1. INTRODUCTION

This Privacy Policy governs the collection, use, storage, processing, and disclosure of personal data by Acceler Edtech Private Limited (hereinafter referred to as ‘Company’, ‘Fragnado’, ‘we’, ‘us’, or ‘our’) in relation to the Fragnado mobile application and website (collectively referred to as ‘Platform’). The Platform is an esports tournament registration and information platform designed exclusively for individuals aged 18 years and above.

This Privacy Policy is published in accordance with and compliance with:

• The Digital Personal Data Protection Act, 2023 (DPDP Act)
• The Information Technology Act, 2000 and amendments thereto
• The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
• The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
• The Promotion and Regulation of Online Gaming Act, 2025 (PROG Act)

2. AGE RESTRICTION AND STRICT ELIGIBILITY

CRITICAL: The Platform is intended exclusively for individuals aged 18 years and above. We do not permit access, registration, viewing, playing, or usage of any kind by persons under 18 years of age.

2.1 Active Age Verification

We implement active age verification measures including:

• Mandatory date of birth declaration during registration
• Document-based age verification where required or when suspicious activity is detected
• Behavioral pattern monitoring to detect potential underage users

Important Clarification: Behavioral monitoring is limited strictly to detecting misuse, fraud, or age misrepresentation and does not involve automated decision-making with legal or significant effects on users.

• Where applicable, limited verification of educational affiliation solely for eligibility in institution-specific tournaments, subject to explicit user consent

2.2 Discovery and Enforcement

If we discover or have reasonable grounds to believe that a user is under 18 years of age:

• The account will be immediately suspended
• All non-retained personal data will be deleted promptly, subject to statutory retention requirements
• We may take appropriate remedial action, including account suspension and deletion, in accordance with applicable law

2.3 Parental Notice

If you are a parent or guardian and believe your child under 18 has created an account or accessed the Platform, please contact our Grievance Officer immediately at grievance@fragnado.com. We will take immediate action to delete the account and all associated data.

3. LEGAL STATUS AND NATURE OF PLATFORM

3.1 Esports Platform – No Money Gaming

Fragnado explicitly declares that it is an esports tournament registration and information platform and is 

• NOT an online gaming platform as defined under the Promotion and Regulation of Online Gaming Act, 2025
• NOT engaged in any form of wagering, betting, or staking of money or money’s worth
• NOT offering games of chance or any chance-based enrichment opportunities
• NOT facilitating gambling, lucky draws, or any form of consideration-based prize distribution
• NOT subject to the Public Gambling Act, 1867 or state gambling legislation

3.2 What Fragnado IS

Fragnado operates exclusively as:

• A skill-based esports tournament registration platform
• An information and content platform showcasing esports tournaments, teams, and sponsor content
• A community platform for collegiate esports enthusiasts aged 18 and above

All tournaments facilitated through Fragnado are based purely on skill, strategy, and competitive gameplay with no element of chance, gambling, or monetary wagering.

4. DEFINITIONS

For the purposes of this Privacy Policy, unless the context otherwise requires:

• ‘Personal Data’ means data about an individual who is identifiable by or in relation to such data, as defined under the DPDP Act, 2023.
• ‘Sensitive Personal Data or Information’ (SPDI) means personal data consisting of information relating to passwords, financial information such as bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation, medical records and history, biometric information, and any detail relating to the above as provided to body corporate for providing service.
• ‘Data Principal’ means the individual to whom the personal data relates, as defined under the DPDP Act, 2023.
• ‘Data Fiduciary’ means Acceler Edtech Private Limited, which alone or in conjunction with others determines the purpose and means of processing personal data.
• ‘Data Processor’ means any person who processes personal data on behalf of a Data Fiduciary.
• ‘Processing’ means a wholly or partly automated operation or set of operations performed on personal data, and includes operations such as collection, recording, organization, structuring, storage, adaptation, retrieval, use, alignment, combination, restriction, erasure, or destruction.
• ‘User’ or ‘You’ means any Data Principal who accesses or uses the Platform, and has completed registration.
• ‘Services’ means the esports tournament registration services, tournament information, information and content related to esports tournaments and platform features, and other features provided through the Platform.

