(Effective and Last Updated as on: 20th July, 2024)

Introduction

• Welcome to Param Enterprises("Us" or "Our" or "We" or "Turfwala") website- https://turfwala.com/ ("Website"), including any website which is owned and developed by Us for Our specific partner to give such partner an exclusive platform for its listing of its events/sport sessions etc. ("Brand Page") and mobile application ("Mobile Application") (hereinafter collectively referred to as "Platform"). We operate under the brand name Turfwala and are engaged in organising sports and other recreational events as well as providing an internet-based booking platform for and in connection with Our as well as third party sports and other recreational events and sports facilities and venues through Our Platform either by Our self or through Our subsidiaries, affiliates or third-party service providers ("Primary Services"). On our mobile application, we may also provide ways for you to communicate with other Turfwala users including through messages, [voice and video calls, sending images and video, showing your status, sharing your location with others when you choose and hosting games] ("Secondary Services"). For the purposes of this policy, Primary Services and Secondary Services shall collectively referred to as Services.
• We care about the privacy of the users of Our Platform ("Users") such as yourself. We respect the information that you provide to Us, and want to be sure you fully understand exactly how We use that information. By accepting the Terms of Service provided at terms-and-conditions ("Terms of Service"), you are also agreeing to this privacy policy ("Privacy Policy").
• You understand that by using the Services via any Platform you consent to the collection, use and disclosure of your personal information and aggregate data as set forth in Our Privacy Policy, and to have your personal information collected, used, transferred to and processed in accordance with this policy. If you do not wish to agree with terms of Our Privacy Policy, We kindly request you not to use Our Platform.
• This Privacy Policy does not apply to the practices of companies or entities that We do not own or control, or to individuals that We do not employ or manage

Security

• Turfwala uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information and implement your privacy settings. However, We cannot guarantee that unauthorized third parties will never be able to defeat Our security measures or use your personal information for improper purposes. In the event where you believe your privacy has been breached, please contact Us immediately.
• We want to reduce loss, theft, misuse, unauthorized access, disclosure, alteration, destruction, harassment, and abuse related to Our Platform, but We cannot guarantee complete perfection. When there is clear evidence of any of the above, We will do Our best to respond promptly. You acknowledge that you provide your personal information at your own risk.
• We may transfer the information described in this Privacy Policy to, and process and store it in, India and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, We will take appropriate measures to protect your personal information in accordance with this Privacy Policy. We will take steps to reasonably ensure that the receiving jurisdiction has in place a standard of protection accorded to personal data that is comparable to the protection under India's data protection laws.
• We may sub-contract processing activities to third parties include—record keeping, data analysis, marketing assistance, processing payments, and providing customer service.
• You undertake to treat your password and other confidential information in relation to the use of Our Platforms and its Services confidentially, and We disclaim any liability arising from your failure to do so.
• The collection, storage, usage, and sharing of your data by the Company shall be in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws.
• We have taken appropriate steps for the security and protection of all Our digital platforms including internal applications, however, We shall not be responsible for any breach of security or the disclosure of personal data for reasons outside Our control, such as hacking, social engineering, cyber terrorism, espionage by third parties etc.

Platform Permission

• Most mobile platforms such as iOS, Android, etc. ("Mobile Platform") have defined certain types of device data that apps cannot access without your consent. And these Mobile Platforms have different permission systems for obtaining your consent. For example, the iOS platform will alert you the first time the Mobile Application wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Mobile Application seeks before you first install or use the app, and your use of the app constitutes your consent.

