Privacy Policy

HIGHXP Private Limited (hereinafter referred to as "we", "our", "us" and “HIGHXP” and shall include any affiliates) are committed to protecting the information and data shared by all of our users (hereinafter referred to as “you”, “yourself” and “user”). In light of the same, we have created this privacy policy (“Privacy Policy”) in compliance of all applicable laws including the General Data Protection Regulation 2016/679. The Privacy Policy applies and has effect in respect of all games, related online services (including online interactions and network play), as well as any other products made available by us (collectively referred to as the “Games”) as well as any other features relating to the Games that may be provided by HIGHXP on any technology platform or its website For the purpose of this Privacy Policy the Games and other services of HIGHXP are collectively referred to as “Services”.

The privacy mechanism outlined in this Privacy Policy, as amended from time to time, identifies personally identifiable or personal information that may be collected, how such information is used, and the choices you have regarding our use of this information.

This Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Services is processed, we are the “data controller.”

Please read this privacy policy carefully as by accessing or using the Platform, you agree to be bound by the terms described herein and all the terms incorporated by reference. Any information provided to us is subject to this Privacy Policy. If you do not agree to any or all of these terms, do not use the Games or the Services. Should you continue to access and use the Games or Services and provide your personal information, such act would constitute your consent to the terms contained herein. Terms which are capitalized but not defined herein shall have the meaning assigned to them in the Terms of Use

This Privacy Policy forms a part of and should be read in conjunction with our Terms of Use.”

1. Your Consent and Basis for collection of personal data

1.1 A prerequisite for obtaining access to the Games and usage of the Services is the acceptance of this Privacy Policy. This Privacy Policy shall apply to all users. You grant your consent to be bound by the terms of this Privacy Policy by:

(i) accessing or logging into the Games in the manner as provided for in the Terms of Use;
(ii) submitting any information to HIGHXP;
(iii) using the Services offered by HIGHXP;

1.2 As part of providing our Services to you, we may need to send routine communications to you, such as order transaction emails and other administrative messages through email and notifications posted on the Games, where applicable, or through other means available, including text and other forms of messaging. Though we prefer to communicate with the users via email, as may be deemed necessary, you agree to receive our phone calls, related to performance of Services or any other mode of communication as may be deemed appropriate by HIGHXP.

1.3 By providing your information for accessing and playing a Game or for availing our Services you also consent to us to periodically send emails about new products, special offers or other information that could be of interest to you. If you do not wish to receive promotional information from us, you can, at any time, choose to opt out of receiving such promotional communications by following the process mentioned in the promotional communication.

1.4 You must ensure to provide us with the correct or up-to-date personal information at the time of registration and during the use of our Services. This will allow us to contact you for further correspondences with respect to the Services, including in relation to any in-game purchases you may make. We are not responsible for any inaccurate information you provide to us, which may affect your experience when accessing the Games and the Services.

1.5 If, at any time, you want to access, update, modify or eliminate any information provided by you or which forms a part of the account created with HIGHXP, you may do so by writing to us on You may also withdraw your consent for use of your personal information and stop using the Services for which consent is required. HIGHXP reserves the right to stop providing any Services to which consent has been withdrawn.

1.6 If you are based out of the EU, we rely on the following basis for processing your personal information:

a. Legitimate interest, which means our interest in conducting and managing our business to enable us to provide you with the best Services and Games, and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
b. Performance of a contract, which means we process your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

c. To comply with a legal obligation, which means processing your personal information where it is necessary for compliance with a legal obligation that we are subject to.

2. Information that may be collected

2.1 By downloading accessing and playing the Games or availing the Services of HIGHXP you agree that HIGHXP may collect relevant information for the purposes as set forth in this Privacy Policy. This includes the following data and information:

a.Information you provide us

● Contact information (such as your name and email address)
● Your age
● Your gender
● Your Profile Picture
● Information that you provide when seeking help from our customer service (such as chat logs, emails, contact details such as your phone number and email address if necessary to resolve your request) and other information you provide to us.
● Any other information that is provided to us by you, including, without limitation, financial information in relation to in-app purchases

b.Information we automatically collect directly from you when you use our Services

