Policy for Law Enforcement Authorities (“LEA”) in India Seeking Data from Junglee Games India Private Limited

Junglee Games India Private Limited (hereinafter referred to as “JGIPL/Junglee Games/Company”) having CIN number U72200DL2011PTC219472 is incorporated as a private limited company under the provisions of the Companies Act, 1956, with its corporate office at 6th Floor, North Tower, Smartworks, Vaishnavi Tech Park, Sarjapur Main Road, Bellandur, Bengaluru, Karnataka 560103. Junglee Games operates as a responsible gaming platform and is a member of E-Gaming Federation (“EGF”). Junglee Games offers various skill-based online games including Junglee Rummy, Rummy.com, Junglee Poker, Howzat, Junglee11 and Junglee Ludo. More details on the responsible gaming practices of the Company can be referred to on the ‘Responsible Gaming’ page available on all gaming websites and apps. The games and data are hosted in India. Junglee Games has also appointed Ms. Apoorva Sharma as a Nodal Officer. Read More


This policy is solely intended for Law Enforcement Authorities (“LEA”) in India seeking information from Junglee Games. You can also refer to our Privacy Policy and Terms of Service for more general information about the company and the player/user accounts. You can also refer to our Privacy Policy for understanding the type of data collected by Junglee Games from players/users. We reserve the right to amend this policy and other policies and Terms of Service from time to time. Also, please note that this policy does not apply to requests from LEA outside India. We respect the privacy of players/users and are committed to protecting the player/user data on our platform. Therefore, any request for data records from Junglee Games must comply with the legal requirement and lawful purposes. Junglee Games has a dedicated channel for receiving, tracking, processing, and responding to legitimate legal requests/notices from LEA. A trained team in our disputes channel reviews all notices/requests received from LEA. LEA in India seeking information from Junglee Games about a player/user account can write to us at disputes@jungleegames.com from their official Government email address (Gov.in/nic.in). We reserve the right to disclose data upon receipt of a request following the valid legal process, which could include notice under Section 91 of The Code of Criminal Procedure 1973 (“CrPC”) or under Section 94 of the Bhartiya Nagrik Suraksha Sanhita, 2023 (“BNSS”) as per the procedures laid down under the aforesaid legislations. 


Definitions

APK:

Android Application Package or Android Package Kit

BNSS:

Bharatiya Nagarik Suraksha Sanhita, 2023

CrPC:

The Code of Criminal Procedure, 1973

iOS:

Apple Store / iPhone operating store

KYC:

KYC verification includes the verification of the registered user’s identification document (“ID”), address, and mobile number.

LEA:

Law Enforcement Authorities responsible for enforcing the Law, such as police officials, CBI officials, Cyber Cells, CID, Anti-Corruption Bureau officers, etc.

PSRMG:

Play store real money games - Rummy and Daily Fantasy Sports (DFS)

1. How to raise a data request with Junglee Games?

  • LEA in India seeking information from Junglee Games about a player/user account can write to us at disputes@jungleegames.com; The request must be submitted via a valid Government email address domain, i.e., Gov.in/nic.in;
  • The request notice must be a legal process, i.e., a request notice marked under Section 91CrPC or Section 94 BNSS;
  • We respond to data requests from LEA through our dedicated channel for disputes@jungleegames.com. Therefore, the requests must be submitted to disputes@jungleegames.com.
  • The notice under 91CrPC or Section 94 BNSS must be addressed to the proper entity - Junglee Games India Private Limited;
  • The request must include the case number/DD number/complaint number/FIR number or any number that shows the commencement of the investigation;
  • For our convenience, you can also disclose the nature of the case or any relevant sections under the Indian Penal Code (“IPC”) or Bhartiya Nyay Sanhita (“BNS”) or under any other applicable law in India and provide us with any other information that may assist us in understanding your requirement / necessity / relevancy of the data request from us;
  • Kindly also provide us with appropriate identifiers such as transaction details, transaction reference number, amount, date, time and PII of the user, etc. which would enable us to conduct our searches accurately and assist us in locating the user account / transaction details;
  • Where requests contain transaction details, beneficiary merchant/bank, and fraudster identification, such as KYC, device serial/IMEI numbers, IP address, geolocation, email address, and receiver mobile number, these should be provided . Identifiers such as these are generally required to conduct thorough investigations for fetching information related to devices, accounts, or financial transactions.