Collection of Information

• Turfwala collects information about you when you use Our Services and through other interactions and communications you have with Us.
• We collect information you provide directly to Us, such as when you create or modify your account, request on-demand services, contact customer support, use of any related services connected to Turfwala or participate in contests and surveys, or otherwise participate in activities We promote that might require information about you or complete contact forms or request newsletters or other information from Us (for instance via email) or otherwise communicate with Us. This information may include name, email, phone number, postal address, profile picture, items and quantities requested, delivery notes, and other information you choose to provide.
• When you use Our Primary Services, We collect information about you in the following general categories:

  Personal information:

  • We collect information about you (such as email address, name, username or other relevant unique identifier, mobile phone number, location, date of birth, gender identity etc.) from you when you set up a free account with Us.
  • When you complete your profile, you can share with Us additional information, such as details on your favourite sports, interests in particular venues and events, corporate profile details and other details about you, as well as content such as photos. To add certain content, like pictures, you may allow Us to access your camera or photo album. By choosing to provide this information, you consent to Our processing of that information.
  • You may be able to use your social media login (such as Facebook login) or Google login to create and log into your Turfwala account that allows you to share some information from your social media account or google account with Us.
  • While you may be able to browse some sections of Our Platform without being a registered member, certain activities (such as placing an order) do require registration. We may use your contact information to send you offers based on your previous orders and your interests.
  • In accordance with Our Terms of Service, Your photograph may be clicked (either as single photo or in group with other users) or audio-videos may be made/created during a class/session in fitness centres/venues or at an event or during usage of any third party websites or applications while taking fitness session or attending any event using or through Our Primary Services ("Photos and Videos"). Such Photos and Videos may be clicked/made/captured by the venue/centre managers, or any individual authorised by Turfwala's personnel or venue managers.

  Financial information:

  • If you transact with Us directly or through Our partners (for instance, you pay the booking amount to Our venue partner directly while making booking through Our Platform) or through entities engaged by Us providing financial services, We collect some additional information, such as a billing address, credit / debit card number and a credit / debit card expiration date and/ or other payment instrument details and tracking information.

  Location information:

  • When you use the Services, We collect precise location data about the location of the device from the Platform used by the User. If you permit any of Our Platform to access location services through the permission system used by your mobile/web platform, We may also collect the precise location of your device when the Mobile Application or the Platform is running in the foreground or background. We may also derive your approximate location from your IP address.

  Transaction information:

  • We collect transaction details related to your use of Our Primary Services, including the type of service requested, date and time the service was provided, amount charged, product supplied, and other related transaction details. Additionally, if someone uses your promo code, We may associate your name with that person.

  Device information:

  • We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.

  Call and SMS Data:

  • Our Services may facilitate communications between Users and Our designated support staff ("Support Staff"). In connection with facilitating this service, We receive call data, including the date and time of the call or SMS message, the parties phone numbers, and the content of the SMS message.

  Log information:

  • When you interact with the Services, We collect server logs, which may include information like device IP address, access dates and times, Mobile Application features or Website (including Brand Page) pages viewed, Mobile Application crashes and other system activity, type of browser and the third-party site or service you were using before interacting with Our Services.

  Information collected by cookies and other tracking technologies:

  • We use various technologies to collect information, and this may include sending cookies to your computer/device. Cookies are small data files stored on your hard drive or in your device memory that helps Us to improve Our Services and your experience, see which areas and features of Our Services are popular and count visits. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of Our Services. Further, We may also collect information using web beacons (also known as tracking pixels). Web beacons are electronic images that may be used in Our Services or emails and to track visits or understand usage and campaign effectiveness.

  Other information:

  • When you participate in surveys or focus groups, you give Us your insights into Our products and services, responses to Our questions and testimonials.
  • When you choose to participate in Our promotions, events or contests, We collect the information that you use to register or enter.
  • If you contact Our customer care team or Support Staff, We collect the information you give Us during the interaction. Sometimes, We monitor or record these interactions for training purposes and to ensure a high quality of service.
  • If you ask Us to communicate with or otherwise process information of other people (for example, if you ask Us to send an email or payment link (in case of split payment option) or any other information/material on your behalf to one of your friends or any other user), We collect the information about others that you give Us in order to complete your request.
  • We also process your content you publish, as part of the operation of the services.
  • Participate in communities or forums or blogs or news feed on the Platform.
  • Knowingly volunteer information on any other part of the Services (e.g., request for customer service, submit a job application).

