Funny Exchange Privacy Policy

1. Information We Collect

1.1 Personal Information You Provide Directly

Account Registration Information:

• Full name, date of birth, and age verification
• Mobile phone number and email address
• Postal address and geographic location
• Government-issued identification (Aadhaar, PAN, Passport, etc.)
• Proof of address (utility bills, rental agreements, bank statements)

Financial Information:

• Bank account details for deposits and withdrawals
• Payment method information (UPI, NetBanking, card details)
• Transaction history and betting records
• Account balance and fund transfer history

Communication Information:

• Messages sent through customer support
• Feedback, complaints, and dispute documentation
• Survey responses and preference information
• Support tickets and correspondence logs

Additional Information:

• Betting preferences and market interests
• Device preferences (app vs. web)
• Language and notification preferences
• Marketing consent and communication preferences

1.2 Information Collected Automatically

Technical Data:

• IP address and device identifiers (IMEI, UDID, MAC address)
• Device type, operating system, and browser information
• Login timestamps and session duration
• Pages visited, click patterns, and interaction data
• Approximate geographic location (derived from IP)

Behavioral Data:

• Betting patterns and market selections
• Trading activity and odds research
• Login frequency and usage patterns
• Feature utilization and platform navigation
• Error logs and technical issues encountered

Tracking Technologies:

• Cookies (session, persistent, and third-party)
• Web beacons and pixel tags
• Local storage and cache data
• Google Analytics and third-party analytics platforms
• Device fingerprinting technologies

1.3 Information from Third Parties

• Financial & Payment Processors: transaction confirmation, payment status, fraud flags, KYC/AML results
• Identity Verification Services: identity, address, age verification, fraud screening results
• Law Enforcement & Regulatory Bodies: subpoenas/legal process info and authorized queries
• Third-Party Integrations: affiliate/referral data, partner promotions, support platform logs

2. How We Use Your Information

2.1 Primary Uses

Service Delivery & Account Management:

• Create and manage your Funny Exchange account
• Process deposits, withdrawals, and fund transfers
• Settle bets and manage your betting positions
• Provide real-time market data and odds updates
• Maintain transaction history and account records
• Calculate commissions, rewards, and bonuses

Security & Fraud Prevention:

• Verify identity and prevent unauthorized access
• Detect and prevent fraudulent betting patterns
• Monitor suspicious account activity and duplicate accounts
• Prevent market manipulation and collusion
• Implement AML compliance and prevent payment fraud/chargebacks

Legal & Regulatory Compliance:

• Comply with KYC requirements
• Meet AML obligations
• Respond to legal requests from authorities
• Maintain required records and support dispute investigations

Customer Support & Service Improvement:

• Respond to inquiries and support requests
• Resolve technical issues and account problems
• Investigate complaints/disputes and provide personalized assistance
• Track support interactions for quality assurance
• Analyze common issues to improve services

2.2 Secondary Uses

Marketing & Communications (with consent):

• Send promotional offers, bonuses, and special events
• Notify about new sports, markets, and platform features
• Send service updates, maintenance notifications, and important alerts
• Conduct marketing research and user satisfaction surveys
• Create user segments for targeted communications

Analytics & Service Optimization:

• Analyze usage patterns to improve platform functionality
• Identify popular markets and optimize odds
• Test new features and conduct A/B testing
• Monitor system performance and server load
• Generate anonymized reports for business intelligence

Product Development:

• Develop new betting markets and features
• Customize user experience based on preferences
• Improve app/website performance and interface usability
• Enhance odds calculation algorithms

3. Legal Basis for Processing (GDPR & Data Protection)

We process personal data under the following lawful bases:

• Contractual Necessity: required to fulfill your betting exchange contract
• Legal Obligation: compliance with KYC, AML, and gambling regulations
• Legitimate Interests: fraud prevention, platform security, and service improvement
• Consent: marketing communications and optional analytics (explicit opt-in)
• Regulatory Compliance: meeting financial and gambling authority requirements

4. Information Sharing & Disclosure

4.1 We Do NOT Share Personal Data For:

• Commercial sale or exchange
• Direct marketing by third-party companies (without consent)
• Behavioral advertising networks
• Data brokers or information resellers
• Corporate mergers/acquisitions (except under specific conditions)

4.2 We MAY Share Information With:

Payment & Financial Partners:

• Banks and payment gateways (e.g., UPI/NetBanking providers)
• Card networks for transaction processing
• Cryptocurrency processors (for USDT/Bitcoin deposits)
• Refund processors and chargeback handlers

Regulatory & Legal Authorities:

• Suspicious transaction reporting (where applicable)
• Regulators, tax authorities, and law enforcement (with valid legal process)
• Court-ordered disclosures

Service Providers & Operational Partners:

• Cloud hosting, support/helpdesk platforms, email delivery services
• Analytics providers (e.g., Google Analytics, Mixpanel)
• Fraud detection and verification services
• Backup and disaster recovery providers

