntarily:

• Join a waitlist.
• Create an account.
• Complete a profile.
• Verify their age or identity.
• Participate in games.
• Submit a withdrawal request.
• Contact customer support.
• Submit a privacy request or complaint.
• Respond to a survey or feedback request.

Users should ensure that the information they provide is accurate and relates to them.

3.2 Information Collected Automatically

Certain information is generated when users access or interact with Qashpool Services.

This may include session information, technical logs, gameplay events, security events, and diagnostic information.

Automatic collection may occur through our application, website infrastructure, and service providers.

3.3 Information Obtained Through Verification Providers

Where verification is required, we may use an appropriate third-party provider to verify a user’s age, identity, or other eligibility information.

Depending on the service, the provider may return a verification status, a reference number, relevant verified attributes, or additional information required for a legitimate verification purpose.

The precise information processed will depend on the verification method and applicable requirements.

3.4 Information Received from Payment and Service Providers

Where relevant, we may receive information about the status of payments, withdrawals, refunds, or other transactions.

For example, a payment provider may inform us that a transaction has succeeded, failed, been reversed, or requires further verification.

We use this information to reconcile records, update transaction status, and respond to user enquiries.

3.5 Information Collected for Security and Fraud Prevention

We may process account activity, device information, gameplay patterns, and transaction records to identify potential security incidents or violations of our published rules.

Such processing may include identifying unusual login patterns, repeated failed verification attempts, suspected duplicate accounts, automated gameplay, or suspicious payout requests.

Where decisions materially affect a user’s account or financial interests, we aim to maintain appropriate review and complaint-handling procedures.

4. HOW WE USE YOUR INFORMATION

We process personal data only for purposes that are lawful and appropriate to the relevant service.

4.1 Account Creation and Management

We use relevant information to register users, create and maintain accounts, manage profiles, and provide access to Qashpool Services.

4.2 Authentication and Account Security

We use authentication information and security logs to verify access, protect accounts, prevent unauthorised use, and support account recovery.

4.3 Age and Eligibility Verification

We may process age and eligibility information to enforce our minimum-age requirement, determine access to restricted features, and meet applicable legal obligations.

4.4 Identity Verification and Fraud Prevention

Where appropriate, identity information and verification results may be used to confirm that an account belongs to the person claiming it, detect impersonation, prevent duplicate reward claims, and investigate suspected fraud.

4.5 Game Operations and Leaderboard Management

We use gameplay information to deliver quizzes, calculate scores, maintain rankings, record achievements, and provide the features available on the platform.

4.6 Reward Eligibility and Payout Processing

If monetary rewards are legally permitted and offered, we may process relevant gameplay, eligibility, identity, transaction, and payout information to determine whether a user qualifies for a reward and to process authorised payments.

4.7 Payment Reconciliation and Financial Recordkeeping

We may use transaction information to reconcile payments, investigate failed transactions, address discrepancies, maintain appropriate financial records, and meet applicable tax or reporting obligations.

4.8 Customer Support and Grievance Resolution

We process relevant information to respond to enquiries, investigate complaints, resolve disputes, and maintain records of the steps taken.

4.9 Service Improvement and Analytics

We may analyse aggregated or appropriately protected information to understand platform performance, identify technical problems, improve gameplay, and evaluate how users interact with our services.

Where possible, analytics will be conducted using information that does not directly identify individual users.

4.10 Marketing and Promotional Communications

Where permitted by law and consistent with user preferences, we may use contact information to send announcements, product updates, invitations, or promotional communications.

Users may opt out of promotional communications through the available unsubscribe mechanism or by contacting us.

Opting out of promotional communications will not necessarily stop essential account, security, transaction, or legal notices.

4.11 Legal and Regulatory Compliance

We may process information where necessary to comply with applicable laws, lawful requests, tax requirements, regulatory obligations, or binding orders from competent authorities.

4.12 Prevention and Investigation of Misconduct

We may process relevant information to investigate suspected fraud, identity misuse, unauthorised access, manipulation of gameplay, or violations of applicable rules.