  Information We receive from others:

  • In addition to the information you provide Us directly, We receive information about you from others, including:
  • Other users: Other users may provide information about you as they use Our services. For instance, We may collect information about you from other users if they contact Us about you or ask Us to send a payment link to complete the payment transaction in relation to any booking made on Our Platforms.
  • Social media: You may be able to use your social media login (such as Facebook login) or Google login to create and log into your Turfwala account on the Platform. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with Us.
  • Other partners: We may receive information about you from Our partners, for instance where Turfwala ads are published on a partner's websites and platforms (in which case they may pass along details for instance information in connection with a campaign's success).
  • When you use Our Secondary Services, We do not retain your messages in the ordinary course of providing our Secondary Services to you. Instead, your messages are stored on your device and not typically stored on our servers. Once your messages are delivered, they are deleted from our servers. The following scenarios describe circumstances where we may store your messages in the course of delivering them:

    • Undelivered Messages. If a message cannot be delivered immediately (for example, if the recipient is offline), we keep it in encrypted form on our servers for up to 30 days as we try to deliver it. If a message is still undelivered after 30 days, we delete it.
    • Media Forwarding. When a user forwards media within a message, we store that media temporarily in encrypted form on our servers to aid in more efficient delivery of additional forwards.
    • We offer end-to-end encryption for our Secondary Services. End-to-end encryption means that your messages are encrypted to protect against us and third parties from reading them.

  Use of Information

  • We may use the information We collect about you from Our Primary Services to:
    • Provide, maintain, and improve Our Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, develop safety features, authenticate users, and send product updates, security alerts and administrative messages
    • Perform internal operations, including, for example, to prevent fraud and abuse of Our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends
    • Send or facilitate communications between you and a Support Staff
    • Send you communications We think will be of interest to you, including information about products, services, promotions, news, and events of Turfwala and other companies; and to process contest, sweepstake, or other promotion entries and fulfil any related awards
    • Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements
    • Respond to your comments, questions and requests and provide customer service to Users
    • Publicly display the Photos and Videos on the Platform or on public forum including on social media platform (such as Facebook and Instagram) at its sole discretion. Unless stated otherwise, all Photos and Videos are believed to be in the public domain as either promotional materials or publicity photos and videos as Turfwala may determine at its sole discretion
    • Enforce applicable user agreements or policies, including the Terms of Service and to protect Us, Our users or the public from harm or illegal activities
    • We reserves the right, but has no obligation, to monitor the User content you post while using Our Primary Services on any of Our Platforms. We have the right to remove any such information or material for any reason or no reason, including without limitation, if in Our sole opinion, such information or material violates, or may violate, any applicable law or Our business policies and practices or to protect or defend Our rights or property or those of any third party. We also reserves the right to remove information upon the request of any third party
    • For the avoidance of any doubt, We should clarify that in the event We anonymize and aggregate information collected from you, We will be entitled to use such anonymized data freely, without any restrictions other than those set out under applicable law. We do this for purposes such as analyzing how the Service is used, diagnosing service or technical problems, maintaining security, and personalizing advertisements and promotions.

  Third-Party Links and Information

  • The Primary Services may contain links to third-party materials that are not owned or controlled by Turfwala and are simply provided for convenience. Turfwala does not endorse or assume any responsibility for any such third-party sites, information, videos (including videos on youtube.com), materials, products, or services. If you access a third-party website or service from the Service (for instance attend any fitness or sports session hosted on Our Platform but accessible online via third party application or websites) or share content on or through any third-party website or service, you do so at your own risk, add you understand that this Privacy Policy does not apply to your use of such sites.
  • You expressly relieve Turfwala from any and all liability arising from your use of any third-party website, service, or content, including without limitation content submitted by other Users.
  • Additionally, your dealings with or participation in promotions of advertisers found on the Service, including payment and delivery of goods, and any other terms (such as warranties) are solely between you and such advertisers.
  • You agree that Turfwala shall not be responsible for any loss or damage of any sort relating to your dealings with such advertisers.
  • We may receive data whenever you visit a third-party link through Our Platforms which includes the date and time of your visit to the third-party website, the web address or URL, technical information about the IP address, browser and the operating system you use and, if you are logged into Turfwala Platforms, your username.
  • We may also receive information from other sources and combine that with information We collect through Our Primary Services. For example: If you choose to link, create, or log in to your Turfwala account with a payment provider (e.g., Paytm) or social media service (e.g., Facebook), or if you engage with a separate app or website that uses Our API (or whose API We use), We may receive information about you or your connections from that site or app.
  • If your employer uses one of Our enterprise solutions, We may receive information about you from your employer.

