Zenali Innovative Technologies Private Limited ("Zenali", "we", "us" or "our") operates the PlayARC website at https://www.playarc.gg/ (the "Website").
1. OVERVIEW
This Privacy Policy explains how Zenali collects, uses, stores, shares and otherwise processes personal data when you:
- Visit or use the website;
- Create or use a PlayARC account;
- Join a waitlist or pre-book a Product;
- Purchase Products through the Website;
- Make or attempt to make a payment;
- Communicate with us through customer support, email, WhatsApp or other communication channels; or
- Otherwise interact with Zenali in connection with the Website or our Products.
For the purposes of this Privacy Policy, "personal data" means information relating to an identified or identifiable individual.
This Privacy Policy applies to personal data collected through the Website and through other interactions with Zenali that are specifically described in this Privacy Policy.
Zenali is committed to handling personal data responsibly and in accordance with applicable data protection and privacy laws.
Please read this Privacy Policy carefully to understand what personal data we collect, why we collect it, how we use it, with whom we may share it, and the choices and rights available to you.
Where applicable law requires your consent for a particular processing activity, Zenali will obtain such consent through an appropriate mechanism. Where permitted by applicable law, you may withdraw consent for processing based on consent by contacting Zenali using the contact details provided in this Privacy Policy.
This Privacy Policy should be read together with our Terms of Service and Refund and Return Policy.
2. PERSONAL DATA WE COLLECT OR PROCESS
Depending on how you interact with the Website and our Products, Zenali may collect or process the following categories of personal data:
2.1 Account Information
When you create or maintain a PlayARC account, we may collect:
- Full name;
- Email address;
- Mobile number;
- Password or other account authentication information;
- Date of birth; and
- Address and other information required to maintain your account.
2.2 Order and Pre-Booking Information
When you place an order, participate in a pre-booking programme or join a Product waitlist, we may collect:
- Product and order details;
- Pre-booking details;
- Order or booking reference;
- Quantity of Products;
- Applicable purchase price or pre-booking amount;
- Delivery address;
- Billing information;
- Order, booking and transaction history;
- Refund, return or replacement information; and
- Communications relating to your order or pre-booking.
2.3 Payment and Transaction Information
Payments made through the Website may be processed by third-party payment service providers, including HDFC SmartGATEWAY.
Zenali may receive transaction-related information necessary to confirm and administer your payment and order, including payment status, transaction reference, payment confirmation and related transaction details.
Where payment information is entered directly into the payment service provider's payment interface, Zenali does not receive or store your full payment card details through that payment processing flow.
2.4 Communications and Customer Support Information
When you contact or communicate with Zenali through email, WhatsApp, customer support or other communication channels, we may collect:
- Your name and contact details;
- Order or pre-booking information;
- Details of your request or complaint; and
- The contents and records of your communications with us.
2.5 Device and Technical Information
When you visit or use the Website, we may automatically collect certain technical information, which may include:
- IP address;
- Browser type and version;
- Device type;
- Operating system;
- Network information;
- Device or browser identifiers;
- Date and time of access; and
- Other technical information necessary to operate, secure and improve the Website.
2.6 Website Usage and Analytics Information
We may collect information relating to how you interact with and use the Website, including pages viewed, features used, navigation patterns, session information and similar usage information.
We use third-party analytics and measurement technologies, including Google Analytics, Meta Pixel and Microsoft Clarity, which may collect information about your interaction with the Website through cookies, pixels, tags, scripts or similar technologies, subject to applicable law and consent requirements.
2.7 Marketing and Communication Preferences
We may collect information regarding your communication preferences and whether you have opted in or opted out of promotional communications.
Where you have provided the required consent or where otherwise permitted by applicable law, we may use your email address or mobile number to send promotional communications through email or WhatsApp.
2.8 Other Information You Provide
We may also collect personal data that you voluntarily provide to us through reviews, feedback, surveys, promotions, competitions, customer support requests or other interactions with Zenali.
3. SOURCES OF PERSONAL DATA
We may collect personal data from the following sources, depending on how you interact with Zenali and the Website:
3.1 Directly From You
We collect personal data that you provide directly to us, including when you:
- Create or update your PlayARC account;
- Join a Product waitlist or pre-book a Product;
- Place an order;
- Provide billing or delivery information;
- Contact customer support;
- Communicate with us through email or WhatsApp;
- Provide feedback, reviews or other information; or
- Otherwise provide information to Zenali.
3.2 Automatically Through the Website
When you visit or use the Website, certain technical and usage information may be collected automatically through cookies, pixels, tags, scripts, server logs and similar technologies.
This may include information about your device, browser, IP address and interactions with the Website. We may use third-party analytics and measurement services, including Google Analytics, Meta Pixel and Microsoft Clarity, for purposes described in this Privacy Policy, subject to applicable law and any required consent.