● Information about your game progress and activity
● Information about your interactions with other players
● IP address and device identifiers
● Information about your device
● Information we collect using cookies and similar technologies
● General geolocation information such as GPS
● Aggregated data in relation
● Such other information that may be relevant to the Services and is provided by you
● If you choose to use the communication features in our Services to communicate or share information with other players, then we'll collect information on what is communicated and shared. This includes:

a) Your participation in player forums and message boards
b) Your public posts or comments on other player's profiles or game boards
c) Your non-public messages or invitations to other players, made directly on our website or through in-game mechanisms
d) Your posted photos, drawings or other user-generated content

c. Information that may be collected if you use our Services with a guest account

Depending on which of our Services you interact with we may collect and process details about how you use and interact with our Games, advertising, and other Services (for example, information about how and when you play our Games, what advertisements you have clicked on and what you have skipped etc.). If you choose to connect through your Facebook account, the personal data that we collect when you play our Games will be anonymous, but we will collect device level identifiers and other information associated with those identifiers including:

a. the type of device(s) you are using to play our Games or access our Services, identifiers such as IP address, device identifiers, ad identifiers, a Game ID, and the country or region that you are playing in; and
b. how you play our Games and interact with our websites (such as level start, level end, session start, booster use, spending, rewards, your progress through the Games, session time and duration, number of attempts at each level and purchases made).

2.2 Information that may be provided by third parties

When you access the Games via a third-party service provider such as Facebook, Google, Apple etc., we may collect and store personal and non-personal information which is made available by that third party service provider, such as your Facebook name, your profile picture or its URL, your Facebook ID, spend data on Google store and other public data of your friends that is provided by such third service providers. We will also receive technical data in order to ensure the Games connect to the correct third-party service provider account. You will also be able to use your account to log in on multiple devices and synchronize progress across those devices. We recommend that you review the privacy policies of such third-party service providers to identify how your data is being processed and shared by them as well. Accessing the Games through such third-party service providers will not allow us to post anything on your accounts maintained with such third-party platforms.

2.3 We and our third party service providers may also collect the following information for advertisement and analytic purposes to optimize the Services for you:

a) ad identifiers and other non-personal data collected from your device;
b) the Games you play and information about how you interact with our Games and Services;
c) country or region; and
d) other information that is shared by our third-party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us
e) any other data shared by you

2.4 The Games and Services may enable users to communicate with other users or third-party service providers to post information to be accessed by others, whereupon other users may collect such data. HIGHXP hereby expressly disclaims any liability for any misuse of such information that is made available by users in such a manner.

3. How will the information collected be used?

3.1 Our primary commitment to the users is to ensure that we deliver the features promised and functioning of the Games as per industry standards, so that you have the best experience when playing our Games. In light of the same, the manner in which we use the information is listed out herein below:

a. To provide, maintain and improve our Games and Services, including without limitation:
i. To create account and permit users to access and play our Games
ii. Provide gameplay basis user performance and preference
iii. Verify and confirm payments
iv. Maintain and update user’s profile
v. Enable social features
vi. Provide offers within the game
vii. Enable personalization and customization of game features to enhance user experience and enjoyment
viii. Provide player support
ix. Communicate with players regarding service update, security alerts, technical notices, outages and respond to support messages
x. Monitor APP performance, debugging and to improve our Games and Services

b. To provide a safe experience:
i. Analyse and monitor social features
ii. Prevent fraud and take action against fraudulent activities
iii. to measure interest in our Services;
iv. to ensure internal quality control

c. To comply with all applicable laws
d. To perform such other functions as otherwise expressly set out in this Privacy Policy or as required by law.

3.2 We share the information with our third-party service providers for the purposes set out herein above and for; (i) ensuring that our Services function properly so that you and other users have the best experience when playing our Game(s) and using the Services; (ii) improving the quality of our Services, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Games and Services, (iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.

3.3 We may also use ad identifiers, software development kits (“SDK”) and similar technologies made available by our third-party service providers to

a. recognize you and your device;
b. provide interest-based advertising to you;
c. enable us and our third-party service providers to provide you with more customized services, for example to provide our Services in the correct language.

