TOROi Technologies Private Limited (herein after referred to as “TTPL” or “we” or “us” “our”) operates the Fantasy Trading League (herein after referred to as “FTL”) and the FTL application in India, which is a financial market education platform that uses the tool of skill based gaming to incentivise learning related to the financial market through without limitation, its mobile or website application (the “FTL app”) partner applications, codes, softwares and technologies (collectively referred to as the “FTL Portal”). FTL is a simulated assets based mock trading game (the “Game”) wholly conditioned upon the performance of the real assets like without limitation, stocks, forex, commodities and crypto currencies on different relevant markets and access to without limits various courses, content and blogs (collectively the “Services”). The Services will be available for use on the FTL app and the FTL’s website i.e. (the “Website”).
Any person including males, females, transgenders and all other natural persons irrespective of their sex/sexuality utilizing the FTL Portal, Website or the Services (hereinafter "User" or "you" or "your", “his” “her or “his/her”) or any of its features including participation in the Game(s) and utilising the other Services being conducted on the Portal) shall be bound by this Privacy Policy (the “Privacy Policy”). This Privacy Policy may be considered as an extension of the ‘FTL-Terms of Use’ document and the User’s express consent provided to FTL/TTPL to abide by those Terms of Use shall also automatically signify the User’s consent to agree and follow the terms of this Privacy Policy. Any usage of the FTL Portal by the User after registration on the FTL Portal including the FTL app and/or Website, would signify the User’s acceptance of the terms of this Privacy Policy.
TTPL and FTL fully respects the privacy of its Users and is committed to protect it in all respects. This Privacy Policy demonstrates TTPL’s/FTL’s complete commitment to its User’s privacy while utilising the FTL Portals and the same is of great importance to TTPL/FTL. The User is therefore, requested to take the time to read the 'About Us' page on the Website in order to get to know more about TTPL and the process of development of the FTL concept. TTPL is dedicated towards establishing a trusting relationship with its Users, based on respect for personal identity and information and by promoting the use of fair information practices. This Policy covers all web and mobile FTL Portal properties owned and maintained by TTPL/FTL, including but not limited (the Website) and the Services.
As TTPL wants to demonstrate its commitment to its Users' privacy, TTPL will disclose in good faith:
- What personally identifiable information  (“Personal Information”)of the User TTPL will collect;
- How TTPL use the Personal Information and with whom TTPL will be sharing the User’s Personal Information;
- What choices are available to Users regarding such collection, use and distribution of the Personal Information, and how Users can correct any inaccuracies in the Personal Information at any point while using the FTL app, the Website and the Services; and
- What types of security procedures have been put in place by TTPL to protect against any loss, misuse or alteration of such Personal Information of the User controlled by TTPL..

Some Services are offered for free but a major portion of the Services provided via the FTL app and the Website are paid versions where the User shall need to purchase‘Coins’ on the FTL app with rupee value currency and redeem them on the FTL app/ Website in order to avail of those Services (Ref. FTL -Terms of Use). However, in order to avail the Services, the User will first need to register himself/herself to participate in FTL's online financial market based mock Game(s). During this process, the information about the User is collected by TTPL/FTL as (i) information supplied by Users themselves and (ii) information automatically tracked during User's navigation on FTL.
Before the User submits any information not limited to Personal Information on the Portal, the User is advised and requested to please read the terms of this Privacy Policy thoroughly for an understanding of how exactly TTPL will be treating the User’s Personal Information once provided on the FTL app or the Website. By using any part of the Portal, the User unconditionally hereby consents to without limitation, the collection, use, disclosure and transfer of the User’s Personal Information for the purposes outlined in this Privacy Policy and without limits to the collection, processing and maintenance of this information. If the User does not agree to the terms of this Privacy Policy, such User is advised not use the Portal or any part of the Services in its entirety. The User is hereby warned that his/her use of any part of the Portal and /or the Services would undeniably indicate his/her unconditional acceptance of the terms of  this Privacy Policy and of  without limits the collection, use and disclosure of such User’s Personal Information in accordance with this Privacy Policy. While the User would always have the option not to provide TTPL/FTL with certain requested information, the User is informed that in such a case, by withdrawing or failing to provide his/her consent to without limits collect certain information or by requesting temporary suspension of the collection of information from TTPL/FTL or by requesting the deletion of information collected by TTPL/FTL, the User shall not be able to either access the Portal at all or even if allowed to access the Portal, may not be able to take full advantage of the entire scope of features of the Services offered to the User by TTPL/FTL through the Portal and TTPL/FTL, at all times, reserve the right not to provide the User with access to the Portal or the use of the Services therein for any reason whatsoever.

