1.1 Welcome to Free Fire India (“FFI” or the “Game”) run by Garena Online Private Limited ("Garena", "we", "us" or "our"). Garena takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all users of FFI, including uses of its website (the "Site") and mobile application  (we refer to FFI, the Site and the other services referred to in our Terms of Service collectively as the "Services"). Users refers to a user who registers for an account or who otherwise uses or accesses the Services (individually and collectively, “users”, “you” or “your”). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This policy (“Privacy Policy”) is designed to assist you in understanding how we collect, use, disclose, transfer and/or process the personal data you have provided to us and/or possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data. Capitalised terms used in this Privacy Policy that are not otherwise defined have the meanings given to them in the FFI Terms of Service.

 

 

1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number, and contact information.

 

1.3 By using the Services, registering for an account with us or visiting our Site, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS THE GAME OR OUR SITE. If we change our Privacy Policy, we will notify you including by posting those changes or the amended Privacy Policy on the Site. We reserve the right to amend this Privacy Policy at any time. To the fullest extent permissible under applicable law, your continued use of the Services or Site, including making any purchases using or for the Services, shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.

 

1.4 This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.

 

 

2.1 We will/may collect personal data about you: 

• when you register and/or use our Services, the Game or Site, or open an account with us; 

• when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;

• when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;

• when you interact with us, such as via telephone calls, letters, face-to-face meetings, social media platforms and emails, including when you interact with our customer service agents; 

• when you use our electronic services, or interact with us via our Game or Site or use our Services. This includes, without limitation, through cookies which we may deploy when you interact with the Game or our Site;

• when you grant permissions on your device to share information with our Game or Site;

• when you link your Garena account with your Social Media Account (defined below) or other external account or use other social media features, in accordance with the provider’s policies;

• when you carry out transactions through our Game or Site (where applicable) or with our authorized third-party payment service providers;

• when you provide us with feedback or complaints;

• when you register for a contest, for games or game specific events;

• during your gameplay; and

• when you submit your personal data to us for any reason. 

 

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

 

 

3.1 The personal data that Garena may collect from FFI users includes but is not limited to:

• name, username and user ID;

• parent or legal guardian’s phone number (in case of minor); 

• transaction information (but not bank account or credit card information); 

• chat and other information about the people and accounts you interact with (only in case of you being reported for toxicity or another reason, by another user); 

•age (only <18 or >18);

• information sent by or associated with the device(s) used to access our Services, including IP address;

• photographs or audio or video content submitted via the Services; 

• marketing and communications data, such as your preferences in receiving marketing materials, your communication preferences and history of communications with us and our service providers;

• any information provided for purposes of customer service or grievance handling, including but not limited to name, phone number, email address, age, parent or legal guardian’s name, and payment method; ; 

• any other information provided when an FFI user signs up or uses the Services, including information shared via any linked social media account (“Social Media Account”) or other platform, which information may include email addresses, platform or account identifiers, nicknames, social media contacts, and platform or account transactions; and

• usage and transaction data, including data on activities, purchases, use of the Services and the advertising and other content that FFI users engage with.

 

 

3.2 You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. Subject to applicable law, we reserve the right at our sole discretion to require further documentation to verify the information provided by you.

 

3.3 If you sign up to be a user of our Services using your Social Media Account, link your account to your Social Media Account or use any Garena social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider's policies, and we will manage and use such personal data in accordance with this Privacy Policy at all times. 

 

3.4 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer / Grievance Offer in writing in accordance with Section 14, below. Further information on opting out can be found in the section below entitled "How can you withdraw consent, request access to or modify information you have provided to us?". Note, however, that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services. 

 

 

4.1 As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you use our Services. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our Game and Site.

 

 

4.2 As when you view pages or content on our Site or Game , most of the same information is sent to us (including, without limitation, IP Address, information about your operating system, etc.); but, instead of page views, your device sends us information on the content, advertisement viewed and/or software installed and time.

 

 

5.1 We or our authorized service providers and advertising partners may from time to time implement "cookies" or other features to allow us or third parties to collect or share information in connection with your use of the Services. These features help us improve our Site, Game and the Services we offer, help us offer new services and features, and/or enable us and our advertising partners serve more relevant content to you, including through remarketing, subject to applicable law. “Cookies” are identifiers we transfer to your computer or mobile device that record data about your computer or device, how and when the Services or websites are used or visited, by how many people and other activity within our Site and Game. We may link cookie information to personal data. Cookies may also link to information regarding what items you have selected for purchase or pages you have viewed. Depending on the relevant Services, this information may be used to deliver content specific to your interests, to enable us or our third party advertising partners to serve advertisements through the Services or on sites across the internet, and to monitor usage of the Services.

