This Privacy Policy is published in compliance of: (i) Section 43A of 'The Information Technology Act, 2000'; (ii) Rule 4 of 'The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011' (hereinafter referred to as the "SPI Rules"); (iii) Relevant Provisions of 'The Consumer Protection Act, 2019' read with 'The Consumer Protection (E-Commerce) Rules, 2020'
For the purposes of this Privacy Policy, the term “User(s)” shall have the same meaning as defined in the Terms of Use available on our Website(s)/Mobile Application(s) of Top Stroke.
[User(s) are requested to refer to the definition clause in the Terms of Use for clarity on any terms not separately defined in this Privacy Policy.]
Top Stroke Sports Private Limited ("Company", "Top Stroke", "We", or "Us") is committed to delivering an engaging and secure experience for all our users. While providing access to our services, we place the highest priority on protecting your privacy and safeguarding your personal data.
This Privacy Policy outlines how we collect, use, store, and protect information when you interact with the Top Stroke mobile application (currently available only on Android) and our informational branding website. It also describes the choices you have regarding your personal information and the steps we take to ensure your data remains secure and handled in compliance with applicable laws.
By accessing or using the Top Stroke app or website, you agree to the terms and practices described in this Privacy Policy and our Terms of Use. PLEASE DO NOT USE, INSTALL OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY.
We are committed to maintaining transparency in how your data is handled and ensuring it is never shared with unauthorized third parties. Any disputes concerning privacy will be subject to this Privacy Policy, read in conjunction with our Terms of Use.
"Personal Information" is defined under the SPI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
The SPI Rules further define "sensitive personal data or information" (hereinafter referred to as the "SPDI") of a person to mean Personal Information about that person relating to: (i) passwords; (ii) financial information such as bank accounts, credit and debit card details or other payment instrument details; (iii) physical, physiological and mental health condition; (iv) name, age, address, e-mail, phone number, date of birth, sexual orientation; (v) medical records and history; (vi) biometric information; (vii) information received by body corporate under lawful contract or otherwise; (viii) visitor details as provided at the time of registration or thereafter; and (ix) call data records.
All the aforementioned information is collectively referred to as "Personal Information."
The information about the Users, as collected by us from the Website(s)/Mobile Application(s) of Top Stroke, includes: a) information supplied by the users; and b) information automatically tracked during navigation (“Information”).
By accessing or using our Website(s)/Mobile Application(s) of Top Stroke and/or its services, the User(s) voluntarily and unconditionally gives their consent to the collection, storage, and/or use of the Personal Information provided by them, including any changes provided at a later stage, for availing any of the services that we offer.
To avail certain services on our Website(s)/Mobile Application(s) of Top Stroke, the User(s) may be required to provide certain information during the registration process, which may include but is not limited to:
a) email address, b) password
Top Stroke does not collect:
sex,
age,
PIN code,
credit card or debit card details,
medical records and history,
sexual orientation,
biometric information.
We presume adequate and lawful parental consent in case the Personal Information is shared by any user under the age of 18 (eighteen) years.
The information supplied by the User(s) enables us to improve our Website(s)/Mobile Application(s) of Top Stroke and provide a more user-friendly experience.
All required information is service-dependent, and Top Stroke may use the above-mentioned User information to maintain, protect, and improve our services (including analytics and promotional communications), and to develop and provide new features for our User(s).
It is clarified that any information shall not be considered sensitive in case it is freely available and accessible in the public domain or is furnished under the Right to Information Act, 2005 and any rules made thereunder, or any other law for the time being in force.
The primary reason for gathering this information is to improve our products, services, content, and overall user experience on the Website(s)/Mobile Application(s) of Top Stroke.
We have implemented reasonable security practices as per Rule 8 of the SPI Rules as mentioned above and the Information Technology Act, 2000, amended through the Information Technology Amendment Act, 2008.
Top Stroke adheres to stringent, internationally accepted standards of technological, managerial, technical, operational, and physical security to protect your personally identifiable information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. Our data is securely managed and stored using third-party cloud infrastructure — specifically Amazon Web Services (AWS) — which follows globally recognized security protocols and best practices.
We have adopted “Reasonable Security Practices” as mandated under the Information Technology Act, 2000 and the SPI Rules. In compliance with these laws, we ensure proper care, due diligence, and oversight over our information technology and security operations in accordance with relevant provisions, including Sections 43, 43A, 45, 66, 72A, and 85 of the Information Technology Act, 2000, as amended by the Information Technology Amendment Act, 2008 and any associated rules.
However, Top Stroke, its founders, team members, affiliates, or partners shall not be held liable for any fraudulent or criminal activities arising from misuse or unauthorized access of sensitive personal information stored in our systems.
By accessing or using the Website(s)/Mobile Application(s) of Top Stroke, User(s) agree that we shall not be held responsible for any uncontrollable security breaches and any resulting losses (whether direct or indirect), including financial loss, opportunity cost, legal costs, loss of business or reputation, as permitted under the applicable sections of the Information Technology Act, 2000, and all relevant laws of India in force at the time.
You further agree and acknowledge that our management shall not be held accountable for any criminal liabilities under the IT Act, 2000/2008 related to your data, provided we have fulfilled the due diligence obligations under the relevant sections and rules of the law.