A. Purpose & Usage

To avail certain Services on the Portal, Users would be required to provide certain information for the registration process namely:
User’s mobile number (other than a number registered in a Restricted State -ref. in ToU)User’s Name;User’s email ID; and User’s profile display picture (optional)
In the course of providing the User without limits, access to the Services, to the features offered through the Portal and to verify the User’s identity and to secure the User’s account details, the User may be required give TTPL/FTL the permission to without limitation, capture, record the User’s device information, operating system information, network information and location information. The User may also be required to furnish additional information, including his/her bank account details and PAN card details. In certain instances, TTPL/FTL may also collect sensitive Personal Information from the User on the Portal. Sensitive Personal Information means such Personal Information of the User which consists of information relating to without limits, the User’s physical, physiological and mental health condition; medical records and history; biometric information and financial information, without limits such as information regarding the payment instrument/modes used by the User to make such payments, which may include cardholder name, credit/debit card number (in encrypted form) with expiration date, banking details and wallet details. This information is to be submitted by the User at the time of making a payment to enable the User to complete his/her payment expeditiously. Such information shall also be required to be furnished by the User, in the event the User wishes to withdraw his/her winnings from the Play-off League Games played, from the FTL app/ Portal. Except for any financial information that the User may choose to provide while making payment for any Services on the Portal or for making withdrawals of money on the Portal, TTPL will attempt not to collect any further/ other sensitive Personal Information (other than those mentioned above) in the course of providing the Services on the Portal. TTPL/FTL however, reserves the right to collect any further sensitive Personal Information from the User,  if development of further Services on the Portal are made, which would render the collection of such sensitive Personal Information necessary by TTPL/FTL and the User, hereby unconditionally consents to provide TTPL/FTL with the same whenever required. Any sensitive Personal Information collected by TTPL/FTL shall not be disclosed to any third party without the User’s express express consent, save as otherwise set out in this Privacy Policy or as provided in a separate written agreement between TTPL/FTL and the User (like the FTL- Terms of Use document) or as required by the law. It is clarified that this condition shall not apply to publicly available information, including any sensitive Personal Information, in relation to the User on the Portal.
All the information required by TTPL/FTL via the Portal is specific and based on the kind of Game/ Services the User wishes to participate in or access and will be utilised for the purpose of providing the Services, including but not limited to the Services opted for or specifically requested by the User. The information as supplied by the User would enable TTPL/FTL to improve the Services and provide the User with the most user-friendly Game experience.
TTPL/FTL may also share such information with affiliates and third parties in limited circumstances, including but not limited to the purpose of providing the Services opted for or specifically requested by the User, complying with legal process, preventing fraud or imminent harm and ensuring the security of TTPL/FTL’s network and Services.