Any action taken will be subject to applicable law and our relevant account, security, and dispute procedures.

5. LEGAL BASIS FOR PROCESSING PERSONAL DATA

5.1 Consent

Where consent is required, we will seek it through an appropriate affirmative action after providing information about the relevant processing.

Consent requests will be designed to explain the purpose of processing and the categories of personal data involved.

Consent for optional marketing or other optional activities will be distinguished from information processing necessary to provide a requested service, where appropriate.

5.2 Processing for Permitted and Specified Purposes

We process personal data for the purposes explained in this Policy and any applicable notice presented at the point of collection.

Where processing is based on consent, the relevant purposes and information will be communicated before consent is obtained.

We will not treat acceptance of this Privacy Policy as unlimited permission to process personal data for any purpose.

5.3 Processing Required to Comply with Legal Obligations

Certain information may need to be processed or retained to comply with applicable legal requirements, including relevant financial, tax, security, or recordkeeping obligations.

Where applicable law permits or requires processing without consent, we will rely only on the relevant lawful basis and within its scope.

5.4 Withdrawal of Consent

Where processing is based on consent, users may withdraw their consent through the available mechanism or by contacting us.

Withdrawal will not invalidate processing that was lawfully undertaken before withdrawal.

After receiving a valid withdrawal request, we will stop the relevant consent-based processing unless another lawful basis permits or requires continued processing.

Withdrawal may affect our ability to provide features that genuinely depend on the relevant information.

5.5 Consequences of Withholding Required Information

Some information is necessary to create an account, authenticate access, verify eligibility, or provide a requested feature.

If a user does not provide information that is necessary for a particular service, we may be unable to provide that service or feature.

We will seek to explain the consequences of withholding required information at the relevant point in the user journey.

We will not require optional information merely because it may be commercially useful.

6. AGE RESTRICTIONS AND PROTECTION OF MINORS

6.1 Minimum Age Requirement

Qashpool is intended exclusively for individuals aged 18 years and above.

Individuals under 18 are not eligible to register for or participate in Qashpool’s adult-only competition or access age-restricted reward features.

Users must provide accurate information about their age and must not misrepresent their eligibility.

The use of an adult’s phone number, identity document, bank account, or payment details does not make an underage individual eligible to participate.

6.2 Age Declaration and Verification

During registration or before accessing a restricted feature, we may request a date of birth, age declaration, or other information necessary to establish eligibility.

Where appropriate, we may use an independent verification provider or another lawful verification method.

We may restrict access until verification is completed.

A self-declaration alone may not be sufficient where stronger verification is reasonably necessary to establish eligibility or comply with applicable requirements.

6.3 Handling Information of Suspected or Confirmed Minors

If we become aware of information suggesting that an account belongs to an individual under 18, we may take appropriate protective measures, including:

• Restricting access to the account or affected features.
• Suspending participation in age-restricted competitions.
• Suspending pending reward or payout processing while eligibility is investigated, where legally permissible.
• Requesting proportionate information necessary to resolve the concern.
• Reviewing the account and associated activity.
• Taking steps required by applicable law.

We will assess the information available before taking a final decision where appropriate.

6.4 Suspension and Closure of Underage Accounts

If we reasonably establish that an account belongs to an individual who is not eligible under our minimum-age requirement, we may close the account or restrict access to the affected services.

Any outstanding funds, disputed rewards, or transactions will be handled in accordance with applicable law and the relevant contractual and payment requirements.

We will not assume that the discovery of an underage user automatically permits us to confiscate or permanently retain money.

6.5 Handling Information Collected from Minors

Qashpool does not intend to knowingly collect personal data from individuals under 18 for participation in its adult-only competition.

If we discover that personal data has been collected from an underage user, we will assess the circumstances and take appropriate steps to restrict further processing, delete or otherwise handle the information where required, and address applicable legal obligations.

Information may be retained where retention is required or permitted by applicable law, including where necessary to address a legal claim, investigate suspected fraud, or comply with a lawful obligation.

6.6 Requests from Parents and Legal Guardians

A parent or legal guardian who believes that an underage individual has created an account may contact us through the designated privacy or support channel.

