Privacy Policy

Last Updated on 16th June, 2026

Gati Lite (the “Platform”) is operated by Dyumn Tech Private Limited, having its registered office at 101, D Definity Premises Co-operative Society Limited, Survey No. 95, Hissa No. CTS No. 364, Jayprakash Road No. 01, Goregaon East, Mumbai, Maharashtra, India – 400063 (hereinafter referred to as “Company”, “We”, “Us”, “Our”). We offer an online game as provided on the Platform (the “Game” and, together with the Platform, the “Services”).

This Privacy Policy (“Policy”) sets out Our practices for the collection, use, storage, processing, transfer and disclosure of personal information of Users. This Policy is an electronic record under applicable laws and does not require any physical or digital signature.

This Policy should be read together with Our Terms of Use available on the Platform (“Terms”). Capitalized terms used but not defined in this Policy shall have the meanings given to them in the Terms. By accessing Our Platform or availing Our Services, You consent to the collection and processing of Your Personal Information by the Company in accordance with this Policy and for the purposes stipulated herein.

The Services are made available to Users worldwide. We handle your Personal Information in accordance with all the applicable data protection and privacy laws, regulations and statutory requirements in force from time to time in the jurisdiction relevant to the Users as on the relevant date which may include the (Indian) Digital Personal Data Protection Act, 2023, the General Data Protection Regulation (EU) 2016/679 and its United Kingdom equivalent (“GDPR”), and applicable state privacy laws of the United States (collectively, “Applicable Privacy Laws”).

1. Who does this Policy apply to?

1.1 This Policy applies to (a) all persons accessing Our Platform; and (b) all persons participating in the Game offered by Us or using any of Our Services offered on Our Platform (hereinafter referred to as “User”, “You”, “Your”).

1.2 The Platform and the Services are intended only for persons who are above the age of majority applicable in their jurisdiction. Please see Paragraph 10 below.

2. What data do We collect?

2.1 In the course of providing the Services to the Users through the Platform, We may collect the following information (“User Information”):

Contact and registration information: Your phone number (verified through OTP) and/or email address, used for communication and for registering on Our Platform, together with account administration information (e.g., username and security information).
Single sign-on information: If You register or log in using Your Google account (“Google SSO”) or, on Apple devices, using Sign in with Apple, We may receive information associated with that account, such as Your name, email address and account identifier, in accordance with Your settings with that provider.
Game and profile information: Your game preferences, activities, profile information (including username, game progress, scores, achievements) to improve the Services and provide You with relevant suggestions.
Purchase information: In-App Purchases are processed by the Apple App Store or Google Play Store. We do not collect or store Your full payment card or bank details; We receive transaction confirmations and related identifiers from the relevant store, and information relating to Bank Payment Reversals for fraud prevention and recovery purposes.
Device and technical information: When You log in to or use the Platform, We gather data on (i) the type of mobile device You use; (ii) Your mobile device’s unique ID; (iii) the IP address of Your mobile device; (iv) Your mobile operating system; (v) the type of mobile internet browser You use; (vi) coarse (approximate) location and (vii) unique device identifiers, and other diagnostic data.
Referral program information: Referral Codes used or shared, the relationship between Referring Users and Referred Users, and milestone or reward data in connection with the User referral program described in the Terms.
Giveaway information: Information You provide when entering Giveaways, including information needed to verify eligibility and deliver rewards.
Support communications: Information You provide when You contact Us or the Grievance Officer.
Any other information as required to investigate and manage fraud, Bank Payment Reversals, abuse of the referral program or Giveaways, or other violations under the Terms or applicable laws.

2.2 This Policy shall not apply to User Information that does not qualify as ‘personal information’ or ‘personal data’ under the Applicable Privacy Laws (“Personal Information”). We may create and use aggregated and/or anonymized data derived from User Information for Our legitimate business purposes, including analytics, improvement of the Services and commercial purposes, provided that such data does not identify any User. Any such non-personal, aggregated or anonymized information may be used, processed or disclosed by Us without the restrictions set out in this Policy.

3. How do We collect Your data?

3.1 We collect Personal Information directly from You when You: (a) register on Our Platform; (b) use the Platform or play the Game; (c) make In-App Purchases; (d) participate in the referral program or Giveaways; or (e) contact Us.

3.2 We also receive Your data indirectly from the following sources: (a) Google, if You link Google SSO with Our Services; (b) Apple, if You use Sign in with Apple; (c) the Apple App Store or Google Play Store, in connection with Your purchases; and (d) Our analytics and advertising partners, as described in Paragraph 6.4.

4. How do We use Your Personal Information?

We use the Personal Information for the following purposes:

4.1 Providing Our Services: The processing of Personal Information is necessary to enable the User to use the Services via the Platform.

4.2 Sending Services-related communications: We may send You push notifications or alerts to Your mobile device, emails to Your registered email ID or texts to Your registered phone number to provide Service-related information and, where You have agreed to receive them, special offers, promotions and other marketing messages.