3.3 From Payment Service Providers
When you make a payment through the Website, Zenali may receive transaction and payment-status information from the applicable payment service provider, including HDFC SmartGATEWAY.
Such information may include transaction references, payment status, confirmation of successful or failed payment and other information necessary to administer your order or pre-booking.
3.4 From Service Providers
We may receive or access personal data processed by service providers that assist us with operating our business and Website, including providers supporting:
- Website hosting and technology infrastructure;
- Payment processing;
- Analytics and measurement;
- Customer support;
- Email and WhatsApp communications;
- Logistics and delivery;
- Security and fraud prevention; and
- Other business operations.
3.5 From Other Sources
Where permitted by applicable law, we may receive personal data from other sources where necessary to prevent fraud, protect the security of our Website and services, comply with legal obligations, or provide and administer our Products and services.
4. HOW WE USE PERSONAL DATA
Depending on how you interact with Zenali and the Website, we may use personal data for the following purposes:
4.1 Providing and Managing Our Services
We may use personal data to:
- Create, maintain and manage your PlayARC account;
- Provide access to and operate the Website;
- Process and manage Product orders and pre-bookings;
- Manage Product waitlists and communicate with customers regarding pre-bookings;
- Process payments and verify payment status;
- Apply pre-booking amounts towards the applicable Product purchase;
- Process refunds, returns, replacements and warranty-related requests;
- Arrange Product delivery;
- Provide customer support;
- Maintain records of transactions and customer interactions; and
- Otherwise provide and administer the Products and services you request.
4.2 Communications
We may use your personal data to communicate with you regarding your Account, pre-booking, order, payment, delivery, refund, return, warranty or customer support request.
These communications may be sent through email, WhatsApp, SMS, telephone or other communication channels where appropriate.We may also send you important service-related notices, including changes to our Products, Website, policies or terms where such communication is required or appropriate.
4.3 Product and Pre-Booking Notifications
Where you join a waitlist or pre-booking programme, we may use your contact information to notify you about matters relating to that Product or pre-booking programme, including pre-booking availability, applicable pre-booking dates, refund deadlines, final payment instructions, order status and other information necessary to administer the programme.
4.4 Marketing and Promotional Communications
Where you have provided the required consent or where otherwise permitted by applicable law, we may use your personal data to send promotional and marketing communications about our Products, launches, offers, events and other activities through email and WhatsApp.
You may opt out of promotional communications at any time using the unsubscribe or opt-out mechanism provided in the communication or by contacting us using the details provided in this Privacy Policy.
Opting out of promotional communications will not affect necessary transactional or service-related communications concerning your Account, orders, payments, deliveries, refunds, returns or other services you have requested.
4.5 Website Analytics and Improvement
We may use personal data and technical or usage information to understand how customers use the Website, measure Website performance, identify technical issues, improve functionality and user experience, and develop or improve our Products and services.For these purposes, we may use third-party analytics and measurement services, including Google Analytics, Meta Pixel and Microsoft Clarity, subject to applicable law and any required consent.
4.6 Security and Fraud Prevention
We may use personal data to:
- Authenticate and secure your Account;
- Protect the Website and our systems;
- Setect, prevent and investigate fraudulent, unauthorised or suspicious transactions or activities;
- Protect our customers, employees and business;
- Investigate misuse of the Website or violations of our policies; and
- Maintain the security and integrity of our services.
4.7 Legal and Regulatory Compliance
We may use personal data where necessary to:
- Comply with applicable laws, regulations and legal obligations;
- Respond to lawful requests from government authorities, regulators, courts or law-enforcement agencies;
- Rstablish, exercise or defend legal claims;
- Rnforce our Terms of Service, Refund and Return Policy and other applicable policies; and
- Protect our legal rights, property and interests.
4.8 Business Operations
We may use personal data for other legitimate business and operational purposes, including maintaining business records, auditing, accounting, reporting, internal administration, service improvement and managing relationships with our service providers.
5. HOW WE SHARE PERSONAL DATA
We may share personal data with third parties where necessary to operate our Website, provide our Products and services, process transactions, communicate with customers, protect our business, or comply with applicable law.
We may share personal data with the following categories of recipients:
5.1 Payment Service Providers
We may share relevant information with payment service providers, including HDFC SmartGATEWAY, to process and facilitate payments made through the Website and to verify payment status and transaction details.
Payment service providers may independently process payment information in accordance with their own privacy policies and applicable laws.
5.2 Website, Technology and Hosting Service Providers
We may share personal data with service providers that support the operation, hosting, maintenance, security and functionality of the Website and our technology systems.