5. ACCEPTANCE AND CONSENT

By registering for and using the Platform, you:

• Acknowledge that you have read, understood, and agree to be bound by this Privacy Policy
• Provide free, specific, informed, and unambiguous consent to the collection, use, storage, and processing of your personal data as described herein
• Confirm that you are at least 18 years of age and have the legal capacity to enter into this agreement
• Understand your rights as a Data Principal under the DPDP Act, 2023

If you do not agree with the terms of this Privacy Policy or cannot provide the required consent, you must not access, register for, or use the Platform in any manner.

6. PERSONAL DATA WE COLLECT

In accordance with the principles of data minimization and purpose limitation under the DPDP Act, we collect only the personal data that is necessary for the specified, explicit, and legitimate purposes of providing our Services.

6.1 Mandatory Registration Information

To create an account and use the Platform, you must provide:

• Identity Information: Full name, email address, mobile number, date of birth (for age verification)
• Authentication Information: Username and password (encrypted and stored securely)
• Educational Affiliation (Where Applicable): Name of college/university (collected only when registering for institution-specific tournaments, with explicit consent)
• Tournament Information: Gaming username/ID for tournament participation, preferred game titles

6.2 Optional Information

You may choose to provide the following optional information to enhance your experience:

• Profile Information: Profile picture, bio, social media links
• Team Information: Team name, team members’ gaming IDs (for team-based tournaments)
• Communication Preferences: Notification settings, marketing communication preferences

We do NOT collect: Gender, caste, religion, political affiliation, sexual orientation, biometric data, precise geolocation data, student ID numbers, course details, year of study, academic grades, or financial information beyond payment transaction confirmation.

6.3 Information Collected Automatically

When you use the Platform, we automatically collect:

• Technical Information: Device type, operating system version, device identifiers (for fraud prevention), mobile network information
• Network Information: IP address (for approximate geographic location and security purposes only – we do NOT collect precise GPS location data)
• Usage Information: Pages visited, tournament registrations, time spent on Platform, click patterns (aggregated for analytics)
• Cookies and Similar Technologies: Session cookies (essential for functionality), analytics cookies (with consent). You can manage cookie preferences through your browser settings.

6.4 Payment Information

Important: Fragnado does not directly collect payments for tournament registrations or any services. If tournament organizers or sponsors require payment, such transactions are processed through their own third-party payment gateways. We do NOT collect, process, or store any payment information, credit card details, debit card details, UPI information, or bank account details. Any purchases or transactions occur on external platforms, and you should review their respective privacy policies and terms.

Clarification: Payment processors, where applicable, are engaged directly by tournament organizers or sponsors, not by Fragnado. We have no access to or control over such payment processing activities.

6.5 Information from Third Parties

We may receive limited information from:

• Educational Institutions: Enrollment verification data (with your explicit consent) for eligibility confirmation
• Social Media Platforms: Basic profile information (name, email) if you choose to link your social media account for login purposes

7. PURPOSE AND LAWFUL BASIS FOR PROCESSING

We process your personal data only for specified, explicit, and legitimate purposes. The purposes and lawful basis for processing are:

7.1 Service Provision (Contractual Necessity)

• Create and manage your account
• Process tournament registrations and manage your participation
• Display tournament information relevant to your preferences
• Facilitate communication regarding tournaments and your account

7.2 Legal Compliance

• Verify age (18+ requirement) as mandated by law
• Verify student status at eligible institutions for collegiate tournaments
• Comply with Intermediary Guidelines and Digital Media Ethics Code Rules, 2021
• Respond to lawful requests from government authorities, law enforcement, courts, or regulatory bodies
• Retain certain data for regulatory compliance periods as specified in Section 11

7.3 Security and Fraud Prevention (Legitimate Interest)

• Detect and prevent fraud, abuse, security breaches, and unauthorized access
• Monitor for underage users and take corrective action
• Ensure fair play and detect cheating in tournaments
• Protect the rights, property, and safety of Fragnado, our users, and the public

7.4 Platform Improvement (Legitimate Interest)

• Analyze aggregated usage patterns to improve Services and develop new features
• Conduct research and analytics to enhance user experience
• Optimize Platform performance and functionality

7.5 Sponsor Content Display (Consent)

With your explicit consent, we may:

• Display sponsor content and advertisements relevant to esports and gaming
• Use aggregated, non-identifiable analytics to measure sponsor content effectiveness

Purpose Limitation: We do NOT use sponsor content viewing data for behavioral profiling, cross-platform tracking, or sale to third parties. You may opt out of personalized sponsor content by adjusting your preferences in account settings.