The ad identifiers specified in section 3.3 are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising, which are uniquely associated with your device and may include other identifies such as tags and pixels. These technologies allow third party service providers to recognize your device when you access the Games and Services.

3.4 Non-personally identifiable information, exclusively owned by HIGHXP may be used in an aggregated or non-personally identifiable form for internal research, statistical analysis and business intelligence purposes including those for the purposes of determining the number of visitors and transactional details, and HIGHXP may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates.

3.5 We process personal data for our legitimate interests of ensuring that any use of the Services is lawful and non-fraudulent, does not disrupt the operation of our Services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations.

3.6 Where we reasonably believe that you are or may be in violation of any applicable laws or our terms of use, we may share your personal information with relevant law enforcement agencies in relation to such alleged violation.

3.7 HIGHXP shall not be responsible in any manner for the authenticity of the personal information supplied by the user to HIGHXP. If a user provides any information that is untrue, inaccurate, not current, or incomplete (or becomes untrue, inaccurate, not current, or incomplete), or HIGHXP has reasonable grounds to suspect that such information is untrue, inaccurate, not current, or incomplete, HIGHXP has the right to suspend or terminate such access to the Games or Services at its sole discretion

3.8 We may use automated decision-making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy. We process your personal information via automated decision-making methods in order to identify users who are cheating in the Games. We may block users from the Games and/or the Services who are determined to be cheating following an automated decision process. In this scenario the user will be notified of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision to block access to the Games and/or the Services.

3.9 With your consent, we may use the data provided by you for additional purposes.

3.10 Advertisements

a. We may process data collected from you to show you personalized advertisements, including advertisements for third party services. The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements.

b. In case you click on any advertisements, we request you to read the privacy policy of the third-party service provider to whose platform or website you are redirected to, as the third-party services process your data based on their privacy policy. HIGHXP shall have no liability for any data collection or processing by such third-party service providers on their websites or platforms.

4 Who we may share the data with?

4.1 Group members, personnel, suppliers, or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company, and its subsidiaries, as defined in the Companies Act, 2013), our personnel, suppliers, or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy subject to obligations of confidentiality and data protection at least as stringent as the term of this Privacy Policy.

4.2 Payment service partners and websites.

4.3 To government institutions/ authorities to the extent required i) under the laws, rules, and regulations and/ or under orders of any relevant judicial or quasi-judicial authority; ii) for the purposes of prevention, investigation, and prosecution of cyber incidents; iii) for reporting any offences committed by users; iv) to protect and defend the rights or property of HIGHXP; v) to fight fraud and credit risk; vi) to enforce HIGHXP's Terms of Use (to which this Privacy Policy is also a part); vii) for verification of any information provided by users; or viii) when HIGHXP, in its sole discretion, deems it necessary in order to protect its rights or the rights of others.

4.4 To Third Party Service Providers and Partners:
a.We may share your information collected under this Privacy Policy with our third-party service providers and partners whose services are necessary for providing the functionalities of the Game and Services. The Games and Services may incorporate SDKs and application programming interfaces (“API”) provided by third party service providers and partners for ensuring that best experience for our users. These third-party service providers and partners will process the personal information provided by HIGHXP in compliance with HIGHXP’s instructions in order to provide the agreed upon Services and Games and for the purposes as set out in Clause 3.2 of this Privacy Policy. Such third-party service providers and partners shall include technical support providers who assist with our Services and Games, service providers who assist us by providing services such as hosting, player support, advertising, analytics and fraud prevention and professional advisers such as solicitors, accountants, tax advisors, auditors and insurance brokers. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers and partners to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions or as per the terms of our agreements with such third-party service providers and partners. The third-party service providers and partners may obtain your consent for further processing of the data for their own use as per their own privacy policies.

b. We may also provide your personal data to our marketing and advertising partners who help us to serve ads to you by combining information received from us with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties or through SDKs and API’s that are inserted in the Games and Services. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see and serve ads to you when you visit third party services or if they determine that you would be interested to see an advert for HIGHXP’s Games or Services, they will serve you with a HIGHXP ad while you are using other websites and services.

c. We work with numerous third-party service providers and partners to provide the Games and Services to you, and by playing our Games and availing our Services you consent to us sharing your personal data with such third party service providers and partners. These partners may use cookies, web beacons, and other tracking technologies to collect or receive data about you and might claim controller rights over your personal data. You can view the partners with whom your data may be shared along with their privacy policies and opt out provisions on the following link:

4.5 Mergers and Acquisitions: where substantially all our assets are acquired by a third party, such information may be one of the assets that is transferred or acquired by a third party. Under such circumstances, HIGHXP would attempt to ensure that the third party acquiring HIGHXP follows the provisions of this Privacy Policy and process your personal information as set forth in this Privacy Policy.

