Privacy Policy

Bennett, Coleman & Co. Ltd and/or its subsidiary(ies) and/or affiliate(s) (“we”, “us”, “our”, “BCCL ”,”Company”) values the trust placed in us by data subject (“you”, “your”, “user”, “subscriber”) and therefore, we follow the highest standards of privacy guidelines to protect the information shared by you with us.

This privacy policy (“Policy”) explains our policy regarding the collection, use, disclosure and transfer of your information by Bennett, Coleman & Co. Ltd. and/or its subsidiary(ies) and/or affiliate(s) (collectively referred to as the "Company"), which operates various websites more specifically the website https://www.etplay.com including sub-sites, platforms, applications, m-web platforms and other platforms (collectively referred to as “Sites”) for delivery of information, products, offerings and content via any mobile or internet connected device or otherwise (collectively the "Services"). This Policy forms part and parcel of the Terms of Use and other terms on the Site (“Terms of Use”). Capitalized terms which have been used here but are undefined shall have the same meaning as attributed to them in the Terms of Use.

This Privacy Policy is applicable to persons who access, browse or use the Services (“User”). For the purpose of this Policy, wherever the context so requires "you" or "your" shall mean User and the term "we", "us", "our" shall mean Company.

Further, the privacy and cookie policy of the following websites will also apply to persons who access, browse or use the Services of ET Play :

https://www.etplay.com/privacy-policy

As we update, improve and expand the Services, this Policy may change, so please refer back to it periodically. By accessing and using the Sites or otherwise using the Services, you consent to collection, storage, and use of the personal information you provide (including any changes thereto as provided by you) for any of the Services that we provide.

The Company respects the privacy of the Users of the Services and is committed to protect it in all respect, your right to privacy is of paramount importance to the Company. The information about the User as collected by the Company is: (a) information supplied by Users and (b) information automatically tracked while navigation (c) information collected from any other source (collectively referred to as “Information”).

1. INFORMATION RECEIVED, COLLECTED AND STORED BY THE COMPANY

A. INFORMATION SUPPLIED BY USERS

Registration data:

When you register on the Sites for the Service, we ask that you to provide basic contact information such as your name, date of birth, sex, age, address, pin code, contact number, occupation, interests and email address etc. When you register using your other accounts like on Facebook, Twitter, Gmail etc. we shall retrieve Information from such account to continue to interact with you and to continue providing the Services.

Subscription or paid service data:

When you choose any subscription or paid service provided as part of our Services, we or our payment gateway provider may collect your purchase, address or billing information, including your credit card number and expiration date etc. However, when you order using an in-app purchase option on any of the applications of the Company, same are handled by such mobile operating system platform providers. The subscriptions or paid Services may be on auto renewal mode unless cancelled. If at any point you do not wish to auto-renew your subscription, you may cancel your subscription before the end of the subscription term.

Voluntary information:

We may collect additional information at other times, including but not limited to, when you provide feedback, comments, change your content or email preferences, respond to a survey, or any communications with us.

The user agrees to receive updates/news about BCCL Promotional Announcements, Event Notifications, Surveys/Opinion Polls via Calls, SMS texts, Emails, Website Browser Notifications, App Push Notifications etc.

B. INFORMATION SUPPLIED BY USERS

Cookies:

To improve the responsiveness of the Sites for our Users, we may use "cookies", or similar electronic tools to collect Information to assign each visitor a unique, random number as a User Identification (User ID) to understand the User's individual interests using the identified computer or device. Unless you voluntarily identify yourself (through registration, for example), we will have no way of knowing who you are, even if we assign a cookie to your computer or device. The only personal information a cookie can contain is information you supply. A cookie cannot read data off your hard drive or device. Our advertisers may also assign their own cookies to your browser (if you click on their ads etc.), a process that we do not control. We receive and store certain types of Information whenever you interact with us via Site or Service though your computer/laptop/netbook or mobile/tablet/pad/handheld device etc. The detailed cookie policy can be viewed at : https://www.etplay.com/privacy-policy

Opting out

If a User opts out using the Ads Settings, the unique DoubleClick cookie ID on the User's browser is overwritten with the phrase "OPT_OUT". Because there is no longer a unique cookie ID, the opt-out cookie can't be associated with a particular browser.

