Privacy Policyप्राइवेसी पॉलिसी DRAFT

1. Who we are

KhelWala is a free-to-play casual games app and website published by Tech Assistant ("we", "us"). For the purposes of India's Digital Personal Data Protection Act, 2023 ("DPDP Act"), Tech Assistant is the Data Fiduciary for personal data processed through KhelWala.

This policy covers the KhelWala Android app, the website at https://khelwala.in, and related support channels.

2. Your account: one phone, one account

KhelWala has no sign-up or login. The first time you open the app, we create an account for your phone automatically. To keep exactly one account per phone, and to bring the same account back if you reinstall the app, we store a hashed device identifier: a one-way code derived from an identifier on your device. We do not store the original identifier, and the hash cannot be used to find out who you are.

The account resets if the phone is factory reset. We do not ask for your phone number, email address, real name or a password.

3. What we collect

• Account data: the hashed device identifier, an account ID, and the date the account was created.
• Profile details you choose: display name, avatar and language preference.
• Game data: match history, moves needed to run a fair online game, results, XP, levels, achievements and leaderboard position.
• Social data: your friends list, friend requests, room codes and room invites.
• Push token: only if you allow notifications, so we can tell you about friend requests and room invites.
• Technical data: app version, device model, operating system version, IP address and basic logs needed for security and fixing errors.

Games against the computer run entirely on your phone and work offline.

What we do not collect

• We do not collect your phone number, email address, contacts, photos, location, or any payment or bank details. KhelWala has no in-app payments.
• The website does not use analytics, advertising cookies or tracking scripts. It only stores your language choice in your browser.

4. How we use your data

We process personal data on the basis of your consent, which you give when you start using the app, and for legitimate uses permitted under the DPDP Act. We use it to:

• create your account and keep one account per phone;
• run online games, quick match, rooms, friends, match history and leaderboards;
• send notifications you have allowed, such as friend requests and room invites;
• keep games fair, and detect cheating, abuse and fraud;
• fix problems and improve performance;
• reply to you when you contact support; and
• meet our legal obligations.

We do not sell your personal data, and we do not use it to build advertising profiles.

5. Who we share it with

We share personal data only with service providers (Data Processors) who help us run KhelWala, under contracts that limit their use of it:

• Google Firebase Cloud Messaging to deliver push notifications, if you allow them;
• Cloud hosting providers that run our servers and databases.

Other players can see your display name, avatar, level and game results in matches, rooms and leaderboards. We may disclose data if the law requires it, or to protect the safety of our users. Some providers may process data outside India, where the DPDP Act and government notifications allow it.

Note for legal review: if advertising (for example AdMob outside gameplay) is added later, this section and the in-app consent flow must be updated before that feature launches.

6. How long we keep it

We keep account data for as long as your account is active. When you delete your account, we erase or anonymise your personal data within a reasonable period, except where we must keep limited records to meet a legal obligation, resolve disputes or prevent abuse. Accounts that stay inactive for a long period may be deleted, as the DPDP rules require.

7. Your rights

Under the DPDP Act you have the right to:

• access a summary of the personal data we hold about you and how it is used;
• correct, complete or update your data, for example your display name;
• erase your data, by deleting your account;
• revoke your consent at any time (this will stop the features that depend on it);
• nominate another person to exercise your rights in case of death or incapacity; and
• grievance redressal, and, if you are not satisfied, to complain to the Data Protection Board of India.

In the app: you can delete your account and request an export of your data from the app's settings. You can also email connect@techassistant.co.in with your player name. Because accounts are tied to a phone, we may ask you to make the request from the app on that phone so we can confirm it is yours.

8. Children

KhelWala is a family-friendly game. If you are under 18, please use online features only with the consent and supervision of a parent or lawful guardian. Where the DPDP Act requires verifiable parental consent, we will ask for it, and we do not track children's behaviour or show them targeted advertising. If you believe a child's personal data has been processed without consent, contact us and we will delete it.

Note for legal review: confirm the age gate and the verifiable parental consent mechanism under the DPDP Rules before launch.

9. Security

We use reasonable security safeguards, including encrypted connections (HTTPS/TLS), one-way hashing of device identifiers, access controls and server-side validation of every online game action. No system is perfectly secure; if a personal data breach occurs, we will inform affected users and the Data Protection Board as the law requires.

10. Changes to this policy

We may update this policy. If the changes are significant, we will tell you in the app before they take effect. The date at the top shows the latest version.

11. Contact and grievances

For privacy questions, requests or complaints, contact our Grievance Officer:

Grievance Officer, KhelWala (Tech Assistant)
Email: connect@techassistant.co.in
[Name and postal address to be added after legal review]

We aim to respond within the time limits set by the DPDP Act and its rules.