We may request proportionate information to establish the legitimacy of the request.

We will review the concern and take appropriate action in accordance with applicable law.

A parent’s request does not automatically entitle the parent to access all information associated with another individual’s account. We will consider identity, authority, privacy, and applicable legal requirements before disclosing information.

7. IDENTITY VERIFICATION AND KNOW YOUR CUSTOMER (KYC)

7.1 When Identity Verification Is Required

We may require identity verification where reasonably necessary to establish eligibility, prevent impersonation, protect accounts, process permitted payouts, or comply with applicable legal or payment-provider requirements.

Verification requirements may differ depending on the feature being accessed and the level of risk involved.

7.2 Types of Identification Information Accepted

Depending on the applicable requirements and verification method, we may request an appropriate government-issued identity document or other reliable information capable of establishing the required identity or age attributes.

We will communicate the accepted verification methods through the relevant interface or verification process.

Users should submit only documents and information requested through authorised channels.

7.3 Verification Through Third-Party Providers

Qashpool may engage an appropriate third-party verification provider to verify age, identity, or eligibility.

Depending on the arrangement, the provider may collect and process documents directly and return the verification result to Qashpool.

Where possible, we will seek to minimise the information received and retained by Qashpool.

Third-party verification providers may process information under their own contractual obligations and applicable privacy notices. We will identify relevant providers where appropriate.

7.4 Verification Failures and Inconsistent Information

If the information provided cannot be verified, appears inconsistent, or raises a legitimate concern about identity or eligibility, we may request clarification or additional verification.

Access to the relevant feature may be restricted while the issue is resolved.

We will seek to provide an appropriate explanation and review mechanism, subject to legitimate security, fraud-prevention, and legal considerations.

7.5 Identity Verification for Withdrawals

Where monetary withdrawals are legally permitted and offered, we may require verification before processing a payout.

We may need to establish that the person requesting the withdrawal is eligible to receive the relevant funds and that the proposed payment destination satisfies applicable requirements.

A third party’s willingness to receive a payout does not, by itself, establish the eligibility of the person who participated in the game.

7.6 Secure Handling of Identity Documents

Identity documents contain sensitive personal information and will be handled with appropriate care.

Where feasible, we will use secure verification systems and avoid retaining complete document images when a verified result is sufficient.

Access to identity information will be limited to authorised personnel and service providers who require it for a legitimate purpose.

We will not publish identity documents or make them visible on public leaderboards.

7.7 Retention and Deletion of Verification Information

Verification information will be retained only for as long as reasonably necessary for the purpose for which it was collected, subject to applicable legal, regulatory, security, and recordkeeping requirements.

Where full documents are not required for continued retention, we may retain a verification status or reference instead.

The specific retention periods will depend on the verification process and applicable obligations.

8. FINANCIAL AND PAYMENT INFORMATION

8.1 Collection of Payment and Payout Details

Where payment or reward features are legally available, we may collect the information necessary to initiate, verify, process, and reconcile the relevant transaction.

The information requested will depend on the payment method and applicable requirements.

We will seek to avoid collecting financial information that is not necessary for the transaction.

8.2 Bank Account and UPI Information

Where supported, users may be asked to provide bank account or UPI information for authorised transactions.

Such information will be used for the relevant payment, payout, verification, reconciliation, or compliance purpose.

Users must ensure that the details submitted are accurate and that they are authorised to use the relevant payment destination.

Qashpool will not ask users to disclose their UPI PIN, internet banking password, or OTP to receive a payout.

8.3 Payment Processing Through Third Parties

Transactions may be processed through authorised payment providers, banks, or other financial service providers.

These providers may independently process information necessary to execute transactions, prevent fraud, and comply with their legal obligations.

Their processing will also be subject to their applicable terms and privacy notices.

8.4 Financial Transaction Records

We may maintain records of relevant payments, rewards, withdrawals, refunds, reversals, and transaction statuses.

These records may be used to reconcile accounts, investigate discrepancies, respond to disputes, and comply with applicable recordkeeping obligations.