5.How long will personal information be retained

5.1 Under normal circumstances the personal information collected by HIGHXP will only be retained for such periods of time as you continue to access the Games or as may be required for the provision of Services. We may further retain the other information for a period of 2 years, or such other period as may be prescribed by applicable laws including for such period as may be required for resolving disputes or answering requests from governmental or regulatory authorities. Confidentiality of such information shall be maintained during the period of retention.

6. Security Policy

6.1 HIGHXP takes careful precaution to protect our user's personal information from unauthorised access, improper use or disclosure or unauthorised modification. To prevent unauthorised access, we have put in place the latest industry-standard security technology and procedures to safeguard the information we collect online including technical, operational, and physical security controls. Your personal information is encrypted and is protected with the most secure encryption software, which encrypts all information you input. We store your personally identifiable information on computer servers placed in a secure environment. HIGHXP shall have agreements with its third-party service providers for ensuring adequate protection for your information. Although we have taken significant steps to protect your personally identifiable information, no company, including HIGHXP can fully eliminate security risks associated with personal information. We further disclaim any responsibility for any intercepted information sent via the internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner. If we learn of a security system’s breach, we shall notify you electronically by posting a notice on the Services or Game you are playing or sending an e-mail to you where you have shared your contact details.

7. Your Rights

7.1 Access to your personal data: You may ask us whether or not your personal data is being processed and access following information:
a. the purposes of the processing;
b. the categories of personal data concerned;
c. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
d. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
e. where the personal data are not collected from you, any available information as to the source of personal data;
f. the existence of automated decision-making;
g. if personal data is transferred to a third country or to an international organisation, information regarding safeguards.

7.2 Rectification and Erasure: You may request for rectification of inaccurate personal data and completion of incomplete personal data. Further, you may request erasure of your personal data on the following ground:
a. the personal data is no longer necessary in relation to the purposes for which personal data was collected or otherwise processed;
b. withdrawal of consent for processing personal data for one or more specific purposes and there is no other legal ground for processing such personal data;
c. objection to processing personal data (as provided below) and there is no overriding legitimate ground for processing personal data;
d. objection to processing personal data for direct marketing purposes;
e. the personal data have been unlawfully processed;
f. Erasure for compliance with legal obligations HIGHXP is subject;
g. Personal had been collected to offer information society services.

However, the right to erasure of personal data is not absolute and we may refuse erasure of personal data when processing of personal data is necessary:
a. for exercising the right of freedom of expression and information;
b. for compliance with a legal obligation to which HIGHXP is subject;
c. for the performance of a task carried out in the public interest or in the exercise of official authority vested in HIGHXP;
d. for reasons of public interest in the area of public health in accordance with applicable laws;
e. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes provided erasure of personal data is likely to render impossible or seriously impair the achievement of the objectives of that processing;
f. for the establishment, exercise, or defence of legal claims.

7.3 Restrict processing of personal data: You may ask us to stop processing personal data if:
a. the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
b. the processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of use of personal data;
c. we no longer need the personal data for the purposes of the processing, but personal data is required by you for the establishment, exercise, or defence of legal claims;
d. you have objected to processing personal data, pending the verification whether our legitimate grounds override your rights.

7.4 We shall communicate any rectification, erasure of your personal data or restriction of processing personal data to each recipient to whom your personal data has been disclosed, unless this proves impossible or involves disproportionate effort. If you request, we shall disclose about such recipients.