B. Disclosure & Sharing

TTPL/FTL may also share information as provided by the User and the data concerning the usage of the Services and participation in the Games in either format (ref. Terms of Use) with any third party service provider(s) engaged by TTPL/FTL, without limitation for the purpose of data analytics or other similar purposes, for the purpose of storage, improving the Services and helping TTPL/FTL serve the User better in any manner or for development of more advanced features on the FTL app.Where TTPL/FTL proposes to use or dissipate in any manner, the User’s Personal Information (i.e. information relevant for identifying the User and which is not otherwise publicly available) for any other purposes than those mentioned herein, TTPL/FTL will ensure that it notifies and obtains the User’s consent first. Hence, the User will be at liberty and will be given the opportunity to withhold or withdraw his/her consent for such use other than as specifically listed above.
By using the Portal, the User hereby expressly agrees and grants unconditional consent to without limitation, the collection, use and storage of this information by TTPL. TTPL reserves the right to share, disclose and transfer information collected hereunder with its own affiliates and/or without limits its suppliers, affiliates, licensors, related Companies, Directors, employees, partners, founders and representatives ( the “TTPL Entities”). In the event TTPL/FTL sells or transfers all or a portion of its business assets, the User’s information may be one of the business assets that are shared, disclosed or transferred as part of the transaction. For such events, the User hereby expressly grants his/her unconditional consent and permission to TTPL/FTL for the disclosure and transfer of such User’s information to such third parties. TTPL may share information as provided by the User and data concerning usage of the Portal, including the Website and the Services and participation in the Game with its commercial partners or third party service providers for the purpose of without limitation facilitating user engagement, for marketing and promotional purposes and other related purposes. Further, TTPL reserves the right to disclose the User’s Personal Information as obligated by law, in response to duly authorised legal process, governmental requests and as necessary to protect the rights and interests of TTPL.

C. Use Of Cookies/Session

In order to improve the effectiveness and usability of the Portal for FTL’s/TTPL’s Users, TTPL/FTL use "cookies", or such similar electronic tools such as “Session” to collect information to assign each User a unique random number as a User Identification (User ID) for TTPL/FTL’s internal purposes to understand the User's individual interests using the identified computer or electronic device(s). Unless the User voluntarily identifies himself/herself (e.g., through registration), TTPL/FTL would have no way of knowing the identity of the User, even if the User is assigned a cookie to the User's computer and/or other electronic devices used by the User to access the Portal and/or the Services. The only Personal Information a cookie or any other technology applied for the same purpose can contain is the information supplied by the User himself/herself. A cookie or any other technology applied by TTPL/FTL for the same purpose will not be able to read data off the User's hard drive. Any of TTPL’s/FTL’s advertisers, if any, either in present or in the future, may also be allowed by TTPL/FTL to assign their own cookies to the User's browser (if the User clicks on their ad banners), a process that TTPL does not control. The User hereby, unconditionally grants TTPL/FTL his/her requisite consent/permission to accept the placement of such cookies by such third party advertising entities, being allowed to advertise on the Portal and during the Services, either presently or in the future by TTPL/FTL.
TTPL's web servers automatically collect limited information about User's computer's/ device(s)’ connection to the Internet, including User's IP address, each time when the User visits the Portal. (User's IP address is a number that lets computers/electronic devices attached to the Internet know where to send data to the User -- such as the web pages viewed by the User). The User is informed that the User’s IP address does not identify that User personally in any form. TTPL uses this information to deliver its web pages and other features of the FTL app and/or the Services to the Users upon request, to tailor its Portal to the interests of its Users, to measure traffic within the Portal and ascertain the geographic locations from where TTPL's visitors/ Users come (this is important since Users from Restricted States [Ref. Terms of Use] are barred from using the Portal or any of the Services. TTPL/FTL shall make best efforts to geo-block such Users from gaining access to the FTL Portal or any of the Services using the latest applicable technologies, but in no way guarantees the same).

D. Links

The FTL app or Portal may at present or in the future, contain links to other websites. Such websites are governed by their respective privacy policies, which are beyond TTPL's/FTL’s control. Once the User leaves TTPL's servers (the User can tell where he/she is by checking the URL in the location bar on the User's browser), use of any information provided by the User is governed by the privacy policy of the operator of that website which the User is visiting. That policy may differ from TTPL's own Privacy Policy. If the User can't find the privacy policy of any of these websites via a link from the website's homepage, the User may contact the website admin team directly for more information. TTPL is not responsible for the privacy practices or the content of such websites. However, the links to any internal pages provided on the FTL Portal or while using the Services are subject to this Privacy Policy and any grievance related to any information shared by the User within the domain of the FTL app, the Portal and/or the Services may be shared by the User with the TTPL/FTL’s support team via email on and TTPL/FTL support team shall try to resolve any such issues in the swiftest manner and within the time prescribed in the FTL-Terms of Use.