8.5 Tax-Related Information and Statutory Reporting

Where applicable, we may collect or process tax identification information, transaction values, reward records, and other information necessary to calculate or report legally required tax deductions.

We may share relevant information with competent authorities where required by law.

The specific tax treatment of rewards will depend on applicable law and the final structure of the relevant service.

8.6 Fraud Detection and Suspicious Transactions

We may review relevant transaction information to detect suspicious payout requests, unauthorised transactions, identity mismatches, duplicate claims, or other indicators of potential fraud.

Where legally permissible, we may request additional verification or temporarily restrict a transaction while a legitimate concern is investigated.

Any resulting decision will be handled under the applicable terms, security procedures, and legal requirements.

9. COOKIES, ANALYTICS, AND TRACKING TECHNOLOGIES

9.1 Essential Cookies

We may use essential cookies or similar technologies to support website functionality, authentication, session management, and security.

These technologies may be necessary for certain features to operate correctly.

9.2 Analytics and Performance Technologies

Where implemented, analytics technologies may help us understand website usage, identify errors, measure performance, and improve the service.

The information collected may include page visits, session events, technical diagnostics, and general usage patterns.

Where required, we will obtain consent before using the relevant technologies.

9.3 Advertising and Marketing Technologies

If Qashpool introduces advertising or marketing technologies, those technologies may collect information about interactions with campaigns or website content.

We will provide appropriate disclosures and obtain consent where required by applicable law.

We will not assume that consent to essential website functionality also constitutes consent to optional advertising or tracking.

9.4 Cookie Preferences and User Controls

Where applicable, users may manage optional cookies through the controls made available on the website or through their browser settings.

Disabling certain cookies may affect website functionality.

The actual cookie categories, providers, and controls will be reflected in the implementation and any applicable cookie notice.

10. HOW WE SHARE YOUR INFORMATION

Qashpool does not sell personal data as a standalone product.

We may share personal data where necessary for the purposes described in this Policy, subject to applicable law and appropriate safeguards.

10.1 Service Providers and Technology Partners

We may share relevant information with providers that support our operations, including hosting, infrastructure, authentication, analytics, customer support, communication, and security services.

These providers will receive information appropriate to the services they perform.

Where required, we will put suitable contractual and security arrangements in place.

10.2 Identity Verification Providers

We may share relevant information with identity or age verification providers to establish eligibility, verify identity, or prevent misuse.

The information shared will depend on the verification method and purpose.

10.3 Payment and Banking Partners

Where transactions are legally permitted, relevant information may be shared with payment providers, banks, and other financial service providers to process payments, withdrawals, refunds, and related verification.

10.4 Analytics and Security Providers

We may share relevant technical or usage information with analytics, monitoring, and security providers to improve performance, identify vulnerabilities, detect suspicious activity, and protect the platform.

Where possible, we will use aggregated or minimised information.

10.5 Legal and Regulatory Authorities

We may disclose information to a competent authority where required by applicable law, a valid legal process, or a binding order.

We may also disclose information where necessary to meet applicable legal obligations or protect rights and safety, to the extent permitted by law.

10.6 Fraud Prevention and Investigation

We may share relevant information with appropriate service providers or competent authorities when necessary to investigate suspected fraud, identity theft, unauthorised access, or other unlawful conduct.

Any disclosure will be limited to what is appropriate for the relevant purpose and permitted by applicable law.

10.7 Corporate Restructuring, Mergers, or Acquisitions

If Qashpool undergoes a merger, acquisition, restructuring, financing transaction, or transfer of business assets, relevant information may be disclosed to the parties involved where legally permissible and subject to appropriate safeguards.

Any successor handling personal data will be required to comply with applicable legal obligations.

10.8 Publicly Displayed Information and Leaderboards

Qashpool may display certain player information publicly where this is an intended feature of the service.

For example, a leaderboard may display a GamerTag, score, ranking, XP, or achievement.

We will seek to avoid publicly displaying personal information such as phone numbers, email addresses, identity documents, bank details, or verification records.

Users should choose a GamerTag that does not unnecessarily reveal their real name or other private information.

