Privacy Policy

1. Introduction

Welcome to TKGem ("TKGem", "we", "our", "us"). Your privacy matters to us. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our website, mobile applications, and services (collectively, the "Platform"). By accessing or using the Platform, you consent to the practices described in this policy.

We are committed to safeguarding your personal information using industry-standard security technologies, transparent data practices, and clear privacy controls. This policy applies to all users in India and outlines rights consistent with international best practices.

2. Scope & Definitions

This policy covers personal data processed by TKGem in connection with operating the Platform, including account creation, gameplay, payments, customer support, promotions, and analytics. "Personal data" means any information that can identify you directly or indirectly, such as your name, contact details, device identifiers, or transaction records.

It does not cover third-party websites or services linked from our Platform. We encourage you to review their privacy policies separately before interacting with them.

3. Data We Collect

• Account Information: Name, email, mobile number, date of birth, address, and password.
• KYC Documents: Aadhaar, PAN, Passport, Driver's License, and proof of address.
• Payment Data: UPI ID, bank account details, card tokens, transaction history.
• Gameplay & Activity: Games played, session durations, preferences, achievements, and interactions.
• Device & Technical: IP address, device identifiers, OS version, browser type, app version, crash logs.
• Cookies & Tracking: Cookie identifiers, pixels, local storage, and similar technologies.
• Support Interactions: Chat transcripts, emails, call recordings where lawful.
• Marketing Preferences: Opt-in status, communication choices, and campaign interactions.

We collect data directly from you during registration and use of the Platform, and automatically via cookies and analytics tools. In limited cases, we may receive data from payment providers, anti-fraud partners, or identity verification services.

4. How We Use Data

• Provide Services: Create and manage accounts, enable gameplay, process payments, and deliver support.
• Security & Fraud Prevention: Authenticate users, detect suspicious activity, enforce policies, and protect the Platform.
• Improve Experience: Personalize content, recommend games, optimize performance, and fix bugs.
• Communications: Send transactional updates, important notices, and with consent, marketing communications about offers and promotions.
• Compliance: Meet legal obligations including record-keeping, tax, KYC/AML, and dispute resolution.

5. Legal Bases for Processing

We process personal data based on one or more of the following legal grounds:

• Consent: Where you explicitly agree to certain processing such as marketing, cookies, or optional features.
• Contractual Necessity: To provide services under our Terms of Service and fulfill transactions.
• Legal Obligations: To comply with applicable laws including KYC/AML requirements and tax regulations.
• Legitimate Interests: To improve services, ensure security, prevent fraud, and personalize user experience, balanced against your rights.

6. KYC & Verification

To maintain a safe and compliant platform, we may request identity and address verification using government-issued documents. Verification helps prevent fraud, underage gaming, and misuse of payment methods. Some features like withdrawals may require successful KYC completion.

We store KYC information securely with restricted access and retain only as long as necessary for compliance. Where lawful, we may use third-party verification services to validate documents.

7. Cookies & Tracking Technologies

Cookies are small files stored on your device to remember preferences and enable core functionality. We use:

• Essential Cookies: Required for login, session management, and security.
• Preference Cookies: Save settings like language and display options.
• Analytics Cookies: Measure usage, performance, and engagement.
• Advertising Cookies: Show relevant offers and track campaigns, only with consent.

You can manage cookie preferences via browser settings or in-platform controls. Disabling essential cookies may affect core functionality.

8. Analytics & Advertising

We use analytics tools to understand how the Platform is used, diagnose issues, and improve features. These tools may collect pseudonymous identifiers, device data, and interaction metrics. Where enabled, advertising partners may use cookies or pixels to measure campaigns and avoid showing you irrelevant ads.

We avoid invasive tracking and do not sell your personal data. You can opt out of marketing communications at any time.

9. Data Sharing & Third Parties

We may share limited data with trusted partners to provide and improve services, including payment processors, cloud hosting providers, analytics vendors, customer support tools, identity verification services, and anti-fraud partners.

All partners are required to implement strong security measures and use data only for authorized purposes. We do not sell personal data.

10. Security Measures

We employ multi-layered security including 256-bit SSL encryption, firewalls, access controls, hashing, tokenization, and regular security audits. We limit access to personal data to trained personnel on a need-to-know basis and maintain secure development practices.

While no system can be 100% secure, we work continuously to improve our defenses and promptly address vulnerabilities.

11. Data Retention

We retain personal data only as long as necessary to provide services, meet legal obligations, resolve disputes, and enforce agreements. Retention periods vary by data type and legal requirements. When data is no longer needed, we delete or anonymize it.

12. Your Privacy Rights

• Access: Request a copy of the personal data we hold about you.
• Correction: Ask us to fix inaccurate or incomplete information.
• Deletion: Request deletion of certain data subject to legal exceptions.
• Restriction: Limit processing in specific scenarios.
• Objection: Object to processing based on legitimate interests or direct marketing.
• Portability: Receive data in a structured, commonly used format.
• Consent Management: Withdraw consent for optional processing at any time.

To exercise rights, contact us using the details below. We may need to verify your identity before fulfilling requests.

13. Preferences & Opt-Out

Manage your communication preferences in your account settings. You can opt out of marketing emails, SMS, and push notifications, while still receiving important transactional updates about your account and security.

Cookie preferences can be updated via the in-platform banner or your browser settings.

14. Children's Privacy

TKGem does not knowingly collect or process data from individuals under 18. If we discover that a minor has provided personal information, we will delete it promptly. Parents or guardians who believe a minor has used the Platform should contact us immediately.

15. International Transfers

Where data is transferred across borders for processing (for example, to global cloud providers), we implement safeguards aligned with industry standards and contractual protections to ensure equivalent protection levels.

16. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in laws, technology, or our practices. Material changes will be communicated via in-platform notices or email. The latest version will always be available on this page.