7.6 Marketing Communications (Consent)

With your separate, explicit consent, we may send promotional materials, newsletters, and information about new tournaments or features. You may withdraw consent and opt out at any time through account settings or email unsubscribe links.

7.7 No Automated Decision-Making

Important: Fragnado does not engage in solely automated decision-making that produces legal or similarly significant effects on users. All decisions that may significantly affect users involve human review and oversight.

8. DISCLOSURE AND SHARING OF PERSONAL DATA

We respect your privacy and will NOT sell, rent, or trade your personal data. We share personal data only in the following limited circumstances:

8.1 Data Processors and Service Providers

We engage trusted third-party Data Processors to assist in operating the Platform, including:

• Cloud hosting and storage providers
• Email and SMS communication services
• Analytics providers (aggregated data only)
• Customer support tools

Data Processor Accountability: All Data Processors are bound by written contractual obligations requiring: (i) processing personal data only per our instructions; (ii) implementing appropriate security measures; (iii) maintaining confidentiality; (iv) assisting with Data Principal rights requests; (v) deleting or returning data upon contract termination; and (vi) notifying us immediately of any data breaches.

8.2 Tournament Organizers and Sponsors (With Consent)

When you register for a tournament, we share limited information necessary for tournament administration:

• Shared with Tournament Organizers: Name, gaming ID, team details, contact information (email/mobile)
• Shared with Sponsors (Optional): Only if you explicitly consent, we may share aggregated tournament participation data (non-identifiable) or, with separate explicit consent, contact information for prize fulfillment

Tournament organizers and sponsors are contractually bound to use your data solely for tournament purposes and must comply with applicable data protection laws.

8.3 Educational Institutions (With Prior Consent)

We may share limited information with your educational institution ONLY with your prior explicit consent and solely for: (i) student verification; or (ii) organizing institution-specific tournaments. Data sharing agreements with institutions include confidentiality and data protection clauses.

8.4 Legal and Regulatory Disclosure

We may disclose personal data when legally required or permitted, including:

• In response to lawful requests from government authorities, law enforcement agencies, courts, or regulatory bodies under applicable Indian laws (IT Act, CrPC, etc.)
• To comply with court orders, warrants, subpoenas, or other legal processes
• To report cyber incidents to CERT-In as required under the Intermediary Guidelines
• To the Data Protection Board of India when required under the DPDP Act
• To protect legal rights, prevent fraud, or respond to imminent threats to safety

8.5 Publicly Visible Information

Certain information may be publicly displayed on the Platform, including: username, gaming ID, tournament participation history, rankings, and performance statistics. You acknowledge and consent to this public display as necessary for the competitive nature of esports tournaments.

8.6 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or substantially all assets, personal data may be transferred to the successor entity. We will: (i) provide at least 30 days’ advance notice via email and prominent Platform notice; (ii) inform you of choices regarding your data (including account deletion option); and (iii) require the successor to honor this Privacy Policy.

8.7 Aggregated and De-identified Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with third parties for research, analytics, marketing, or business intelligence purposes. Such data is not subject to this Privacy Policy as it is no longer personal data.

9. DATA SECURITY AND PROTECTION MEASURES

We implement comprehensive security practices and procedures mandated under the DPDP Act, 2023 and Rule 8 of the IT (SPDI) Rules, 2011 to protect personal data from unauthorized access, disclosure, alteration, or destruction.