 

5.2 You may refuse the use of cookies or web beacons by selecting the appropriate settings or adjusting your preferences on your browser or device. However, please note that if you do this you may not be able to use the full functionality of our Site, Game or the Services. 

 

5.3 You may also be able to opt out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.

 

 

6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

(a) to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;

(b) to manage, operate, provide and/or administer your use of and/or access to our Services, Site and Game (including, without limitation, your preferences), as well as your relationship and user account with us;

 

(c) to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;

(d) to enforce our Terms of Service or any applicable end user license agreements;

(e) to protect personal safety and the rights, property or safety of others;

(f) for identification and/or verification;

(g) to maintain and administer and improve any software updates and/or other updates, to support the Services, including to troubleshoot, report, or address any issues (e.g., to respond to errors or crash reports) that may be required from time to time to ensure the smooth running of the Game and/or our Services; 

(h) to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;

(i) to contact you or communicate with you via voice call, text message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages; 

(j) to allow other users to interact, communicate, or connect with you, including to inform you when another user has sent you a private message or posted a comment for you via the Game or Site;

(k) to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services and/or to enhance your customer experience;

(l) to allow for advertising and other audits and surveys (via offline and online surveys, including on third party platforms (e.g. Google Forms)), to, among other things, validate the size and composition of our target audience, understand their experience with Garena’s Services, aid operations and enhance the game or customer experience; 

(m) for marketing and advertising for any marketing activities where permissible under applicable law, and in this regard, to recommend products and/or services relevant to your interests, to send you by various mediums and modes (including email or SMS) of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom Garena may collaborate or tie up with) that Garena (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters or marketing materials from us and from our related companies;

(n) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on Garena or on its related corporations or affiliates;

(o) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;

(p) to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;

(q) to audit our Services or Garena's business;

(r) to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;

(s) to store, host, back up (whether for disaster recovery or otherwise) of your personal data within your jurisdiction;

(t) to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves Garena as a participant or involves only a related corporation or affiliate of Garena as a participant or involves Garena and/or any one or more of Garena's related corporations or affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal, transfer of or financing of an organisation or a portion of an organisation or of a portion of or all of any of the business, business activities, or assets of an organisation; and/or

(u) to verify your qualification and/or to submit your application/request when you register for participation in the game specific contests, events or tournaments, and to give you rewards where applicable; and

(v) other purposes which are permissible under applicable law and which we notify you of at the time of obtaining your consent.

(collectively, the “Purposes”).

 

6.2 You acknowledge, consent and agree that Garena may access, preserve and disclose your Account information and Content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over Garena or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over Garena, (c) enforce the Free Fire India Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against Garena or other claim that any Content violates the rights of third parties; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of Garena, its users and/or the public.

 

6.3 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.

 

 

7.1 We implement a variety of security measures and operational controls, and we strive to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security. 

 

7.2 We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interest warrant further retention of such personal data. If you cease using our Services, or your permission to use the Site, Game and/or the Services is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

 

 

8.1 In conducting our business, we will/may need to disclose your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Such third parties include, without limitation:

• our subsidiaries, affiliates and related corporations;

• other users of our Services in connection with your use of the Services and for one or more of the above-stated Purposes;

• contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as mailing houses, game development partners, payment or financial services providers, advertising and marketing partners, telecommunication companies, information technology companies, and data centres;

• governmental or regulatory authorities having jurisdiction over Garena or as otherwise permitted under Section 6.2; 

• a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of Garena’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, or transition of any of our Services, in which personal data held by Garena about our users is among the assets transferred; or to a counterparty in a business asset transaction that Garena or any of its affiliates or related corporations is involved in, including any entity which succeeds or to which we transfer the operation of any of our Services; and

• third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

 

8.2 We may, among other things, disclose your gaming history and/or disclosing records showing which games were viewed or accessed by which IP addresses. We may also share statistical and demographic information about our users and their use of the Services with advertising partners and third party suppliers of advertisements, remarketing, and other programming subject to applicable law. 

 

8.3 Additionally, you may elect to export your user activity feeds as RSS feeds which may be subscribed to by other users, which may include information regarding your game play, installation of games, connections with other users and other information about your account activity which is published as a feed on the Site or Games. 