  Sharing of Information

  • We may share the information We collect about you through Our Primary Services as described in this Privacy Policy or as described at the time of collection or sharing, including as follows:
    • With Support Staff to enable them to provide the Services you request;
    • With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or by Us
    • With the general public or with the audience selected by you for the post, such as group or customised list of people, if you submit content in a public forum, such as blog comments, social media posts, or other features of Our Primary Services that are viewable by the general public
    • With third parties with whom you choose to let Us share information, for example other apps or websites that integrate with Our API or Services, or those with an API or service with which We integrate
    • With your employer (or similar entity) and any necessary third parties engaged by Us or your employer (e.g., an expense management service provider), if you participate in any of Our enterprise solutions.

    Further, We may share your information:

    • With Our subsidiaries and affiliated entities that provide services or conduct data processing on Our behalf, or for data centralization and / or logistics purposes
    • With vendors, consultants, marketing partners and other service providers who need access to such information to carry out work on Our behalf
    • In response to a request for information by a competent authority if We believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process
    • With law enforcement officials, government authorities, or other third parties if We believe your actions are inconsistent with Our Terms of Use or other policies, or to protect the rights, property, or safety of Turfwala or others
    • In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of Our business by or into another company
    • If We otherwise notify you and you consent to the sharing
    • In an aggregated and/or anonymized form which cannot reasonably be used to identify you.

    Social sharing features

    • The Primary Services may integrate with social sharing features and other related tools which let you share actions you take on Our Primary Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
    • Analytics and advertising services provided by others
    • We may allow others to provide audience measurement and analytics services for Us, to serve advertisements on Our behalf across the internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, software development kits (SDKs), and other technologies to identify your device when you visit Our site and use Our Services, as well as when you visit other online sites and services, your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information.
    This information may be used by Us and third parties to, among other things, analyse and track data, determine the popularity of certain content and other websites and better understand your online activity.
    • Our Privacy Policy does not apply to, and We are not responsible for, third party cookies, web beacons or other tracking technologies and We encourage you to check the privacy policies of these third parties to learn more about their privacy practices.
    • Public areas, forums, reviews, and community areas
    • Please remember any success stories, comments, messages, blogs etc. posted/ uploaded/ conveyed/ communicated by you on the public sections of Our Platform becomes published content and becomes public. Anyone may take and use that information. Please be careful about what you disclose and do not post any personal information that you expect to keep private.
    • We may publish such published content on Our Platforms so long as you consent. You may request that such published content be taken down at any time and We shall remove such published content. However, We are not responsible for any actions taken by third-parties with respect to such published content.
    • We as an intermediary are responsible to facilitate a transaction between you and the ultimate event or fitness session organiser/partner so as to enable you to book/purchase a reservation for an sports event, sports session, coaching session, etc. For Us to be able to facilitate this transaction and otherwise fulfil Our contractual arrangements with these ultimate product/service providers, We may have to share your data with them so that they are able to verify the accuracy of the information you have shared with Us while issuing your valid booking id or reservation, to provide you with services and benefits that you may be entitled to and to conduct their own analysis.

