Effective Date: 08th February, 2021.

Walking Street Media Private Limited is hereinafter referred to as “Walking Street”, “We”, “PredGuru” or “Us”.

We thank you for playing our games. Your privacy is most significant to us, and we deem it as our duty to care for it seriously; therefore, we conduct our business in compliance with applicable laws on data privacy protection and data security. We hope the policy outlined below will help you understand what data PredGuru may collect, how PredGuru uses and safeguards that data and with whom we may share it.

PRIVACY POLICY

This privacy policy (“Privacy Policy”) is incorporated by reference into the PredGuru Terms of Service (the “Terms Of Service”). This Privacy Policy explains our online information practices, the kinds of information we may collect, how we intend to use, store, protect, disclose and share that information, and how you can opt out of a use or correct or change such information.

Our services will not be available in certain regions. Do not register or use PredGuru if you are from the below mentioned list of Countries where usage of PredGuru will be restricted:

• China & Russia from Asia
• EU/EEA - Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic (Czechia), Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lichtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom
• Countries from Middle-East - Bahrain, Egypt, Iran, Iraq, Israel, Jordan, Kuwait, Lebanon, Oman, Palestine, Qatar, Saudi Arabia, Syrian Arab Republic, Turkey, The United Arab Emirates, Yemen

If any user registers or changes or manipulates the results/output on PredGuru using any unfair, fraudulent means like VPN, etc. then Walking Street Media Pvt. Ltd./PredGuru will not be responsible, rather the user shall be solely responsible for his unlawful act and shall also indemnify PredGuru/ Walking Street Media Pvt. Ltd. for any or all claims arising out of it at fullest extent.

WHAT DOES THIS PRIVACY POLICY APPLY TO?

This Privacy Policy applies to personal information (“Personal Information”) and other information that is processed by PredGuru in the course of our business, including on the PredGuru website (“Site”), (together with any and all future online and offline offerings operated by or on behalf of PredGuru (the “Services”)). All individuals whose responsibilities include the processing of Personal Information on behalf of PredGuru are expected to protect that data by adhering to this Privacy Policy.

By visiting, installing, using or otherwise accessing the Services, you agree to this Privacy Policy and the Terms of Services of PredGuru and give an explicit and informed consent to the processing of your Personal Information in accordance with this Privacy Policy. Please do not install or use the Services if you do not agree to this Privacy Policy or the Terms of Service.

We do everything we reasonably can to protect your rights of privacy on PredGuru, but we are not liable for any unauthorized or unlawful disclosures of your personal and confidential information made by third parties who are not subject to our control (for example advertisers and websites that have links to our Site). You should take note that the information and privacy practices of our business partners, advertisers, sponsors or other sites to which we provide hyperlinks, may be different from ours. Please note that PredGuru is not responsible for the actions of third parties, the content of their sites, the use of information you provide to them or any services they may offer.

PredGuru reserves the right to modify this Privacy Policy and your continued use of the Services shall mean your acceptance of the changes to this Privacy Policy.

WHOM DO WE COLLECT INFORMATION FROM?

PredGuru Collects Personal Information and other information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).

WHAT INFORMATION DO WE COLLECT?

The types of Personal Information we may collect (directly from you or from third-party sources) and our privacy practices depend on the nature of the relationship you have with PredGuru and the requirements of applicable law. Some of the ways that PredGuru may collect Personal Information include:

• You may provide Personal Information directly to PredGuru through interacting with the Services, participate in Services feedback, or contests or and
• as you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

Primary goals in collecting information are to provide and improve our Services, to administer your use of the Services and to enable you to enjoy and easily navigate our Services. We endeavor to collect only that information that is relevant for the purposes of processing. Below are the ways we collect Personal Information and how we use it.

1. Information Collected from Third-parties when registering and Playing the Games

   If you play any of the games or use any of the Services on connected third-party applications or connect the Services to any third-party applications, Google and/or from Social Networking Sites (“SNS”) such as Facebook, we may receive certain information about you from the provider of the third-party application. The information received depends on the third-party application, your privacy settings and, if applicable, your friends' privacy settings on that third-party application.

   When you connect with the Services through an SNS, the information that PredGuru collects may include your first and last name, the login e-mail you provided to that third-party application when you registered with the SNS, when you use any of the Services, on a mobile platform, PredGuru may collect and record certain information such as your location based on your Internet Protocol ("IP") address. This information is useful to PredGuru for troubleshooting and helps PredGuru understand usage trends.

   You can manage the information PredGuru receives about you from a third-party application, like Facebook or Google, on which you play our games and you will need to follow the instructions for the third-party application for changing your privacy settings. If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s terms of service and privacy policy.