We implement layered and robust security measures such as:
Regular internal reviews of our data handling and security practices
Use of modern encryption protocols
HTTPS-secured data transmission
Access controls and firewall protections
Secure AWS-hosted infrastructure
All user data collected via our Website(s)/Mobile Application(s) is stored securely and processed only on our trusted cloud infrastructure. That said, while we take every reasonable measure to protect your information, no system is completely foolproof. We cannot fully guarantee the security of our database or ensure that data transmissions over the internet will never be intercepted. However, we make every effort to protect your information using state-of-the-art cryptographic and security tools.
If you post any content in a public area (such as comments or community features) on the Top Stroke platform, it may be visible to other users who have access to that space.
Please note that the internet is an evolving medium, and our security and privacy practices may adapt accordingly. We may modify this Privacy Policy periodically to reflect technological upgrades, legal changes, or business decisions. Nevertheless, our use of any information will always align with the policy in effect at the time the data was collected, provided such use is not in conflict with prevailing law.
To improve the responsiveness for our User(s), we may use "cookies", or similar other electronic tools to collect information in order to assign each user a unique, random number as a user identification ("User ID") to understand each and every user's individual interests using their identified computer/mobile devices. Unless you voluntarily identify yourself (through registration, for example), we will have no way of knowing who you are, even if we assign a cookie to your computer/mobile devices. A cookie also cannot read data off your hard drive.
The Android application of Top Stroke does not use "cookies" explicitly. However, our Website(s)/Mobile Application(s) of Top Stroke may use third-party code and libraries that use "cookies" to collect information and improve their services. User(s) have the option to either accept or refuse these cookies and to know when a cookie is being sent to your device. However, in case the User(s) choose to refuse our cookies, he/she may not be able to use some/complete portions of our services.
Once the User(s) permit, we may obtain additional information such as the list of apps installed on your device, device information, location, network carrier ("Information") available on your device, to personalize your experience and improve the app suggestions. This data may also be used at our end to take necessary business decisions.
We assure that all or any information of the User(s) shall not be shared with any third party and shall be purely utilized for enhancing each user experience and personalizing the services within the Top Stroke network.
Opting Out: Top Stroke’s Android app does not use cookies directly, and our website is purely informational, so no cookie opt-out is required for general use. However, third-party services (like analytics or crash reporting tools) integrated in the app may use identifiers or cookie-like tools. These are managed by the SDKs, not by Top Stroke directly.
Log File Information: It is necessary to inform and clarify our User(s) that:
Our Website(s)/Mobile Application(s) of Top Stroke may also include links to other third-party websites or mobile applications. Such websites or mobile applications are governed by their respective privacy policies, which are beyond our control.
Once the User(s) access any built-in third-party service by switching to third-party applications/websites [the User(s) can tell where you are by checking the URL in the location bar on your browser], use of any information the User(s) provide to such third party is governed by the respective privacy policy of the concerned operator of the said application/website the User(s) are visiting. That policy may differ from ours. If the User(s) can't find the privacy policy of any of these third-party websites/mobile applications including accessing their homepage, then the User(s) should contact the application or website owners directly for more information regarding this and/or for any other grievances.
Third-Party Advertisers We may use third-party advertising companies to serve ads when you visit the Product. These companies may use information about your visits to the Product to provide advertisements about goods and services that may be of interest to you.
We do not provide any Personal Information to any third-party websites, advertisers, or ad servers without your explicit consent, except in the circumstances mentioned elsewhere in this Privacy Policy.
Top Stroke may share sensitive Personal Information with third parties, including Government Bodies, Government agencies, Government authorities, Service Providers, or Alliance Partners, without obtaining the prior consent of the User(s) in the following limited circumstances:
When the User(s) use our Website(s)/Mobile Application(s) of Top Stroke:
We make good faith efforts to provide our User(s), as and when requested by such User(s), with access to their Personal Information and shall further ensure that any Personal Information or sensitive personal data or information found to be inaccurate or deficient shall be corrected, modified or amended as feasible, subject to any requirement for such Personal Information or sensitive personal data or information to be retained by law or for legitimate business purposes.
We ask each individual User(s) to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.
In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
Upon receiving a specific request coming from any of the User(s), we may ensure that Personal Information in relation to such User(s) is deleted from our database as well as from the third-party cloud service providers.
Because of the way we maintain certain services, after you request for deletion of your Personal Information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems for a certain period of time.
Top Stroke is not intended for use by individuals under the age of 16. We do not knowingly collect, solicit, or store personal data from anyone under the age of 16. If you are under 16, please do not attempt to register for or use our Services, or send any personal information to us, including your name, email address, or any other identifiable details.
If we become aware that we have inadvertently collected personal information from a user under the age of 16, we will take prompt and appropriate steps to delete such data from our records and systems.
If you believe that we might have collected information from or about a child under the age of 16, please contact us immediately at contact@topstrokesports.com, and we will address the concern as quickly as possible.
If you have any concerns, complaints, or grievances regarding this Privacy Policy or the handling of your personal information by Top Stroke, we encourage you to reach out to our designated Grievance Officer. We are committed to addressing your queries and resolving any issues in a transparent and timely manner.
Grievance Officer Name: Grievance Officer Email: contact@topstrokesports.com
As per Rule 5(9) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Grievance Officer shall redress your grievance within 30 (thirty) days from the date of receipt of the complaint.
We are happy to provide clarifications regarding our data handling practices, your rights under this policy, and any additional information about how we operate.
Please note that depending on the complexity of your request, it may take some time to process and respond appropriately. We appreciate your patience and understanding.