5.3 Analytics and Measurement Providers
We may share or permit the collection of relevant information through analytics and measurement technologies, including Google Analytics, Meta Pixel and Microsoft Clarity, to understand Website usage, measure performance and improve our Website, Products and services.
The processing carried out by these providers may also be subject to their respective privacy policies and applicable consent requirements.
5.4 Communication and Customer Support Providers
We may share personal data with service providers that help us communicate with customers and provide customer support, including providers supporting email, WhatsApp and other communication channels.
5.5 Logistics and Delivery Providers
We may share information necessary to fulfil and deliver your order with logistics, courier and delivery service providers.
This may include your name, mobile number, delivery address, order details and other information necessary to complete delivery.
5.6 Professional and Business Service Providers
We may share personal data with professional advisers and service providers, including legal, accounting, audit, compliance, consulting, insurance and other business service providers, where reasonably necessary for our business operations.
5.7 Corporate Transactions
We may share personal data where reasonably necessary in connection with a merger, acquisition, restructuring, financing, sale of assets, sale or transfer of all or part of our business, or a similar corporate transaction, subject to applicable law.
5.8 Legal and Regulatory Requirements
We may disclose personal data where required or permitted by applicable law, including to courts, regulators, government authorities, law-enforcement agencies, tax authorities or other competent authorities.
We may also disclose information where reasonably necessary to establish, exercise or defend legal claims, enforce our Terms of Service or other policies, investigate fraud or unlawful activity, or protect the rights, safety and property of Zenali, our customers or others.
5.9 With Your Direction or Consent
We may share personal data with a third party where you specifically request or direct us to do so, or where your consent is required and has been obtained in accordance with applicable law.
6. THIRD-PARTY WEBSITES AND LINKS
The Website may contain links to websites, applications, social media pages or other online platforms operated by third parties.
These third-party websites and services are not operated or controlled by Zenali. If you choose to access a third-party website or service through a link provided on our Website, your use of that third-party website or service will be subject to the third party's own terms, privacy policy and other applicable policies.
Zenali is not responsible for the privacy practices, security, availability, content or accuracy of information provided by third-party websites or services that are not operated or controlled by Zenali.
The inclusion of a link to a third-party website or service does not necessarily constitute an endorsement, sponsorship or recommendation by Zenali.
We recommend that you review the applicable terms and privacy policies of any third-party website or service before providing personal data or otherwise interacting with it.
7. CHILDREN'S DATA
The Website and Products are intended for use by individuals who are 18 years of age or older.
Zenali does not knowingly permit individuals under 18 years of age to create a PlayARC account, make a pre-booking or purchase Products through the Website without the involvement and consent of a parent or lawful guardian where required by applicable law.
Because we collect date of birth when creating a PlayARC account, we may use that information to determine whether additional requirements relating to children's data apply.
If Zenali is required under applicable law to process personal data relating to a child, we will obtain and verify the consent of the child's parent or lawful guardian in the manner required by applicable law.
We will not knowingly undertake processing of children's personal data in a manner prohibited by applicable law, including processing that is likely to cause a detrimental effect on the well-being of a child or prohibited tracking, behavioural monitoring or targeted advertising directed at children.
If you believe that a child has provided personal data to Zenali without the required parental or guardian consent, please contact us using the contact details provided in this Privacy Policy. We will take appropriate steps to review the matter and, where required by applicable law, delete or otherwise appropriately handle the personal data.
Nothing in this section limits any rights or protections available to children or their parents or lawful guardians under applicable law.
8. SECURITY AND RETENTION OF PERSONAL DATA
8.1 Data Security
Zenali takes reasonable security measures designed to protect personal data against unauthorised access, use, alteration, disclosure, loss or destruction.
Depending on the nature of the personal data and the circumstances, our security measures may include appropriate technical and organisational safeguards, access controls, authentication measures, monitoring and other measures designed to protect the personal data we process.
We also require relevant service providers that process personal data on our behalf to maintain appropriate security measures, where applicable.
However, no method of transmission over the internet or method of electronic storage is completely secure. While we take reasonable measures to protect personal data, we cannot guarantee that personal data will always be completely secure or that unauthorised access, loss or disclosure will never occur.
You are responsible for maintaining the confidentiality of your PlayARC account credentials and should not share your password or other authentication information with others.
8.2 Data Retention
Zenali will retain personal data only for as long as reasonably necessary for the purposes for which it was collected, or for such period as may be required or permitted under applicable law.
The period for which personal data is retained may depend on factors including:
- Whether you maintain an active PlayARC account;
- Whether the information is required to provide Products or services to you;
- Whether the information is required to process or maintain records of orders, pre-bookings, payments, refunds, returns or warranty claims;
- Whether we are required to retain the information for accounting, tax, legal, regulatory or other compliance purposes;
- Whether the information is necessary to establish, exercise or defend legal claims; and
- Whether retention is otherwise necessary for legitimate business or security purposes.