9.1 Technical Security Controls

• Encryption: All sensitive personal data is encrypted in transit using TLS 1.2+ and at rest using AES-256 encryption
• Password Security: Passwords are hashed using bcrypt with salting (industry-standard one-way hashing)
• Network Security: Firewall protection, intrusion detection and prevention systems (IDS/IPS), DDoS mitigation
• Application Security: Regular security audits, penetration testing, vulnerability assessments, secure coding practices
• Infrastructure Security: Secure cloud hosting with ISO 27001 and SOC 2 certified providers, regular security patching

9.2 Organizational Security Controls

• Access Controls: Role-based access control (RBAC) ensuring employees access only data necessary for their job functions
• Multi-Factor Authentication (MFA): Mandatory MFA for all administrative and privileged accounts
• Employee Training: Regular data protection and cybersecurity training for all personnel; confidentiality agreements signed by all employees and contractors
• Audit Logs: Comprehensive logging of all data access and modifications with regular log reviews
• Vendor Management: All Data Processors undergo security assessment; data processing agreements mandate equivalent security standards

9.3 Data Breach Response

In the event of a personal data breach that is likely to cause harm to Data Principals:

• Immediate Containment: Incident response team activates containment protocols within 1 hour of detection
• CERT-In Reporting: Cyber incidents reported to Indian Computer Emergency Response Team (CERT-In) within the timelines prescribed by CERT-In (currently 6 hours) as mandated under Intermediary Guidelines
• Data Protection Board Notification: Breach notification submitted to Data Protection Board of India as required under DPDP Act
• User Notification: Affected Data Principals notified via email within 72 hours with details of: (i) nature of breach; (ii) categories of data affected; (iii) likely consequences; (iv) measures taken; and (v) contact information for queries
• Post-Incident Review: Comprehensive root cause analysis and implementation of preventive measures

9.4 User Responsibilities

You are responsible for: (i) maintaining confidentiality of your account credentials; (ii) using strong, unique passwords; (iii) not sharing your account with others; (iv) logging out after each session on shared devices; and (v) notifying us immediately of any unauthorized access to your account.

9.5 Limitations

While we implement robust security measures, no system is completely secure. We cannot guarantee absolute security against all possible threats. However, we continuously monitor emerging threats and update our security practices accordingly.

10. DATA RETENTION

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Our retention periods are:

10.1 Active Accounts

Personal data associated with active accounts is retained for the duration of your account’s existence and for the periods specified below after account closure.

10.2 Account Deletion by User

Upon your request to delete your account:

• Immediate Deletion: Profile information, preferences, and non-essential data deleted within 72 hours
• 180-Day Retention (Intermediary Compliance): Registration data (name, email, mobile, registration timestamp) retained for 180 days as mandated under Rule 3(1)(b) of the Intermediary Guidelines and Digital Media Ethics Code Rules, 2021 for law enforcement purposes
• Extended Retention (Legal Necessity): Financial transaction records retained for 7 years as required under Income Tax Act; data subject to ongoing legal proceedings retained until resolution

10.3 Inactive Accounts

If your account remains inactive (no login) for 36 consecutive months, we will: (i) send email notice 30 days before deletion; (ii) delete or anonymize all personal data except as required for legal compliance; and (iii) retain only aggregated, non-identifiable usage statistics.

10.4 Content Removal and Preservation

User-generated content (comments, posts, reviews) removed at your request or upon violation detection is preserved for 180 days as required under Intermediary Guidelines for law enforcement access, then permanently deleted.

10.5 Backup and Archival

Deleted data may persist in backup systems for up to 90 days before permanent removal. Backups are encrypted, access-controlled, and used solely for disaster recovery.

10.6 Analytics and Logs

Aggregated, anonymized analytics data and security logs may be retained indefinitely for business intelligence and security purposes. Such data cannot be used to identify you.

11. YOUR RIGHTS AS A DATA PRINCIPAL

Under the Digital Personal Data Protection Act, 2023, you have the following rights:

11.1 Right to Access (Section 11(1) DPDP Act)

You have the right to obtain from us:

• Confirmation of whether your personal data is being processed
• Summary of personal data being processed and the processing activities
• Identities of all other Data Fiduciaries and Data Processors with whom your data has been shared
• Other information as prescribed by the Data Protection Board of India

How to Exercise: Submit request via email to privacy@fragnado.com or through your account settings. We will respond within 30 days with the requested information in a clear, structured format.