4.3 Improving the Services: To analyze Users’ choices and usage patterns, including the frequency and duration of visits, to diagnose problems with Our servers, and to improve Our systems, Platform and Services. We may combine information We receive from third parties with information You give to Us and information We collect about You for these purposes. We analyse log files that may contain IP addresses, browser type and language, internet service provider, referring and exit pages, app crashes, pages viewed, operating system, date/time stamps and clickstream data, which helps Us administer the Platform, understand User behavior and gather demographic information about Our User base as a whole.

4.4 Personalization and advertising: To personalize Your experience and the advertisements that may be displayed on the Platform, including sharing certain data with Our authorized third-party partners for advertising analytics as described in Paragraph 6.4, with Your consent where required under Applicable Privacy Laws.

4.5 Security and fraud prevention: To protect You and other Users from fraudulent activities and transactions (including in connection with Bank Payment Reversals, multiple accounts and abuse of the referral program or Giveaways) and to protect against unauthorized access.

4.6 Compliance with legal obligations: To meet Our legal obligations under applicable laws.

4.7 Market research and reporting: For market research, data solutions and report creation, using aggregated information wherever feasible.

4.8 New purposes: We shall approach the User for the User’s consent for any other specific purpose not listed in this Policy.

4.9 Legitimate Interests: To fulfil Our legitimate interests, or those of a third party in conducting and managing Our business and Our relationship with You as described in this Policy.

5. Where is Your Personal Information stored?

5.1 The Personal Information that We collect in respect of the User is hosted within India. Our third-party partners or service providers may store the Personal Information within or outside India, subject to the safeguards described in Paragraph 7 and in accordance with their respective privacy policies.

5.2 International transfers: Where Personal Information is transferred to a country other than Your own, We will ensure that the transfer is carried out in accordance with Applicable Privacy Laws, including, where required, on the basis of an adequacy decision, standard contractual clauses or other lawful transfer mechanisms providing appropriate safeguards.

6. Why and when do We transfer/disclose Your Personal Information?

We may transfer or disclose the User’s Personal Information within and outside Your jurisdiction (provided that such country offers the same or greater level of protection for Personal Information than Your jurisdiction), in the following manner:

6.1 To affiliated companies, entities and service providers, within or outside Your jurisdiction, that have been contracted to offer services on behalf of the Company. These service providers and vendors are only permitted to use the disclosed Personal Information in accordance with the instructions provided by the Company via binding documents enforceable by the law.

6.2 If required by law, legal process, litigation and/or requests from governmental or regulatory authorities, or for the purpose of national security, law enforcement or other issues of public importance, including cyber incidents and the prosecution and punishment of offences.

6.3 In connection with a sale, divestiture or transfer of the Company (including any shares) or any combination of its products, Services, assets, affiliates and/or businesses, including in the course of mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations or similar transactions or proceedings, in which case the User’s Personal Information may be among the items transferred.

6.4 To Our third party partners who may process User Information on Our behalf for the functionality of their services to display advertisements and perform analytics or other support functionality and provide such analytics to Us. Any collection, processing, storage, and retention of User Information by such third-party partners shall be subject to and governed by their respective privacy policy. You can control and limit our use of your advertising ID by changing the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android) or opt out of targeted ads in the settings in the app by turning off targeted ads.

6.5 With any other third party, only with the consent of the User for such disclosure.

7. How do We protect and retain Your Personal Information?

7.1 Security safeguards: We value the security of the User’s Personal Information and have implemented reasonable technical and organizational security measures designed to protect it from unauthorized access, disclosure, use and modification. From time to time, We review Our security procedures to consider appropriate new technologies and methods. Please be aware, however, that no data security measures can guarantee complete security. If We learn of a security breach, We will notify affected Users and the relevant authorities where and as required under Applicable Privacy Laws and may also post a notice on the Platform and take steps to remediate the breach. If You have any questions about the security of Your Personal Information, please contact the Grievance Officer.

7.2 Retention: We shall retain the User’s Personal Information only for as long as is necessary for as long as (i) the User’s account is active and We have a continued relationship with the User; (ii) needed to comply with Our legal, statutory and contractual obligations; and (iii) needed to provide the Services to the User. Thereafter, Personal Information is destroyed appropriately and securely or anonymized in accordance with applicable laws. Please note that, as described in the Terms, an Account may be terminated after 12 (twelve) months of continuous non-use, following prior notice.

8. What are Your rights and obligations in relation to Your Personal Information?

8.1 Save and except the rights provided in this Policy, all rights to the Personal Information shall belong to the User. The User shall: (a) provide true and accurate details of Personal Information; (b) keep their information up to date; (c) regularly review this Policy; and (d) keep their account credentials confidential and notify the Company of any security breaches.