7.5 Data Portability: Upon your request, we shall provide your personal data in a structured, commonly used, and machine-readable format and transmit such personal data to another data controller where:

a. Processing of personal data is based on consent (i) for one or more specific purposes; or (ii) performance of contract to which you are party or in order to take steps at your request prior to entering into a contract.
b. Processing is carried out by automated means

7.6 With regards to use of information society services, you may object to processing of personal data by automated means using technical specifications.

7.7 If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer,

7.8 You can choose to prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier, by changing the settings of your device itself. Settings vary from device to device, but you will usually find the ad identifier settings under "privacy" or "ads" in your device's settings. In case your advertising preferences are linked to your use of the services of third-party service providers such as Facebook or Google, then you may need to make a request to such third-party service provider or deactivate the ad identifiers from the said third party’s services.

7.9 If you do not agree with the way, we have processed your data you may approach our Grievance Officer for further recourse.

7.10 We shall aim to comply with or respond to any requests made under this section without undue delay, but no later than 30 days from the date of receipt of such request. All requests may be sent to HIGHXP reserves the right to take additional steps to verify the identity of the person making the request to ensure safety and security of your data and personal information.

8.Third Party Links
8.1 The links to third-party advertisements, third party websites or any third-party electronic communication services (referred to as “Third Party Links”) may be provided on the Platform which are operated by third parties and are not controlled by, or affiliated to, or associated with HIGHXP unless expressly specified on the Games. If you access any such Third-Party Links, we request you review the website’s privacy policy. We are not responsible for the policies or practices of Third-Party Links.

9.1 The Platform uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by Us for maintenance of the Platform and its features as well as research and development, and for administration of Your account. In the course of serving advertisements or optimizing Services, We may allow authorized third parties to place or recognize a unique cookie on the Your browser. We do not store personally identifiable information in the cookies. Please note that if you disable cookies, you may lose some of the features and functionality of our Services because the cookies are necessary to track and enhance your activities.

10.Children 10.1 We encourage parents and guardians to teach their children about privacy and how their information may be used on the internet. Children should never disclose their name, address or phone number, or any personal information, without their parents’ or guardian's prior permission.

10.2 If we consider that any of our Services are directed at users under the minimum legal age required in their country of residence, we can block such users from using the Services or accessing the Games.

10.3 If the Services are used by an underage person in contradiction to this Privacy Policy or the Terms of Use, we may collect personal data from such person. If you believe that we might have any information from or about a user who is under the minimum legal age, please contact us. On receipt of the requisite details and verification of the same, we reserve the right to delete such data of underage users.

11. Amendment of Privacy Policy
11.1 HIGHXP may update or amend this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way HIGHXP treats the user's personal information, HIGHXP will display a notice on the Games or send user’s an email.

11.2 Notwithstanding the above, HIGHXP shall not be required to notify the users of any changes made to the privacy policy. Should you have any concern or reject the changes in the Privacy Policy you can refuse to accept the amendments and opt for withdrawing your personal information by writing to the Grievance Officer.

12. International Data Transfers
12.1 It is possible that your personal information may be transferred outside of your countries jurisdiction by HIGHXP or third-party service providers. You hereby agree and accept that such data transfer is required for the provision of the Services by HIGHXP. These organisations who gain access to your information process your personal information in accordance with our instructions and in order to provide the agreed services in accordance with the terms of the contract entered into with HIGHXP. These third-party service providers and partners may further process your data for their own purposes only after obtaining your consent.

12.2 The measures to protect you personal information may include addition of standard data protection clauses adopted by data protection regulators and approved by the regulatory authorities to ensure that appropriate safeguards are in place to protect your personal data in to the agreements executed by HIGHXP with the recipient of your personal information. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your personal information is transferred to or stored, used, or processed in may be different from the privacy laws applicable to the place where you are residing.

12.3 Please feel free to contact our Grievance Office for additional information on third country data transfers as well as our safeguards and supplementary security measures.

13.Contact Us
13.1 Any questions or comments about this Privacy Policy can be addressed to

13.2 Grievance Officer

If you have any compliant or grievances or concerns with respect to Games or the Services or this Privacy Policy, please inform such matters to the designated Grievance Officer as mentioned below through electronic mail:
Name: Grievance Officer - Raghu Sankar, Shankara Seethappa

E-Mail :