2. Managing and responding to complaints received from LEA

  • If Junglee Games finds any request unclear or inappropriate or incomplete, it will raise its concerns with the LEA for seeking further clarification on the same or request more information for conducting internal searches for identifying/retrieving the data.
  • Junglee Games shall make all the endeavours to provide the requisite information within 24 hours. However, for cases wherein it may take some time to fetch information from the internal database, it will inform the LEA a reasonable timeframe, within which the data is shared.

3. Requests that may be fulfilled by Junglee Games

Requests made in the following manner may not be fulfilled by Junglee Games:

  • Unwritten requests such as verbal/on-call requests;
  • Requests not accompanied by a Notice under 91CrPC or Section 94 BNSS or Court order, etc;
  • Requests not directly coming from a Government email address (Gov.in/nic.in);
  • Requests made via social media channels like WhatsApp, Telegram, LinkedIn, Twitter, Facebook, etc.

4. Information to be provided by LEA to Junglee Games

The LEA is requested to provide exhaustive information and sufficient identifiers to assist in conducting internal searches for the identification of the transaction / account details. If required, Junglee Games may request the relevancy of the data request to LEA’s investigation / case in order to assist LEA with the most relevant information and in order to protect the data of the players / users.

5. Information that can be provided by Junglee Games to LEA

Upon a clear mention of the data request in the notice issued to us under Section 91CrPC or Section 94 BNSS, Junglee Games can provide the below-mentioned requested data set as per the records:

  • Transaction history or wallet statement of a Junglee Games player / user account to the LEA, in addition to the below-mentioned information.

Junglee Games can provide the following information in respect to a player account: Registration date, name, mobile number, email address, address, PAN, KYC details, transaction information, withdrawal details, bank account information, transaction IP address of the device when the transaction was initiated and Latitude/longitude of any cash activity done by the player.

Provided that:

  • The above-mentioned details can be shared only for the cases where the same is available.
  • Junglee Games shall provide only the information specifically requested in the request notice.
  • Paymode data is not available with us. It can be shared by the corresponding Payment Aggregator. We can share the name of the Payment Aggregator involved in a particular transaction.
Disclaimer Image

DISCLAIMER: This policy is provided in order to facilitate the timely response to all requests submitted by LEA. Junglee Games will make all its endeavours to provide true and correct information as available in its official records at the time when the information is sought.

In case you have any queries or need support in connection with this policy, you can reach out to our Nodal Officer / Nodal Contact Officer Ms. Apoorva Sharma at nodalofficer@jungleegames.com.

Frequently Asked Questions (FAQ)

Yes, Junglee Games has a dedicated disputes channel which handles all the requests coming from Law Enforcement Authorities. Our Disputes team can be reached at disputes@jungleegames.com.

As per the CrPC and BNSS, if any officer-in-charge of a police station considers that the production of any document or any transaction details is required for investigation, inquiry, trial, or other proceedings, they may request such information by issuing a notice under Section 91CrPC or Section 94 BNSS for requesting such information.

Yes, it shall be provided only if specifically required by the Investigating Officer.

Yes, Junglee Games follows Responsible Gaming practices and more information regarding those practices can be referred to here

The data is safely and securely stored in the servers located in India.

For iOS / Apple Store, APK: KYC verification is mandatory for a registered user either upon achieving a cumulative deposit of ₹50,000/- or first withdrawal, whichever is earlier. For PSRMG: KYC verification is mandatory for a registered user for any cash activity or any cash deposit. In addition, we also reserve the right to verify the PAN and/or KYC documents (ID and address) of the players from time to time. For more information on KYC verification, you can refer to our terms of service published on our website and app.

Yes, Junglee Games has appointed Ms. Apoorva Sharma as the Nodal Contact Officer / Nodal Officer. Junglee Games handles the requests from Law Enforcement via disputes channel - disputes@jungleegames.com. In case of any queries in relation to this policy, LEA can also directly reach out to the Nodal Contact Officer / Nodal Officer at nodalofficer@jungleegames.com.

Template for issuing notice under Section 91CrPC or Section 94 BNSS*

To: Junglee Games India Private Limited

Date:

Complaint number/FIR number/DD number:

Nature of the request/investigation/complaint:

Information sought:

Identifiers/Identifications of the data subject:

Other relevant information/description that would assist us in understanding the reasoning for seeking the above-mentioned information:

Name of the Investigating Officer:

Designation/authority/signature/stamp:

* Please note that this is a mere sample format and should not be construed as a notice under Section 91CrPC or Section 94 BNSS.

* We advocate a safe, fair, and transparent online gaming environment where all players can enjoy gaming responsibly.