The information displayed and the applicable controls will depend on the features implemented.

11. DATA STORAGE, RETENTION, AND DELETION

11.1 Where Personal Data Is Stored

Personal data may be stored in systems operated by Qashpool or by authorised service providers.

The location of storage may depend on the infrastructure, verification, communication, and payment services used.

We will assess applicable data-location and transfer requirements and implement the necessary arrangements.

11.2 Data Retention Principles

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected or as required or permitted by applicable law.

Retention decisions may take into account:

• The duration of the user’s account.
• The need to provide requested services.
• Security and fraud-prevention requirements.
• Financial and tax recordkeeping obligations.
• Pending complaints or disputes.
• Legal claims or investigations.
• Applicable statutory retention periods.

We will not treat indefinite retention as the default for every category of information.

11.3 Retention of Account Information

Account information may be retained while an account remains active and for an appropriate period afterward where necessary for security, dispute resolution, legal compliance, or other legitimate purposes.

The precise retention period will depend on the category of information and applicable requirements.

11.4 Retention of Identity Verification Records

Identity documents and verification results may be retained for different periods depending on their purpose.

Where a complete document is no longer necessary, we may delete it while retaining a limited verification record where justified.

11.5 Retention of Financial and Transaction Records

Financial and transaction records may need to be retained after an account is closed to meet applicable tax, accounting, payment, or legal obligations.

Such records will be handled with appropriate access restrictions.

11.6 Deletion and Anonymisation of Personal Data

Where applicable, users may request deletion of personal data or deletion of their account.

We will assess and process valid requests in accordance with applicable law.

Where appropriate, information may be anonymised so that it can no longer reasonably be associated with an identifiable individual.

11.7 Exceptions to Deletion Requirements

Some information may need to be retained where required or permitted by applicable law.

Examples may include records necessary to comply with legal obligations, resolve a dispute, investigate suspected fraud, establish or defend a legal claim, or maintain mandatory financial records.

Where continued retention is necessary, we will seek to limit access and use the information only for the relevant purpose.

12. DATA SECURITY

12.1 Technical and Organisational Security Measures

We aim to implement reasonable and appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, loss, misuse, or destruction.

The safeguards used will depend on the nature of the information, the risks involved, and the systems through which it is processed.

12.2 Encryption and Access Controls

Where appropriate, security measures may include encryption in transit and at rest, access restrictions, secure authentication, and monitoring of access to systems containing personal data.

The specific controls will depend on the systems implemented and their technical capabilities.

12.3 Protection of Identity and Financial Information

Access to identity documents, verification results, financial information, and other sensitive operational records will be restricted to authorised personnel and service providers who require access for a legitimate purpose.

We aim to avoid storing unnecessary copies of identity documents or payment credentials.

12.4 Employee and Contractor Access

Personnel who access personal data for Qashpool’s operations should be authorised to do so and subject to appropriate confidentiality and security obligations.

Access should be limited according to operational responsibilities.

12.5 Security Monitoring and Audit Logs

Where implemented, we may maintain security logs and audit trails relating to account access, verification activity, administrative changes, and relevant transactions.

These records may help us investigate security incidents, unauthorised changes, or suspected fraud.

12.6 Data Breach Detection and Response

If we become aware of a personal data breach, we will assess the incident and take appropriate steps to contain it, investigate its cause, mitigate potential harm, and prevent recurrence.

12.7 Notification of Personal Data Breaches

Where notification is required by applicable law, we will notify the relevant individuals and authorities within the applicable timeframes and in the required manner.

We will also take appropriate remedial steps and cooperate with competent authorities where required.

No digital system can be guaranteed to be completely secure. However, we aim to implement safeguards appropriate to the risks associated with the information we process.

13. INTERNATIONAL DATA TRANSFERS

13.1 Use of International Service Providers

Some service providers may process or store personal data in countries outside India.

Whether this occurs will depend on the providers and infrastructure used by Qashpool.

13.2 Cross-Border Data Transfers

Where personal data is transferred outside India, we will assess and comply with applicable legal restrictions, government directions, and other requirements.