  Your Data

  Account information

  • • You may correct your account information at any time by logging into your account. If you wish to cancel your account, please email Us at info@turfwala.com
    • Please note that in some cases We may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if We believe you have committed fraud or violated Our Terms of Service, We may seek to resolve the issue before deleting your information.
    • Access, correction and deletion rights
    • Turfwala will comply with individuals requests regarding access, correction, and/or deletion of the personal data it stores in accordance with applicable law.
    • You may request access, correction or updation, and deletion of the data by contacting info@turfwala.com. You may note that deletion of certain data or withdrawal of consent may lead to cancellation of your registration with Us or your access to Our Services.
    • Based on technical feasibility, We will provide you with access to all your personal and sensitive personal data that We maintain about you. We will perform verification before providing you access to this data.
    • You may opt out of Our marketing emails by clicking on the 'opt-out' link provided in the emails. However, We may still send you non-marketing emails about your accounts or any other transactions with you.

    Location information

    • We request permission from Our Platform for collection of precise location from your device, per the permission system used by your mobile operating system or the operating system of your device. If you initially permit the collection of this information, you can later disable it by changing the location settings on your mobile device or any other device which You are using for accessing the Platform. However, this will limit your ability to use certain features of Our Services.

    Promotional Communications

    • You may opt out of receiving promotional messages from Us by following the instructions in those messages. If you opt out, We may still send you non-promotional communications, such as those about your account, about Services you have requested, or Our ongoing business relations.

    Geo-Location Terms

    • The Services include and make use of certain functionality and services provided by third-parties that allow Us to include maps, geocoding, places and other content from Google or third-party vendors like Google, as part of the Services (the Geo-Location Services). Your use of the Geo-Location Services is subject to Googles then current terms of use for Google Maps/Google Earth (https://www.google.com/intl/en_us/help/terms_maps.html) and by using the Geo-Location Services, you are agreeing to be bound by Googles Terms of Use or relevant terms from other third-party providers.

    International Visitors and Users

    • We currently only provide the Services in India. If you choose to become a User from other regions of the world, then please note that you may be transferring your personal information outside of those regions for storage and processing. Also, We may transfer your data from India or elsewhere to other countries or regions in connection with storage and processing of data, fulfilling your requests, and providing the services associated with the Services. By providing any information, including personal information, on or through the Services, you consent to such transfer, storage, and processing.

    Retention and Storage

    • We retain your data only for as long as necessary to provide the services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods: (a) mandated by law, contract or similar obligations applicable to Our business operations; (b) for preserving, resolving, defending or enforcing Our legal/contractual rights; or needed to maintain adequate and accurate business and financial records.
    • Your personal data will primarily be stored in electronic form. We may enter into agreement with third parties to collect, store, process your personal data but under full compliance with applicable laws.
    • We may need to retain your personal data even if you seek deletion thereof, if it is needed to comply with Our legal obligations, resolve disputes and enforce our agreements.
    • If you are a registered user, please be advised that after you terminate your usage of a Service, We may, unless legally prohibited, delete all data provided or collected by you from Our servers.

  Changes to the Privacy Policy

  • We reserve the right, at Our discretion, to change this Privacy Policy on a going-forward basis at any time. Please check this Privacy Policy periodically for changes. Modified Privacy Policy becomes effective upon its publication on the Website. If We make material changes to this Privacy Policy, We will attempt to provide you reasonable notice before such changes become effective. By continuing using the Services, you agree to be bound by the updated, amended, or modified Privacy Policy. If you do not agree to be bound by the modified Privacy Policy, you must immediately cease your use of the Services. Disputes arising under this Privacy Policy will be resolved in accordance with the version of this Privacy Policy that was in effect at the time the dispute arose.
  • We encourage you to review Privacy Policy whenever you access Our Services to stay informed about Our information practices and the ways you can help protect your privacy.

  Contact Us

  • Should you have questions about this Privacy Policy or Turfwala's information collection, use and disclosure practices, you may contact, the Grievance Officer appointed by Turfwala. Please find below the details of the Grievance Officer for the purpose of this Privacy Policy:
    • Customer Service
    • Email: info@turfwala.com
    • Address: Mumbai
    • Any communication pursuant to this Clause which is not marked to the designated individual mentioned here in above shall not be treated as a valid and binding communication for the purpose of this Privacy Policy.