8.2 Subject to Applicable Privacy Laws, You have the following rights in relation to Your Personal Information:

Right to know what Personal Information We hold about You and to have that information communicated to You;
Right to access copies of Your Personal Information. The first copy will be provided free of charge; We may charge a reasonable fee for additional copies only where permitted under Applicable Privacy Laws;
Right to request that the Personal Information held by Us be corrected, rectified, updated or deleted;
Right to object to the processing of the Personal Information or to request restriction thereof;
Right to data portability, where provided under Applicable Privacy Laws;
Right to opt out of targeted advertisements;
Right to withdraw Your consent to the processing of any or all Personal Information, or to decline to provide any permissions on the Platform, at any time;
Right to nominate another individual to exercise Your rights in the event of death or incapacity, where provided under Applicable Privacy Laws (including the Digital Personal Data Protection Act, 2023); and
Right to lodge a complaint with the data protection authority of Your jurisdiction (for example, Your local supervisory authority in the EU/EEA, the Information Commissioner’s Office in the UK, or the Data Protection Board of India), without prejudice to any other remedies available to You.

8.3 Any request to access, update, delete or correct Personal Information, or to withdraw consent, should be shared with the Grievance Officer as per Paragraph 13 below. We will action such requests without undue delay and within the timelines prescribed under Applicable Privacy Laws, and Your request shall take effect no later than 5 (five) business days from receipt (or such shorter period as required by law), after which We will not use Your Personal Information for the relevant processing unless required to comply with Our legal obligations.

8.4 If You object to the processing of Personal Information, withdraw consent or delete Personal Information, Your access to the Platform and Services may be limited, or We may not be able to provide the Services to You.

8.5 We will evaluate requests for deletion of Personal Information in accordance with applicable law. Information sought to be deleted may remain with Us in archival records for the purpose of compliance with statutory enactments or other lawful purposes. You are therefore requested to carefully evaluate what information You provide to Us.

9. Links to third-party websites/apps

9.1 We may, through Our Platform, provide links to third-party platforms. We do not make any representations or warranties with respect to such third-party platforms and are not responsible for the practices employed by such platforms, applications or services, including the information or content contained there. Your use of such third-party platforms is subject to those third parties’ own rules, policies and practices, and not this Policy. We encourage You to review the applicable terms and privacy policies of any third-party platform before engaging with it.

10. Should children access this Platform?

10.1 The Platform and the Services are intended only for persons who are above the age of majority applicable in their jurisdiction. We do not knowingly collect or process Personal Information of any person below such age.

10.2 Subject to the Applicable Privacy Laws, the Company does not undertake any independent verification, background checks or due diligence to confirm the age of its Users and relies on the information and representations provided by Users for this purpose. If We become aware that Personal Information of a person below the applicable age has been collected or processed, We shall take prompt steps to delete or anonymize such information and terminate the related account, unless retention is required to comply with applicable legal obligations. If You are a parent or legal guardian and believe that Your child has provided Personal Information to Us, please contact the Grievance Officer as per Paragraph 13.

11. How do We update this Policy?

11.1 This Policy is current as of the Last Updated date set forth above.

11.2 We may periodically change this Policy to keep pace with new technologies, industry practices and regulatory requirements, among other reasons. Where We make material changes to this Policy, We will provide Users with reasonable advance notice through the Platform, by email or by other reasonable means, and, where required under Applicable Privacy Laws, We will seek Your consent. Subject to applicable laws, Your continued use of the Services after the effective date of the updated Policy constitutes Your acceptance of the changes. If at any point You do not agree to any portion of the updated Policy, You must immediately stop using the Services and may delete Your Account. You can see when this Policy was last updated by checking the “Last Updated” date at the top of this Policy.

12. Governing Law and Dispute Resolution

12.1 This Policy shall be governed by and construed in accordance with the laws of India and the Parties agree that they are bound by the laws of India for the purposes of this Policy.

12.2 Any dispute, claim or controversy arising out of or in relation to this Policy shall be resolved in accordance with the dispute resolution provisions set out in Paragraph 30 of the Terms.

13. How to contact Us?

Any complaints or concerns with regard to the collection and processing of Personal Information, the exercise of Your rights under this Policy or any breach of this Policy may be taken up with the Grievance Officer appointed by the Company. The details of the Grievance Officer are as follows:

Grievance Officer: Mr. Kamal Upadhyay

Email: grievance@virbhumi.com

Address: 101, D Definity Premises Co-operative Society Limited, Survey No. 95, Hissa No. CTS No. 364, Jayprakash Road No. 01, Goregaon East, Mumbai, Maharashtra, India – 400063

The Grievance Officer shall acknowledge and dispose of complaints within such time period as prescribed under the applicable laws of the User’s jurisdiction, where applicable. As set out in the Terms, the Grievance Officer also acts as the Company’s single point of contact for Users in the European Union for the purposes of Regulation (EU) 2022/2065 (the Digital Services Act) and may be contacted in English.