13.3 Applicable Restrictions and Safeguards

Where necessary, we will implement appropriate contractual, technical, and organisational safeguards for cross-border processing.

We will not represent that all data is stored exclusively in India unless our actual infrastructure and service-provider arrangements support that statement.

14. YOUR PRIVACY RIGHTS

Subject to applicable law and the commencement of the relevant legal provisions, users may have rights concerning their personal data.

14.1 Right to Access Information

Users may request information about the personal data processed by Qashpool and the purposes of processing, to the extent such access is available under applicable law.

14.2 Right to Correction and Updating

Users may request correction of inaccurate or misleading personal data and updating of incomplete information where applicable.

We may require reasonable verification before changing information associated with an account.

14.3 Right to Erasure, Where Applicable

Users may request erasure of personal data where the applicable legal requirements are satisfied.

Certain records may need to be retained to meet legal obligations, resolve disputes, investigate suspected fraud, or satisfy other lawful requirements.

14.4 Right to Withdraw Consent

Where processing is based on consent, users may withdraw consent through the available mechanism or by contacting us.

Withdrawal will be handled in accordance with applicable law.

14.5 Rights Relating to Grievances

Users may raise concerns about how their personal data is collected, used, stored, or shared.

We will provide a process for submitting and resolving privacy-related grievances.

14.6 Account Deletion and Its Consequences

Users may request deletion of their account through the available account settings or by contacting the designated support channel.

Before completing a request, we may need to verify the requester’s identity and explain any material consequences.

Deleting an account may result in the loss of access to profile information, gameplay history, achievements, and other account features.

Any outstanding transactions or legally required records will be handled in accordance with applicable law and the relevant contractual arrangements.

Account deletion does not automatically erase information that must lawfully be retained.

14.7 Exercising Your Privacy Rights

Users may submit privacy requests through the designated privacy contact or any account-level mechanism made available by Qashpool.

We may request information reasonably necessary to verify the identity and authority of the requester.

We aim to respond within the timeframes required by applicable law.

If a request cannot be fully fulfilled, we will explain the relevant reason where legally required and provide any applicable complaint or escalation route.

15. MARKETING AND COMMUNICATION PREFERENCES

15.1 Service-Related Communications

We may send communications necessary to operate the service, including account verification messages, security alerts, transaction updates, important service announcements, and responses to support requests.

These communications may continue even if a user opts out of promotional messages, where they remain necessary for the service or required by law.

15.2 Promotional Emails and Messages

Where permitted by law and consistent with the applicable consent or communication requirements, we may send product announcements, launch invitations, updates, or promotional content.

15.3 WhatsApp and SMS Communications

Qashpool may use WhatsApp, SMS, or similar channels for communications such as waitlist invitations, account-related notices, or promotional messages where permitted.

Messages may be delivered through third-party communication providers, which may process relevant contact and delivery information.

Users should review the relevant communication settings and notices where provided.

15.4 Opting Out of Marketing Communications

Users may opt out of promotional communications using the unsubscribe mechanism, available account settings, or the instructions provided in the communication.

Where appropriate, users may also contact us to request removal from promotional mailing lists.

Opting out of marketing does not necessarily stop essential account, security, transaction, or legally required communications.

16. THIRD-PARTY WEBSITES AND SERVICES

16.1 External Links

Qashpool may contain links to third-party websites, applications, or services.

These links may be provided for convenience or to enable a particular service.

16.2 Third-Party Privacy Policies

Third-party services may operate under their own privacy policies, terms, and security practices.

We encourage users to review those policies before providing personal information directly to an external provider.

16.3 Responsibility for Third-Party Services

Qashpool is responsible for its own processing of personal data in accordance with applicable law.

We do not automatically control the privacy practices of independent third-party services. However, where a provider processes personal data on our behalf, we will seek to establish appropriate contractual and security arrangements.

17. CHANGES TO THIS PRIVACY POLICY

17.1 Updates and Revisions

We may update this Policy to reflect changes in our services, data-processing practices, technology, legal obligations, or operational requirements.