Log File Information

We automatically collect limited information about your computer's connection to the Internet, mobile number, including your IP address, when you visit our site, application or service. Your IP address is a number that lets computers attached to the Internet know where to send you data -- such as the pages you view. We automatically receive and log information from your browser, including your IP address, your computer's name, your operating system, browser type and version, CPU speed, and connection speed. We may also collect log information from your device, including your location, IP address, your device's name, device's serial number or unique identification number (e.g.. UDiD on your iOS device), your device operating system, browser type and version, CPU speed, and connection speed etc.

Clear GIFs

We may use "clear GIFs" (Web Beacons) to track the online usage patterns of our Users in an anonymous manner, without personally identifying the User. We may also use clear GIFs in HTML-based emails sent to our Users to track which emails are opened by recipients. We use this information to inter-alia deliver our web pages to you upon request, to tailor our Sites or Service to the interests of our users, to measure traffic within our Sites to improve the quality, functionality and interactivity of our Sites and let advertisers know the geographic locations from where our Users come without personally identifying the Users.

2. Information from other Sources:

We may receive information about you from other sources, add it to our account information and treat it in accordance with this Policy. If you provide information to the platform provider or other partner, whom we provide services, your account information and order information may be passed on to us.

Demographic and other information:

We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use Google Analytics, among others, to track the user behaviour on our Sites. Google Analytics specifically has been enabled to support display advertising towards helping us gain understanding of our users' demographics and interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us. You can opt-out of Google Analytics for display advertising and customize Google Display Network ads using the Ads Settings options provided by Google.

LINKS TO THIRD PARTY SITES / AD-SERVERS

The Sites may include links to other websites or applications. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the application, you are visiting. That privacy policy may differ from ours. If you can't find the privacy policy of any of these sites via a link from the application's homepage, you should contact the application owners directly for more information.

By visiting the Site and entering your data to know more about details of any product or services displayed on the Site or by availing any of our Services, you hereby authorize us to share your data with our advertisers in order to give you more information about the product or goods or services. Apart from the same, we do not provide any personally identifiable information to third party websites / advertisers / ad-servers without your consent.

INFORMATION USE BY THE COMPANY

The information as supplied by the users enables us to improve the Services and provide you the most user-friendly experience. In some cases/provision of certain service(s) or utility(ies), we may require your contact address as well. All required Information is service dependent and the Company may use the above said user Information to, maintain, protect, and improve the Services (including advertising and personalization on the Sites) and for developing new services. We may also use your email address or other personally identifiable information to send commercial or marketing messages with an option to subscribe / unsubscribe (wherever feasible) and your continued usage of the Site and Services is deemed consent to receive any such commercial or marketing messages. We may, however, use your email address, without further consent, for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, billing, etc.), recommending various products or services including those of third parties (with an option to opt out), dealing with requests, enquiries and complaints and customer related activities.

Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and / or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, twitter etc.

Any posted/uploaded/conveyed/communicated by users on the public sections of the Sites becomes published content and is not considered personally identifiable information subject to this Policy.

In case you choose to decline to submit personally identifiable information on the Sites, we may not be able to provide certain services on the Sites to you. We will make reasonable efforts to notify you of the same at the time of opening your account. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information.

The Company may, if you so choose send direct mailers to you at the address given by you. You have the option to 'opt-out' of this direct mailer by way of links provided at the bottom of each mailer. The Company respects your privacy and in the event that you choose to not receive such mailers, we will take all steps to remove you from the list.

When you register with the Sites or Services, we contact you from time to time about updating your personal information to provide the Users such features that we believe may benefit / interest you.

3. INFORMATION SHARING

The Company shares your Information with any third party without obtaining the prior consent of the User in the following limited circumstances:

a) When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including but not limited to cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms or for complying with the applicable laws and regulations.

b) The Company proposes to share such Information to conduct its business and to share such Information within its group companies and officers and employees of such group companies for the purpose of processing personal information on its behalf. We also ensure that these recipients of such Information agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.

c) The Company may present Information to our advertisers and third parties - to help them understand our audience and confirm the value of advertising on our Sites – however it is usually in the form of aggregated statistics on traffic to various pages within our site.

d) The Company may share your Information regarding your activities on Sites with third party social websites to populate your social wall that is visible to other people however you will have an option to set your privacy settings, where you can decide what you would like to share or not to share with others.