Business Scenarios:

• Merger, acquisition, bankruptcy, asset sales, or restructuring (with safeguards)

5. Data Security & Encryption

5.1 Security Measures Implemented

Encryption Standards:

• AES-256 encryption for data at rest
• TLS 1.3 for data in transit
• RSA-2048 encryption for sensitive data handling
• Hardware Security Modules (HSMs) protecting encryption keys
• End-to-end encryption for sensitive communications

Access Controls:

• Role-based access control (RBAC)
• Multi-factor authentication (MFA) for admin accounts
• Biometric security options for users (where available)
• IP whitelisting for administrative access
• Regular access audits and logging

Infrastructure & Operational Security:

• Secure data centers, redundancy, DDoS protection, WAF/IDS monitoring
• Security patches and updates
• Segregated KYC document storage, encrypted backups, incident response
• Periodic third-party audits (where applicable)

6. Cookies & Tracking Technologies

6.1 Types of Cookies Used

Essential/Functional Cookies:

• Session authentication and security tokens
• Account preferences (language, timezone)
• Form data preservation and CSRF protection

Analytics Cookies:

• Analytics tools for feature/usage tracking and event analytics

Marketing Cookies:

• Conversion tracking and remarketing (where enabled)
• Affiliate/referral attribution

6.2 Cookie Management

Users can control cookies through browser settings, privacy preferences, opt-out mechanisms, and consent banner controls. Disabling essential cookies may prevent platform functionality and account access.

7. Your Privacy Rights & Data Subject Rights

7.1 Access & Portability

• Request a copy of personal data we hold
• Understand how data is used
• Receive a machine-readable export (portability)

Process: Submit a request to privacy@funnyexchange.com with identity verification. Response within 30 days.

7.2 Correction & Rectification

• Update account details in settings
• Contact support to modify personal information
• Request verification of data accuracy

7.3 Deletion & Right to be Forgotten

You may request deletion under certain conditions. We may retain data required by law (e.g., KYC, tax, regulatory records).

7.4 Opt-Out Rights

• Unsubscribe from marketing or disable notifications
• Disable certain analytics via preferences
• Manage cookies via browser/account controls

7.5 Object to Processing

You can object to certain processing (e.g., marketing/profiling) except where required for fraud prevention, legal compliance, or essential operations.

7.6 Exercising Your Rights

Use account privacy settings (if available) or email privacy@funnyexchange.com. We respond within 30 calendar days.

8. Data Retention Policy

Retention varies by data type (account/betting, financial, KYC, communications, analytics, marketing). After retention periods expire, data is securely deleted or anonymized where appropriate.

• Betting & transaction records: commonly retained for regulatory/tax/dispute requirements
• KYC documents: retained for required minimum periods
• Support logs: retained for service quality and dispute resolution

9. Data Protection for International Users

Data transfers outside India may be protected by contractual safeguards and compliant mechanisms (where applicable), including GDPR requirements for EU/EEA users and equivalent protections for UK users.

10. Children & Minor Protection

• Services are for users 18 years and older
• Accounts suspected of being operated by minors may be suspended
• Age verification is required during registration

11. Third-Party Links & External Websites

We may link to external websites. We do not control or assume responsibility for their privacy practices. Users should review those sites’ policies independently.

12. Responsible Gambling & Data

We may maintain data related to responsible gaming features (deposit limits, loss limits, time-outs, self-exclusion, and related logs). Where applicable, we may use pattern analysis to identify risk signals and provide resources.

13. California Consumer Privacy Act (CCPA) Compliance

For California residents, we recognize rights such as the right to know, delete, opt-out of sale (if applicable), and non-discrimination for exercising rights.

CCPA Requests: Email privacy@funnyexchange.com with subject line “CCPA Request – [specific right]”.

14. Policy Changes & Updates

We may revise this policy to reflect changes in practices, legal requirements, or security standards. Material changes may be communicated via email and posted on this page with updated effective dates.

15. Data Breach Notification

In case of unauthorized access to personal data, affected users may be notified within 72 hours where required by law. Notifications may include the nature of the incident, data affected, and steps taken.

16. Contact & Support

Privacy Inquiries: privacy@funnyexchange.com

Mailing Address:
Funny Exchange
Data Protection & Privacy Department
Kalyan, Maharashtra, India

Response Time: 30 calendar days for data subject access requests.

17. Definitions

• Personal Data: information relating to an identified or identifiable individual
• Processing: collection, use, storage, deletion, transfer, etc.
• Data Controller: Funny Exchange
• Data Processor: third parties processing data on our behalf
• Sensitive Data: government IDs, financial data, and similar sensitive categories
• Legitimate Interests: fraud prevention, security, and service improvement

18. Acknowledgment

By using Funny Exchange, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described.

Privacy Policy Version: 2.0
Last Updated: January 2025
Effective Date: January 1, 2025