11.2 Right to Correction and Updation (Section 11(2) DPDP Act)

You have the right to correct inaccurate or misleading personal data, and to complete incomplete personal data. Most information can be updated directly through your account settings. For assistance, contact privacy@fragnado.com. We will action corrections within 7 days.

11.3 Right to Erasure (Section 11(3) DPDP Act)

You may request erasure (deletion) of your personal data when:

• The purposes for which it was collected have been fulfilled
• You withdraw consent (where consent was the legal basis)
• The personal data is no longer necessary for the stated purposes

Exceptions: We may retain certain data where:

• Required by law (e.g., 180-day Intermediary Guidelines retention, tax records)
• Necessary for legal claims, compliance, or defense of legal rights
• Needed for fraud prevention and security purposes

How to Exercise: Use the ‘Delete Account’ feature in app settings or email privacy@fragnado.com. We will process erasure within 30 days (subject to legal retention requirements) and provide confirmation.

11.4 Right to Grievance Redressal (Section 11(4) DPDP Act)

You have the right to lodge complaints regarding data processing with our Grievance Officer (details in Section 17) or directly with the Data Protection Board of India.

11.5 Right to Nominate (Section 11(5) DPDP Act)

You may nominate another individual who shall exercise your rights under the DPDP Act in the event of your death or incapacity. To register a nominee, email privacy@fragnado.com with nominee details and authorization.

11.6 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw consent at any time. Withdrawal does not affect lawfulness of processing before withdrawal. Note that withdrawal of consent for essential Services may prevent us from providing those Services. Manage consent preferences in account settings or contact privacy@fragnado.com.

11.7 Right to Opt-Out of Marketing

You may opt out of promotional communications by: (i) clicking ‘Unsubscribe’ in marketing emails; (ii) adjusting notification preferences in account settings; or (iii) emailing marketing-optout@fragnado.com. You will continue to receive essential transactional communications (account security, tournament updates).

11.8 Verification and Response Timelines

For security purposes, we may require identity verification before fulfilling rights requests. Standard response time is 30 days; complex requests may require up to 60 days with notification of extension. We do not charge fees for exercising your rights unless requests are manifestly unfounded or excessive.

12. SIGNIFICANT DATA FIDUCIARY PROVISIONS

Under the DPDP Act, 2023, if Fragnado is notified as a ‘Significant Data Fiduciary’ by the Data Protection Board of India based on volume, sensitivity of data, risk to rights of Data Principals, or potential impact on India’s sovereignty and integrity, we will comply with additional obligations including:

• Data Protection Impact Assessment (DPIA): Conducting and documenting periodic DPIAs for high-risk processing activities
• Data Protection Officer (DPO): Appointing a dedicated DPO based in India with published contact details
• Data Audits: Conducting independent data audits by certified auditors as prescribed
• Enhanced Transparency: Publishing annual transparency reports on data processing activities, breaches, and government data requests

Users will be notified via Platform notice and email if Fragnado is designated as a Significant Data Fiduciary, along with details of enhanced protections.

13. CROSS-BORDER DATA TRANSFER

Personal data is primarily stored and processed within India on servers located in Indian data centers. However, certain Data Processors (cloud hosting, analytics, customer support tools) may process data from locations outside India.

13.1 Permitted Transfers

Cross-border transfers are conducted in accordance with Section 16 of the DPDP Act and only to countries or territories as notified and approved by the Central Government for data transfer, subject to notifications issued by the Central Government from time to time. Current transfers are limited to:

• Approved Jurisdictions: Data Processors located in jurisdictions with adequate data protection standards as determined by the Government of India
• Contractual Safeguards: Standard Contractual Clauses (SCCs) or equivalent mechanisms ensuring equivalent protection standards

13.2 Sensitive Data Localization

Certain categories of sensitive personal data, if designated by the Central Government under the DPDP Act, will be stored exclusively within India without cross-border transfer. We will update this policy and notify users if such restrictions are imposed.

13.3 Your Consent

By using the Platform, you consent to cross-border transfer of your personal data to jurisdictions notified and approved by the Central Government. All such transfers are subject to the safeguards described above. If you do not consent to such transfers, you may request account deletion.