4. ACCESSING AND UPDATING PERSONAL INFORMATION

When you use the Services or Sites (or any of its sub sites), we make good faith efforts to provide you upon verification, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal information or sensitive personal data or information to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

5. INFORMATION SECURITY

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All information gathered on BCCL is securely stored within the Company controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. And, of course, any information you include in a posting to the discussion areas is available to anyone with Internet access.

We use third-party advertising companies to serve ads when you visit or use our Sites or Services. These companies may use information (excluding your name, address, email address or telephone number or any personally identifiable information) about your visits or use to particular website, mobile application or services, in order to provide advertisements about goods and services of interest to you.

6. UPDATES / CHANGES

The internet is an ever evolving medium. We may alter our Policy from time to time to incorporate necessary changes in technology, applicable law or any other variant. In any case, we reserve the right to change (at any point of time) the terms of this Policy or the Terms of Use. Any changes we make will be effective immediately on notice, which we may give by posting the new policy on the Sites . Your use of the Sites or Services after such notice will be deemed acceptance of such changes. We may also make reasonable efforts to inform you via electronic mail. In any case, you are advised to review this Policy periodically on the Site to ensure that you are aware of the latest version.

7. RETENTION OF INFORMATION

We will only retain your personal information for as long as it is necessary to process your Service request, including flight purchases, keep you up to date with Jet Airways’ promotions where you have asked us to do so and/or to provide you with the best customer experience possible and pursuant to the requirements of law including laws of India. Retention is therefore necessary for the purposes of our legitimate interests (for example, to deal with any claims or queries which you have relating to your flight purchases), or where we are required to do so by law.

We will actively review the information we hold and delete it securely, or in some cases anonymise it/encrypt it, when there is no longer a legal, business or customer need for it to be retained.

The Company will not retain the Information longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or keep you updated with Company’s promotions where you have asked us to do so and provide you with the best user experience. When a user account is terminated or expired, all Personal Information collected through the Site will be deleted or in some case encrypted, as required by applicable law.

8. QUESTIONS / GRIEVANCE REDRESSAL

Redressal Mechanism: Any complaints, abuse or concerns with regards to the processing of information provided by you or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email signed with the electronic signature to contactus@timesgroup.com or Mr. Sanio Farro (“Grievance Redressal Officer”)

Mr. Sanio Farro

Grievance Redressal Officer

Bennett, Coleman & Co. Ltd.

The Times of India Suburban Press,

Western Express Highway, Akurli Road,

Kandivali (E), Mumbai- 400 101, India

Ph: 91-22-67675386

We request you to please provide the following information in your complaint:-

a) Identification of the information provided by you;

b) Clear statement as to whether the information is personal information or sensitive personal information;

c) Your address, telephone number or e-mail address;

d) A statement that you have a good-faith belief that the information has been processed incorrectly or disclosed without authorization, as the case may be;

e) A statement, under penalty of perjury, that the information in the notice is accurate, and that the information being complained about belongs to you;

f) You may also contact us in case you have any questions / suggestions about the Policy using the contact information mentioned above.

The Company may reach out to you to confirm or discuss certain details about your complaint and issues raised.

The Company shall not be responsible for any communication, if addressed, to any non-designated person in this regard.

Cookie Policy

Bennett, Coleman & Co. Ltd and/or its subsidiary(ies) and/or affiliate(s) (“we”, “us”, “BCCL”) understand that your privacy is important to data subject (“you”, “your”, “user”, “subscriber”) and we are committed for being transparent about the technologies we use. This Cookie Policy explains how and why cookies and other similar technologies may be stored on and accessed from your device when you use or visit BCCL website or application that posts a link to this Policy (collectively, “the Sites”). This Cookie Policy should be read together with our Privacy Policy and Terms of Use.

What are cookies and Other Tracking Technologies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. The other tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use our websites. This allows our websites to recognize your device from those of other users of the websites. The information provided below about cookies also applies to these other tracking technologies.

How do our sites use cookies and other tracking technologies?

