LEA POLICY

Guidelines/Policy for Law Enforcement Authorities in India Seeking Data from Junglee Games India Private Limited

Junglee Games India Private Limited (hereinafter referred to as “JGIPL/Junglee Games/Company”) is incorporated as a private limited company under the provisions of the Indian Companies Act, 1956, with its corporate office at Obeya Tulip, No. 100, Regent Insignia, 100 Feet Road, 4th Block Koramangala, Bengaluru Urban, Karnataka, 560034 and registered office at CoWrks, 5th Floor, DLF Tower 10A, DLF Phase 2, Sector 24, Gurugram - 122022, Haryana. Junglee Games operates as a responsible gaming platform that offers fair online skill-based games and is the fastest-growing skill games company in India. Junglee Games offers various skill-based online games including Junglee Rummy, Junglee Poker, Howzat, etc.

These guidelines are intended for Law Enforcement Authorities in India seeking information from Junglee Games India Pvt. Ltd. (hereinafter referred to as “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 India Pvt. Ltd. from players/users. We reserve the right to amend these guidelines and our policies and Terms of Service from time to time. Also, please note that these Guidelines do not apply to requests made by law enforcement agencies outside India to Junglee Games.

We respect the privacy of players/users on our platform and are committed to protecting the player/user data on our platform. Therefore, any request for data records from Junglee Games India Pvt. Ltd. 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 Law Enforcement Authorities. A trained team in our Disputes channel reviews all notices/requests received from Law Enforcement Authorities. Law Enforcement Authorities in India seeking information from Junglee Games about a player/user account can write to us at [email protected] 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 a notice under Section 91CrPC as per the procedures laid down under the Code of Criminal Procedure of India, 1973. Junglee Games reserves the right of non-disclosure in case the data request is neither relevant nor necessary nor proportional in order to protect the privacy of our players’/users’ accounts. The information shall be released only for lawful purposes at the sole discretion of Junglee Games.

Definitions

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

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

• These guidelines are intended for Law Enforcement Authorities in India;
• Law Enforcement Authorities in India seeking information from Junglee Games India Pvt. Ltd. about a player/user account can write to us at [email protected] from their official Government email address (Gov.in/nic.in);
• 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;
• We respond to data requests from Law Enforcement Authorities through our dedicated channel for [email protected]. Therefore, the requests must be submitted to [email protected].
• The notice under 91CrPC 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 or provide us with any other information that may assist us in understanding your requirement/relevancy for the data from us;
• Kindly also provide us with appropriate identifiers which would enable us to conduct our searches accurately and assist us in locating the user account/transaction details;
• Where requests contain fraud 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 transmitted. Identifiers such as these are generally required to conduct thorough investigations for information related to devices, accounts, or financial transactions.

2. Managing and responding to complaints received by LEAs

• If Junglee Games finds any request unclear or inappropriate or incomplete, Junglee Games will raise its concerns with the LEA for seeking further clarification on the same.
• 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, we shall inform a reasonable timeframe within 24 hours within which the data will be shared.

3. Requests that cannot be fulfilled by Junglee Games

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

• Unwritten requests such as verbal/on-call requests;
• Requests not accompanied by a Notice under 91CrPC or Court order, etc;
• Requests not directly coming from a Government email address (Gov.in/nic.in);
• Requests raised without mentioning the legal provision under which information is sought shall be routed back to the LEAs for specifying the requisite legal provision under which the notice for information has been issued;
• Requests made via social media channels like WhatsApp, Telegram, LinkedIn, Twitter, Facebook, etc.

4. Information to be provided by LEAs to Junglee Games

The LEA is requested to provide us with the exhaustive information and sufficient identifiers to assist us in conducting our searches and respond in time and in an exhaustive manner. If required, we may ask about the relevancy of the data request to LEA’s investigation/case in order to assist LE with the most relevant information and in order to adhere to data privacy of our players.

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

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

• Junglee Games can provide the transaction history or wallet statement of a Junglee Games player account to the LEAs, 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, transaction IP address of the device when the transaction was initiated.



Provided that:

• i. The above-mentioned details can be shared only for the cases where the same is available. We may not have KYC or transaction details for all players.
• ii. Junglee Games shall provide only the information specifically requested in the request notice.
• iii. 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.

6. Notices received from Law Enforcement Agencies

• Account Restriction/Deletion Requests

If a Government Agency or LEA wants Junglee Games to block/restrict a player’s Junglee Games account, the request in this regard can be made through a Notice under section 91CrPC (in the manner stated hereinabove) mentioning the account to be locked along with the reason for such request.

It is only upon the receipt of a Statutory Notice, Junglee Games shall take the requisite action to lock the account in compliance with the Notice and inform the requesting party accordingly.

DISCLAIMER: These guidelines are provided in order to facilitate the timely response to all requests submitted by LEAs. 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.

7. Frequently Asked Questions

• Does Junglee Games have a separate team to handle requests received from Law Enforcement Authorities?
  Yes, Junglee Games has a dedicated disputes channel which handles all the requests coming from Law Enforcement Authorities. Our Disputes team can be reached out at [email protected].
• Why is a notice issued under the 91CrPC mandatory for seeking player account details of Junglee Games?
  As per the Code of Criminal Procedure, 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 under this code by or before such Court or officer, they may request such information by issuing a notice under Section 91CrPC for requesting such information.
• Will Junglee Games provide a certificate under Section 65-B of the Indian Evidence Act, 1872?
  Yes, it shall be provided only if specifically required by the Investigating Officer and if the information provided is not sufficient.

Please refer to the following standard format for a notice under Section 91CrPC:

Template for issuing notice under Section 91CrPC*