2. Information collected directly from you

   You may provide information directly to PredGuru when you:

   • Use or access the Services
   • connect with or access our Services using a third party ID or log-in, such as an ID for a social networking site or gaming service;
   • contact others using our Services, including when you use chat, “tell a friend,” “email this page,” or other similar features;
   • contact us, including for customer or technical support;
   • register for PredGuru offers, contests, or special events;
   • subscribe to push notifications

   Depending on how you choose to use the Services, this information may include things like your first and last name, email address, location information and other information.

3. Information collected from your devices /Automated data collection:

   Automated data collection includes:

   • data about your account and game progress;
   • your IP address
   • data we collect with cookies and similar technologies (see more below)
   • data about your use of the Service, such as gameplay data and your interactions with other players inside the Service

   In certain cases, we may also create a Unique ID and Encrypted ID for you when you use the Service.

4. Cookies and similar technologies

   We or the service providers acting on our behalf may use cookies, beacons, software development kits, mobile analytics software, and/or similar technologies for a number of purposes, including to authenticate users, prevent fraud, remember preferences and settings, analyze advertising and messaging campaigns, analyze traffic and trends, personalize content (including ads), and otherwise provide the Services. These technologies may collect information about your use of our Services, pages you view, links you tap, messages you open, and other actions taken in connection with our Services. You can disable cookies in your browser settings, but this could affect the availability and functionality of our Services. For information on interest-based advertising and how to opt out, see the Interest-Based Advertising section below.

5. Ad Networks

   PredGuru may feature advertising within the Services. The advertisers may collect and use information about you such as:

   • performance and game contextual data like your games session activity;
   • aggregated and/or de-identified information that is not intended to specifically identify a user; and
   • technical information such as device identifier, Advertising ID, and IP address.

   Ad Networks may use this information to provide interest-based or targeted advertisements to you.

WHY DO WE COLLECT INFORMATION?

1. We collect, store, use and process Personal Information for a variety of business purposes, including:
   • to operate, improve and optimize our games and other Services;
   • to create game accounts and allow users to play our games;
   • to personalize our Services, understand our users and their preferences to enhance user experience and enjoyment using our Services and improve our users’ experience;
   • to provide access to certain areas, functionalities and features of our Services;
   • to notify you about in-game updates, new products or promotional offers;
   • to send related information, including confirmations, technical notices, updates, and security alerts and support and administrative messages;
   • to enable players to communicate with each other in games;
   • to respond to your comments and inquiries and provide customer support services;
   • to prevent potentially prohibited or illegal activities and protect our players;
   • to measure interest in our Services;
   • to ensure internal quality control; and
   • to verify Individual identity.
2. Inform you about our games, products and Services

   PredGuru may use Personal Information to provide you with materials about offers, products and Services that may be of interest, including new games, content or Services. PredGuru may provide you with these materials by in-game offers, push notification, online or offline marketing or email, as permitted by applicable law, including: to deliver advertising and marketing and promotional information to you; to tailor content, advertisements and offers; to notify you about products and services or upcoming special offers/events that may be interest of you; and to notify you about rewards, surveys, contests or other promotional activities or events sponsored or managed by us or our business partners. You can opt out at any time from receiving such materials by clicking on the opt out link provided in all marketing mailings, or by sending an email to dpo@predguru.com without incurring any costs.

3. Send Push Notifications

   PredGuru may occasionally use push notifications to send you game updates, information on winning contests and other Services-related notifications that may be important to you. You may at any time opt out from receiving these types of communications by turning them off at the device level through your settings.

4. Use Anonymous and Aggregated Information

   We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services or other analyses we create. Anonymized and aggregated information is used for several functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, Analytics and any other legally permissible purposes. We may share this information within PredGuru and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

HOW WE MAY DISCLOSE YOUR INFORMATION

We may share the information we collect about you in various ways, including:

1. Service providers

   We may share any information we receive with Service Providers. The types of Service Providers (processors) to whom we entrust Personal Information include Service Providers for:

   • provision of IT and related services;
   • provision of information and services you have requested;
   • customer service activities; and (v) in connection with the provision of the Services. PredGuru has executed appropriate contracts with the Service Providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
2. Marketing - Interest-based or targeted advertising and third-party marketing. Through our Services, PredGuru may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect the following information within our Services:

   performance data (like the number of clicks on an advertisement); certain technical information (for example, IP addresses, non-persistent device identifiers such as Advertising ID and de-identified persistent device identifiers such as a hashed Android ID); other contextual data about your game play (for example, your level and session length); and pseudonymous data, not directly identifying information (e.g., OS name and versions, device models, time stamp). These advertising partners may use this information (and similar information collected from other websites) to measure how effective ads are for delivering targeted advertisements to you about our games within their networks. This practice is commonly referred to as “interest-based or targeted advertising.” We may allow access to other data collected by the Services to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you.