We use cookies to collect and store information when you access our website and use other BCCL services. We use cookies for various purposes such as:

To provide you BCCL Services

To provide non-personalized or personalized advertisements

To identify your location

To identify your browser and device.

For analytics and research

Measure and analyze the audience for each page in order to subsequently improve the ergonomics, browsing, or visibility of content

Measure the reliability of Website by analyzing the number of visits to its pages in real time, and offer varied ads that are adapted to users’ areas of interest

Cookies may also be saved by social media tools if you use these functionalities (e.g. Facebook, Twitter).

Type of Cookies

“First party Cookies” these are the cookies that belong to us and which we place on your device or are those set by a website that is being visited by the user at the time (e.g., cookies placed by BCCL Group).

“Third-party cookies” are cookies that another party places on your device through our site (For e.g. advertising agencies may place their cookies on our website which will collect tracking information and serve you with advertisements).

We use the following types of cookies:

Persistent Cookies. We use persistent cookies to improve your experience of using the sites. This includes recording your acceptance of our Cookie Policy to remove the cookie message which first appears when you visit the site.

Session Cookies. Session Cookies are temporary and deleted from your machine when your web browser closes. We use session Cookies to help us track internet usage as described above.

You may refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Sites. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will check if Cookies can be captured when you direct your browser to our Sites.

The data collected by the websites and/or through cookies that may be placed on your computer will not be kept for longer than is necessary to fulfil the purposes mentioned above. In any event, such information will be kept in our database until we get explicit consent from you to remove all the stored cookies.

We categorize cookies as follows:

Strictly Necessary/Technical

These Cookies are necessary to allow us to operate our Sites so you may access them as you have requested. These Cookies, for example, let us recognize that you have created an account and have logged in/out to access Site content. They also include Cookies that enable us to remember your previous actions within the same browsing session and secure our Sites

Analytical/Performance

These Cookies are used by us or third-party service providers to analyse how the Sites are used and how they are performing. For example, these Cookies track what content are most frequently visited, watch history and from what locations our visitors come from. If you subscribe to a newsletter or otherwise register with the Sites, these Cookies may be correlated to you. These Cookies include, for example, Google Analytics cookies, Comscore cookies.

Functionality

These Cookies let us operate the Sites in accordance with the choices you make. These Cookies permit us to “remember” you in-between visits. For instance, we will recognize your user name and remember how you customized the Sites and services, for example by adjusting text size, fonts, languages and other parts of web pages that are alterable, and provide you with the same customizations during future visits.

Targeting or Advertising Cookies

These cookies are used to deliver content that is more relevant to you and your interests. They are also used to deliver targeted advertising or limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns on BCCL Group and other websites. They remember that you have visited one of our websites and this information is shared with other parties, including advertisers and our agencies. These cookies may also be linked to site functionality provided by third-parties such as Google DFP and Affinity.

Do these cookies collect personal data/identify me?

Most types of these cookies track consumers via their Device ID or IP address therefore they may collect personal data.

Based on the type of cookies used by the relevant third-party, the information these cookies collect may include personal data but they would not be able to directly identify you as an individual or have any of your personal information such as Name, E-mail id or mobile number

Managing advertising cookies

Please note that if you want to opt out from receiving targeted advertising, this does not mean that you will receive less advertising when you use our Website. This just means that the advertising you see will not be as customised to you.

However if you still want to switch off third-party advertising cookies, you can turn do this by visiting the Internet Advertising Bureau’s consumer advice site, Youronlinechoices.com This will give you a list of all cookies that are currently set on your device and how to opt out of each of them.

How do I refuse or withdraw my consent to the use of Cookies?

If you do not want cookies to be dropped on your device, you can adjust the setting of your Internet browser to reject the setting of all or some cookies and to alert you when a cookie is placed on your device. For further information about how to do so, please refer to your browser ‘help’ / ‘tool’ or ‘edit’ section for cookie settings w.r.t your browser that may be Google Chrome, Safari, Mozilla Firefox etc.

Please note that if your browser setting is already setup to block all Cookies (including strictly necessary Cookies) you may not be able to access or use all or parts or functionalities of our Sites.

If you want to remove previously-stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Sites from placing further Cookies on your device unless and until you adjust your Internet browser setting as described above.

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