E. Security Procedures

TTPL/FTL has a full time security team dedicated to protecting all aspects of the FTL Portal which includes the FTL app, the Website and the Services and all its components including the User’s information entered on the Portal. The TTPL/FTL’s security team will make best attempts to use the latest technologies to protect the TTPL/FTL Portal including the FTL app, the Website and the Services from without limitation any hacking, viruses, malware, manipulation or other illegal activity whatsoever, however, the same cannot be guaranteed. All information gathered on the FTL Portal and during the provision of the Services is securely stored within TTPL’s controlled database. The database is stored on servers secured behind a firewall; access to such servers being password-protected and strictly limited based on need-to-know basis. Any information or messages or notifications exchanged between FTL/TTPL and the User are secured through encryption as well as the Personal Information entered by the User on the FTL Portal. However, TTPL/FTL understands that as effective as its security measures are, no security system is impenetrable. Thus, TTPL/FTL cannot guarantee the absolute security of its database, nor can it guarantee that any information supplied by any User will not be intercepted while being transmitted to FTL/TTPL over the Internet. Further, any information included by a User in a posting to any communication areas on the FTL Portal may be available to anyone with internet access. By using the Portal, the User understands and agrees that his/her information may be used in or transferred to countries other than India. The User, therefore, by using the FTL Portal and/or the FTL app hereby waives off any claims that he/she may have against TTPL/FTL arising out of without limitation, the interception, misappropriation, hijack, theft or illegal sale of any data including Personal Information supplied by the User on the FTL Portal and/or the FTL app. The User further agrees that TTPL/FTL will not be responsible for any damages caused to the User as a result of without limitation the above mentioned varieties of theft or misappropriation of the User’s information by any third parties and shall keep TTPL/FTL completely indemnified against any claims made by any third party regarding the information submitted by the User on the FTL Portal and/or the FTL app.
TTPL also believes that the internet is an ever-evolving medium. TTPL/FTL may periodically review from time to time and change this Privacy Policy to incorporate such future changes as may be considered appropriate, without any prior notice to the User. The User may however, be notified of the changes to this Privacy Policy via a separate personal email on the registered email ID of the User by the FTL admin team. Continued usage by the User of the FTL Portal and/or the FTL app after receiving such notification shall signify the User’s acceptance of those changes and no claims may be raised by the User in relation to the revised Privacy Policy thereafter whatsoever, upon TTPL/FTL by the User. If the User does not agree to the revised terms of the Privacy Policy, the User may request the FTL admin team to cancel/terminate the User’s agreement and account with FTL in the manner as provided in the Terms of Use document.
TTPL/FTL’s use of any information that it gathers will always be consistent with the policy under which that information was collected, regardless of what the new policy may be. Any changes to this Privacy Policy will be posted on the FTL Portal including the FTL app and the Website. TTPL/FTL shall always attempt to post the latest updated version of this Privacy Policy on its Portal including the FTL app and Website at all times so that the User are always made aware of what information TTPL/FTL collect, how it is used, how it is stored and under what circumstances can such User’s information be disclosed by TTPL/FTL.

F. Advertising

If TTPL presents information to any online entity, it would usually be in the form of aggregated statistics on traffic to various pages within the FTL Portal. When the User registers with FTL, the FTL admin team/ support team may contact the User from time to time about updating his/her content to provide features which TTPL/FTL believe may benefit the User.
Several deceptive emails, websites, blogs etc. claiming to be from or associated with TTPL may circulate on the internet. These emails, websites, blogs etc. may include without limits, FTL’s logo, photos, links, content or other information. Some emails, websites, blogs etc. may call the User requesting the User to provide his/her sensitive Personal Information (such as phone number, bank details etc.) as registered by that User on the FTL Portal or inform the User that the User has won a prize/ gift or provide a method to commit illegal/ unauthorized act or deed or request detailed Personal Information or a payment of some kind. The sources and contents of these emails, websites, blogs etc. and accompanying materials are in no way associated with TTPL/FTL. For the User’s own protection, TTPL/FTL strongly recommends the User to not respond to such emails or using these websites, blogs etc. However, TTPL/FTL may use the information provided by the User to TTPL/FTL, including your email address or phone number, to contact the User from time to time about the Services availed by the User or to inform the User of updated Services if any. In such cases, if the User is in doubt about the authenticity of such contact efforts, such User may check with the FTL support team to verify the same.