 

8.4 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply.

 

8.5 Third parties may unlawfully intercept or access personal data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.

 

 

9.1 The Services are not intended for children under the age of 18. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 18 without consent and verification from a parent or legal guardian, or unless permitted by law, nor is any part of our Site, Game or other Services directed to them. If you are under the age of 18, you will need to submit a parent or legal guardian’s phone number, as well as a one-time password generated on the parent or guardian’s phone, in order to register for the Game. As a parent or legal guardian, please do not allow such children under your care to submit personal data to Garena without your consent and please also consult Free Fire India’s Terms of Service for more information. In the event that personal data of a child under the age of 18 in your care is disclosed to Garena, you hereby consent to the processing of the child’s personal data and your acceptance and agreement to be bound by the terms of this Privacy Policy on behalf of such child. In the event you do not in fact consent to the processing of the personal data of a child under the age of 18 in your care, please contact our Data Protection Officer / Grievance Officer in writing as described in Section 14, below. We will close any accounts used exclusively by such children without parental or legal guardian consent and remove and/or delete any personal data that was submitted without parental or legal guardian consent by such child or as otherwise required by applicable law. 

 

10.1 Our Site and Games use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your device, to help the website analyse how users use our Services. The information generated by the cookie about your use of the Services or device (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our Services, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. We do not control the placement or collection of information from third party cookies, which are the subject of those third party’s privacy policies, nor the handling of any personal information collected by those third parties. Google’s privacy policy may be found at https://www.google.com/policies/privacy, and Google’s policies towards data security may be found at https://policies.google.com/privacy#infosecurity. The safe handling of data collected by Google is subject to Google’s policies and responsibility.

 

10.2 We, and third parties, may from time to time make software applications downloads available for your use on or through the Services. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your User ID, your device’s IP Address or other information such as what game you are playing during any given session, and any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by Garena. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise. 

 

 

11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you make purchases using or for the Services or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.

 

11.2 In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Site or Game. We may also participate in co-branding and other relationships to offer other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through our Site or Games) may not be received by us. 

 

11.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Site and Game and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).

 

 

12.1 Your personal data will be processed and stored in our servers in India or Singapore. Garena will only transfer your information overseas in accordance with applicable Privacy Laws, and you hereby consent to such transfer and processing. In the event of transfer to another country or region, we will take steps to ensure that your information receives the same level of protection as if, if it had remained in India.

 

 

 

13.1 Withdrawing Consent

 

13.1.1 You may withdraw your consent for the collection, use and/or disclosure and/or request deletion of your personal data in our possession or under our control by sending an email to our Data Protection Officer / Grievance Officer in accordance with Section 14, below. We will process such requests in accordance with this Privacy Policy and our obligations under applicable Privacy Laws and other applicable law. 

 

13.1.2 However, your withdrawal of consent and/or request to delete personal data in in our possession or control may mean that we will not be able to continue providing the Services to you, and we may need to terminate your existing relationship and/or the contract you have with us.

 

13.2 Requesting Access to, or Correction of Personal Data

 

13.2.1 If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the Account Settings page or tab on the Site or Game. If you do not have an account with us, you may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Please submit your written request by sending an email to our Data Protection Officer / Grievance Officer in accordance with Section 14, below. In addition, where required by law, we will take steps to inform any third parties who have received or used your Personal Data of such correction.

 

13.2.2 Where permitted under applicable law, we reserve the right to reject certain requests. In such cases, we will inform you and will provide you with a written estimate of any applicable fees. Subject to applicable law, will provide you the requested personal data within a reasonable time after you pay the applicable fees. 

 

13.2.3 Please submit your written request by sending an email to our Data Protection Officer / Grievance Officer in accordance with Section 14, below. Subject to applicable law, we reserve the right to only respond to data subject requests submitted in accordance with this Policy.

 

 

 

 

14. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
14.1 Our Data Protection Officer / Grievance Officer is named Lokesh Gupta, and may be contacted at dpo.in@garena.com.

14.2 If you have any questions, concerns or complaints about our privacy practices, please do not hesitate to contact our Data Protection Officer / Grievance Officer.

14.3 For any issues in relation to the collection and processing of your personal data, you may reach out to our Data Protection Officer / Grievance Officer , who will respond to your concerns and queries at the earliest and in compliance with applicable law. 
 

 

Last modified: 25 August 2023