3. Disclosures under applicable law

   We may access, preserve, and disclose your Personal Information, other account information and content if we believe doing so is required or appropriate:

   • to comply with law enforcement or national security requests and legal process, such as a court order or subpoena;
   • to respond to your requests;
   • to protect yours, ours or others’ rights, property or safety;
   • to enforce PredGuru' policies or contracts;
   • when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or
   • if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes—e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies, so they may identify users in connection with their investigation of the unauthorized activities.
4. Merger, sale, or other asset transfers

   If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, PredGuru will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

INTEREST-BASED ADVERTISING

We work with third party advertising partner i.e. Google. We may share certain of your information with Google to make advertising more relevant, measure its effectiveness, and help recognize your devices and serve ads. We or they may also employ cookies or similar technologies, as described above, to ensure appropriate advertising and personalized experiences. Please note that our ad partners may combine your information with other information they have independently collected, and may treat that information in accordance with their privacy policies.

If you would prefer to opt out of having information about your PredGuru usage used for interest-based advertising, you may do so by sending us request of opt out from registration as well as menu page available on our PredGuru Please note that you may continue to receive generic ads that are not based on your preferences.

PredGuru THIRD-PARTY ADVERTISING COMPANIES:

ADcodes and Analytics Partners

PredGuru contains ADS from Google and codes from Analytic tools company and can contain codes for profiling the device on media consumption and other device data and utilizing the same to target relevant content and ads to the device. To comply with the European Union GDPR guidelines and pursuant to our agreement with the Advertisers and Analytics Tool Companies, we are hereby including Privacy Policy Link of such companies. By agreeing to our Privacy Policy you are giving consent for processing any personal information or information by the Advertisers in connection with the agreement between PredGuru and the Advertisers.

Google AdSense, https://privacy.google.com/ businesses/controllerterms/ using the Google Ads Settings https://www.google.com/settings/ads, you can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads. You can also opt-out by downloading and installing the Google Analytics Opt-out Browser Add-on https://tools.google.com/dlpage/gaoptout/ for your web browser. In addition to the general limitations in the above terms, we will not be liable to you or any other third party for any damages suffered by you or any other third party howsoever arising from the disclosure of your Personal Information. Your only remedy under such circumstances will be to end this agreement.

INTERNATIONAL TRANSFER

All Personal Information collected via or by PredGuru may be stored anywhere in the world, in the cloud or the servers of our service providers. When we transfer your Personal Information internationally, we will take reasonable steps to ensure that it is treated securely, lawfully and in the manner we describe in this Privacy Policy. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in may be different from the privacy laws applicable to the place where you are resident.

By providing information to PredGuru, you consent to the storage of your Personal Information in these locations.

If you are using our Services from the United States of America with laws governing data collection and use, please note that you are agreeing to the transfer of your information to India and other countries and to the processing of your data globally. This transfer is required to host the Services, provide you with technical and customer support services, perform backups of your data. By choosing to visit PredGuru, utilizing the Services or otherwise providing information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of India and the adjudication of any disputes arising in connection with PredGuru or the Site will be in accordance with the Terms Services.

Your Rights and Choices

Consumers (i.e. California residents) are provided with specific rights under the CCPA regarding their personal information. Your rights and how to exercise same with respect to the PredGuru are described and explained below.

Access to Specific Information and Data Portability Rights You have the right to request that PredGuru disclose certain information to you about PredGuru’s use and collection of your personal information over the preceding 12-month period. Once PredGuru receives and confirms your verifiable consumer request, PredGuru will disclose to you:

• The categories of sources for the personal information PredGuru collected about you;
• The categories of third parties with whom PredGuru shares that personal information;
• The categories of personal information PredGuru collected about you;
• The specific pieces of personal information PredGuru collected about you (also called a data portability request);
• PredGuru’s business or commercial purpose for collecting or selling that personal information;

If PredGuru sold or disclosed your personal information for a business purpose, two separate lists disclosing:

1. sales, identifying the personal information categories that each category of recipient purchased; and
2. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that PredGuru delete any or all of the personal information that PredGuru collected from you and retained, subject to certain exceptions. Upon PredGuru’s receipt and confirmation of a verifiable consumer request from you, PredGuru will, unless an exception applies, delete (and direct any of our service providers having such information to delete) your personal information from PredGuru’s records. Under certain conditions, PredGuru may deny your deletion request. PredGuru may deny your request for deletion if retaining the information is necessary for PredGuru or our service provider(s) to:

• Protect the website and detect security incidents, including preventing fraudulent, deceptive, malicious, or illegal activity, or to enforce the law against those responsible for such actions.
• Comply with the applicable laws;
• Adhere to any legal obligation;
• Provide a service you have requested, complete a purpose for which PredGuru has collected the personal information, to perform any contract with your, or to take any other steps reasonably anticipated within the context of PredGuru’s ongoing business relationship with you;
• Participate in peer-reviewed or public historical, scientific, or statistical research in the public interest that adheres to all other applicable privacy laws and ethical constraints, when the information’s deletion may likely seriously impair or render impossible the research’s achievement, if you previously provided informed consent;
• Troubleshoot or debug products, including to identify and repair errors and intended functionality impairments;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Make other lawful and internal uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise your access, data portability, and deletion rights described above, please submit a verifiable consumer request to PredGuru by sending an email to PredGuru at contact@predguru.com. Only you, or a person registered with the appropriate authority authorized by you to act on your behalf, may make a verifiable consumer request related to your personal information.