G. Conditions Of Use

TTPL does not warrant that this FTL Portal, it’s servers, or email sent by TTPL/FTL or on TTPL/FTL’s behalf are virus free. TTPL will not be liable for any damages of any kind arising from the use of this FTL Portal including the FTL app and Website including, but not limited to compensatory, direct, indirect, incidental, punitive, special and consequential damages, loss of data, goodwill, business opportunity, income or profit, loss of or damage to property and claims of third parties. In no event will TTPL be liable to any User for any damages whatsoever in an amount in excess of the amount spent by that User in the purchase of Coins o the FTL Portal.

H. Retention Of Data

The User’s personal information may be retained and may continue to be used  by TTPL/FTL until: (i) the relevant purposes for the use of the User’s  information described in this Privacy Policy are no longer applicable; and (ii) TTPL/FTL are no longer required by applicable law, regulations, contractual obligations or legitimate business purposes to retain the User’s Personal Information and the retention of the User’s Personal Information is not required for the establishment, exercise or defense of any legal claim.

I. User Account And Data Deletion

Users are entitled to request TTPL to delete their User accounts and their Personal Information by sending an email with their written request to admin team will do its best to respond promptly within the time frame as mentioned in the Terms of Use after the following has been received from the User:
- FTL admin/support team’s receipt of the User’s written request; or
- FTL admin/support team’s receipt of any further information FTL  may ask the User to provide to enable the User to comply with his/her request, whichever is later.
- As an alternative to account termination, by writing to, the User also has the option to request either:
      - the temporary suspension of the User’s account, after which the User will not be able to play any Game(s) on the FTL Portal nor utilise any of the Services whatsoever on that User’s  account till such suspension is asked to be retracted or decided to be retracted by FTL; or
       - the temporary suspension of the User’s account, after which the User will not be able to play any Game(s) on the FTL Portal nor utilise any of the Services whatsoever on that User’s account till such suspension is asked to be retracted or decided to be retracted by FTL; or
     - Permanent deactivation or termination of the User’s account, where the User will no longer be able to log into the FTL Portal permanently (Ref. Terms of Use) and will have to  re- register himself/herself on the FTL Portal through new registration information in order to access the FTL Portal again.
If the User proceeds with permanent termination/ deactivation of his/her account, he/she will lose all access to the FTL Portal and the Services, including any User data and Personal Information associated with that User’s account. Once such User’s account has been permanently terminated by FTL, he/she cannot request for account restoration from FTL. However, in case of a suspension of the account, the account can be resumed by writing to who then may or may not lift the suspension at the FTL’s discretion.
If a User requests deletion of his/her data, TTPL/FTL would follow a deletion process that ensures that such User’s data is safely and completely removed from FTL/TTPL’s servers or retained only in anonymised form. TTPL/FTL try to ensure that it protects information from accidental or malicious deletion. Due to this, there may be delays between when the User requests the deletion and when the copies are actually deleted from FTL/TTPL’s active and backup systems.
Notwithstanding anything contained in this section herein, the deletion, termination or suspension of a User’s account by FTL shall be subject to and done in the manner prescribed in the Terms of Use document. The User is kindly requested to refer to the same.

J. Applicable Law And Jurisdiction

By visiting this Portal, the User agrees that the laws of the Republic of India without regard to its conflict of laws or  principles, will govern this Privacy Policy and any dispute arising in respect hereof shall be subject to and governed by the dispute resolution process set out in the Terms of Use.

K. Updating Information

The User will promptly notify TTPL if there are any changes, updates or modifications to the User’s information provided to FTL at any point. Further, the User may also review, update or modify his/her information and preferences by logging into his/her own ‘profile page’ on the FTL Portal.

L. Contact FTL/TTPL

Any questions or clarifications with respect to this Privacy Policy or any complaints, comments, concerns or feedback can be sent to TTPL/FTL at: or by normal/physical mail addressed to:
Attn: FTL Team
F33, Sushant Shopping Arcade Sushant Lok1 Gurugram Haryana 122009