When personal data is no longer required for the purposes for which it was collected, Zenali will take reasonable steps to delete it, anonymise it or otherwise dispose of it in accordance with applicable law and our internal data-retention practices.
Certain information may need to be retained for longer periods where required by applicable law or where reasonably necessary to protect Zenali's legal rights, prevent fraud or resolve disputes.
9. YOUR RIGHTS AND CHOICES
Subject to applicable law and any conditions or limitations prescribed by law, you may have rights in relation to the personal data processed by Zenali.
Depending on the applicable law, these may include the following:
9.1 Right to Access
You may request information about the personal data relating to you that Zenali processes and other information about its processing, to the extent provided by applicable law.
9.2 Right to Correction
You may request correction of personal data that is inaccurate, incomplete or misleading, subject to applicable law.
You may also update certain Account information directly through your PlayARC Account, where such functionality is available.
9.3 Right to Erasure
You may request deletion or erasure of your personal data where permitted by applicable law.
Zenali may retain certain personal data where retention is required or permitted by law, or where it is reasonably necessary for purposes such as fulfilling legal obligations, maintaining required business records, preventing fraud, resolving disputes or establishing, exercising or defending legal claims.
9.4 Withdrawal of Consent
Where Zenali processes your personal data based on your consent, you may withdraw that consent in accordance with the applicable process.
Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.
Where processing is necessary for purposes that do not depend on your consent, withdrawing consent may not result in cessation of that processing.
9.5 Marketing Preferences
You may opt out of promotional communications from Zenali at any time by using the unsubscribe or opt-out mechanism provided in the relevant communication or by contacting us.
If you opt out of marketing communications, we may continue to send non-promotional communications that are necessary to provide services to you, including communications relating to your Account, pre-booking, orders, payments, delivery, refunds, returns, warranty or customer support.
9.6 Grievance and Complaint
You may raise a grievance or complaint regarding the processing of your personal data by contacting Zenali using the contact details provided in this Privacy Policy.
Zenali will review and address grievances in accordance with applicable law and its applicable grievance-redressal process.
9.7 How to Exercise Your Rights
To exercise an applicable right or submit a request concerning your personal data, you may contact Zenali using the contact details provided in the Contact section of this Privacy Policy.
We may request reasonable information necessary to verify your identity and protect against unauthorised requests before processing a request.We will process and respond to valid requests within the timeframes and in the manner required by applicable law.
Certain requests may be refused, restricted or subject to additional requirements where permitted or required by applicable law.
10. GRIEVANCE REDRESSAL
If you have any concerns, complaints or grievances regarding the collection, use, processing, storage or disclosure of your personal data by Zenali, you may contact our Grievance Officer using the contact details provided in the Contact section of this Privacy Policy.
When submitting a grievance, you should provide sufficient information to enable us to understand and investigate the matter, including your name, contact details and a description of your concern, together with any relevant Account, order or transaction reference where applicable.
Zenali will acknowledge and address grievances in accordance with the timelines and procedures prescribed under applicable law.
We may request reasonable information necessary to verify your identity before processing a grievance or request relating to your personal data.
If you are not satisfied with the response or resolution provided by Zenali, you may exercise any further rights or pursue any remedy available to you under applicable law, including approaching any competent authority or forum where such right is available.
For grievances relating specifically to an order, Product, refund, return, delivery or payment, you may also contact Zenali through the customer support details provided on the Website.
11. DATA PROCESSING WITHIN INDIA
Zenali operates the PlayARC business in India and currently provides its Products and services to customers in India.
Zenali does not currently offer Products or services for purchase or delivery outside India. Personal data is intended to be processed in connection with Zenali's India operations. Where third-party service providers used by Zenali process or store personal data outside India, such processing will be subject to applicable law and the safeguards applicable to such service providers.
Zenali will comply with applicable Indian requirements relating to the processing and transfer of personal data.
12. CHANGES TO THIS PRIVACY POLICY
Zenali may update or modify this Privacy Policy from time to time to reflect changes in our business practices, Products, Website, data-processing practices, applicable laws or regulatory requirements.
The updated Privacy Policy will be published on the Website, and the "Last Updated" date at the beginning of this Privacy Policy will be revised accordingly.
Where required by applicable law, Zenali will provide appropriate notice of material changes through the Website or other appropriate communication channels.
We encourage you to review this Privacy Policy periodically to remain informed about how Zenali processes personal data.
Any changes to this Privacy Policy will apply from the effective date stated in the updated Policy, unless otherwise required by applicable law.