A verifiable consumer request for access or data portability may be made by you only twice within a 12-month period. The verifiable consumer request must:

• Describe your request with sufficient detail allowing us to properly evaluate, understand, and respond to it; and
• Provide sufficient information that allows PredGuru to reasonably verify that you are the person about whom PredGuru collected personal information or an authorized representative.

PredGuru cannot provide you with personal information or respond to your request if PredGuru cannot verify your identity or authority to make the request and confirm the personal information relates to you. PredGuru will only use personal information provided in a verifiable consumer request to verify the requestor’s authority to make the request or identity.

Response Timing and Format

PredGuru makes efforts to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), PredGuru will inform you of the reason and extension period in writing. If you have an account with the Website, PredGuru will deliver its written response to that account. If you do not have an account with us, or a response is not capable of being sent thereto, PredGuru will deliver our written response by mail or electronically, at your option. Any disclosures PredGuru provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. If applicable, the response PredGuru provides will also explain the reasons PredGuru cannot comply with a request. For data portability requests, PredGuru will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Unless it is repetitive, excessive, or manifestly unfounded, PredGuru does not charge a fee to process or respond to your verifiable consumer request. If PredGuru determines that the request warrants a fee, PredGuru will provide you with a cost estimate before completing your request tell you why it made that decision.

Personal Information Sales Opt-Out Rights

You have the right to opt out of certain uses and disclosures of your Personal Information. When you have consented to PredGuru’ processing of your Personal Information other information, you may withdraw that consent at any time and opt out to further processing, by contacting dpo@predguru.com. You can send us request for opt out from the PredGuru registration page or if already registered on PredGuru then you can find the opt out link in the menu from where you can exercise your right to opt out. Even if you opt out, we may still collect and use anonymized, non-Personal Information regarding your activities on our Services. You have right to direct us to not sell your personal information at any time (the “right to opt-out”). To exercise the right to opt-out, you may submit a request to us by clicking on link Do Not Sell My Personal Information available on intro page & also in menu.

Once you make an opt-out request, PredGuru will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting PredGuru and sending us a message to that effect. PredGuru will only use personal information provided in an opt-out request to comply with and review the request.

Non-Discrimination

PredGuru will not discriminate against you for exercising any of your rights. Unless permitted by the law, we will not:

• Deny you goods or services;
• Deny you a different level or quality of goods or services.

DATA RETENTION

PredGuru retains the Personal Information collected as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

SECURITY OF YOUR INFORMATION

We follow generally accepted industry standards and maintain reasonable safeguards designed to secure and prevent unauthorized access to the information in our possession. Personal information is stored in secure operating environments, and only those at PredGuru with a legitimate business need to do so may access your personal information. We also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us.

CHILDREN’S PRIVACY

The Services are not directed to children under 18, and PredGuru does not knowingly collect Personally Information from children under 18. If you are under 18, please do not send any data about yourself to us, including your name, email address or any personal identifiable information. If you are a parent or legal guardian of a child under the age of 18 who uses our services, please contact us at dpo@predguru.com. We will delete your child’s Personal Information if we are able to identify your child.

REDRESS/ COMPLIANCE AND ACCOUNTABILITY

If you have any questions about our privacy practices or this Privacy Policy, please contact PredGuru by email at dpo@predguru.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

Complaint Escalation

If you are not satisfied with the way your query or complaint is handled by PredGuru, please let us know by emailing us at management@predguru.com.

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

1. Revision to the Privacy Policy

   We may revise this Privacy Policy at our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.

2. Posting of Revised Privacy Policy

   If there are any material changes to this Privacy Policy, PredGuru will notify you by email or as otherwise required by applicable law. We will post adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

3. New Uses of Personal Information

   Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. When consent of the Individual for the processing of Personal Information is otherwise required by law or contract, PredGuru will endeavor to comply with the law or contract.

CONTACT INFORMATION

Email: management@predguru.com, dpo@predguru.com

Address: Walking Street Media Pvt. Ltd., 402, ABC, 4th Floor, Centrum Plaza, Sector-53, Golf Course Road, Gurugram, Haryana, India-122002

Telephone: +91 124 4663531