17.2 Notification of Material Changes

Where appropriate or required by law, we will notify users of material changes through the website, email, in-product notifications, or another suitable channel.

Where renewed consent or another affirmative action is legally required, we will obtain it before undertaking the relevant processing.

17.3 Effective Date of Changes

The latest version will display its effective date and last-updated date.

A revised Policy will apply from its stated effective date, subject to applicable law.

We will not rely on a revised Policy to retrospectively authorise processing that was unlawful when it occurred.

18. GRIEVANCE REDRESSAL AND PRIVACY COMPLAINTS

18.1 Privacy Contact and Grievance Officer

Users may contact Qashpool regarding privacy concerns, requests to exercise privacy rights, suspected misuse of personal data, or complaints about our handling of information.

The designated contact details will be published below and updated when necessary.

Privacy Contact: hello@qashpool.com
Grievance Officer: Afthab Ahammed (hello@qashpool.com)

Where applicable law requires a designated grievance officer or other responsible person, Qashpool will provide the required details and comply with the applicable obligations.

18.2 Submitting a Privacy Complaint

A complaint should include sufficient information to help us understand and investigate the issue.

Where appropriate, users should provide:

• A description of the concern.
• The relevant account identifier.
• The type of personal data involved.
• The approximate date of the incident.
• Any relevant support or transaction reference.

Users should not send passwords, OTPs, UPI PINs, or unnecessary identity documents in ordinary complaint messages.

18.3 Complaint Handling and Resolution

We will review privacy complaints and take appropriate steps to investigate them.

Where appropriate, we may request additional information, verify the identity of the requester, or refer the matter to the relevant internal team or service provider.

We aim to communicate the outcome within the timeframe required by applicable law or our published complaint-handling procedure.

18.4 Escalation Under Applicable Law

If a user is dissatisfied with the handling of a privacy complaint, the user may exercise any applicable escalation or appeal rights available under Indian law.

Where applicable, the relevant statutory authority or dispute-resolution mechanism will be identified through the appropriate official channels.

Nothing in this Policy prevents a user from exercising a statutory right or approaching a competent authority where permitted by law.

19. CONTACT INFORMATION

19.1 Qashpool’s Legal Entity Details

Qashpool is operated by:

Legal Entity Name: Wisebox Pvt Ltd
Brand Name: Qashpool
Official Website: https://qashpool.com

19.2 Privacy-Related Contact Information

For questions about this Policy or the handling of personal data:

Email: hello@qashpool.com

Users should use this channel for privacy-related enquiries, access requests, correction requests, deletion requests, and concerns about personal information.

19.3 Data Protection and Grievance Contact

For formal privacy complaints or grievances:

Designated Contact: Afthab Ahammed, Grievance Officer
Email: hello@qashpool.com

We will update these details if the responsible person or contact information changes.

20. DEFINITIONS AND INTERPRETATION

20.1 Definitions of Key Terms

For the purposes of this Policy:

Account means a registered user profile or other account used to access Qashpool Services.

Applicable Law means the laws, rules, regulations, directions, and binding legal requirements applicable to Qashpool and the relevant processing activity.

Personal Data means information about an identifiable individual, as defined under the applicable data-protection framework.

Processing includes collecting, recording, organising, storing, using, sharing, disclosing, updating, retrieving, restricting, or deleting personal data.

User means an individual who visits, registers for, or otherwise interacts with Qashpool Services.

Verification Provider means a third party engaged to perform age, identity, eligibility, or other verification services.

Service Provider means a third party that provides technology, hosting, communication, payment, analytics, security, verification, or other services to Qashpool.

Qashpool Services means the website, applications, gaming platform, account systems, and other services operated by or on behalf of Qashpool.

20.2 Interpretation of This Policy

This Policy should be read together with any applicable notice provided when personal data is collected.

If a provision of this Policy conflicts with a mandatory requirement of applicable law, the applicable legal requirement will prevail to the extent of the conflict.

Nothing in this Policy creates a right to participate in a game, receive a reward, or use a payment feature that is unavailable or prohibited under applicable law or the relevant terms of service.