14. THIRD-PARTY LINKS AND SERVICES

The Platform may contain links to third-party websites, applications, or services (including sponsor websites, social media platforms, payment gateways, and gaming platforms). We are not responsible for the privacy practices, content, or security of these third parties.

Third-party services are governed by their respective terms of service and privacy policies. We encourage you to review their policies before interacting with them. Your interactions with third parties are at your own risk, and we disclaim all liability arising from such interactions.

Social Media Integration: If you link your social media accounts, you authorize us to access limited profile information as permitted by the social media platform. You may revoke this authorization at any time through your social media account settings.

15. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time to reflect changes in our practices, legal requirements, technology, or operational needs. Material changes will be communicated as follows:

• Notice Period: At least 30 days’ advance notice for material changes via email and prominent Platform banner
• Updated Date: ‘Last Updated’ date at the top of this policy will reflect the most recent revision
• Renewed Consent: For changes affecting processing of sensitive personal data, we will seek your explicit renewed consent where required under the DPDP Act
• Version History: Previous versions of this policy are available upon request to privacy@fragnado.com

Your continued use of the Platform after the effective date of changes constitutes acceptance of the updated Privacy Policy. If you do not agree with changes, you must discontinue use and may request account deletion.

16. INTERMEDIARY OBLIGATIONS AND COMPLIANCE

As an intermediary under the Information Technology Act, 2000 and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, Fragnado complies with the following obligations:

16.1 Due Diligence Obligations

• Rules of Use: Published Terms of Service prohibiting unlawful content including: defamatory, obscene, pornographic, invasive of privacy, hateful, racially or ethnically objectionable, promoting illegal activities, infringing intellectual property, violating laws, or harming minors
• User Reporting: Mechanism for users to report unlawful content via in-app reporting feature and report@fragnado.com
• Privacy Policy Publication: This Privacy Policy is published in accordance with Rule 3(1)(b)

16.2 Removal of Unlawful Content

• 36-Hour Takedown: Upon receiving actual knowledge (from court order or government notification) of unlawful content, we will remove or disable access within 36 hours
• User Notification: Content creator notified of removal with reasons (unless prohibited by law)
• 180-Day Preservation: Removed content and associated user data preserved for 180 days for investigative or legal purposes, then permanently deleted

16.3 Information Retention for Investigation

User registration data (name, email, mobile, IP address, registration timestamp, and relevant account activity logs) is retained for 180 days after account deletion or suspension to assist government agencies in cyber security incidents and criminal investigations as required under Rule 3(1)(b).

16.4 CERT-In Cyber Incident Reporting

In compliance with the Information Technology (The Indian Computer Emergency Response Team and Manner of Performing Functions and Duties) Rules, 2013, we report cyber security incidents to CERT-In (Indian Computer Emergency Response Team) within the timelines prescribed by CERT-In (currently 6 hours) of noticing the incident.

Reportable incidents include:

• Data breaches, data leaks, or unauthorized access to personal data
• Malware, ransomware, or other security incidents
• Unauthorized access to IT systems or infrastructure
• Website defacement, denial of service attacks, or intrusions

16.5 Grievance Officer Appointment

We have appointed a resident Grievance Officer to address user complaints as required under Rule 3(2). Details are provided in Section 17.

16.6 Proactive Monitoring Limitations

Fragnado does not proactively monitor user-generated content. However, upon receiving notice of unlawful content or violations of Terms of Service, we take prompt action as described above. We use automated tools to detect and prevent spam, fraud, and security threats.

17. CONTACT INFORMATION AND GRIEVANCE REDRESSAL

17.1 Data Fiduciary Contact

For questions, concerns, or to exercise your rights under this Privacy Policy or the DPDP Act, contact:

Acceler Edtech Private Limited

Name: Shubhankar Chandorkar

Attention: Privacy Officer

Email: privacy@fragnado.com

Phone: +91 920987907

Registered Office: Acceler Edtech Private Limited, 304, KBC Towers, next to SRK K52, Karvenagar, Pune, Maharashtra 411052

17.2 Grievance Officer

In accordance with Section 11(4) of the DPDP Act, 2023 and Rule 3(2) of the Intermediary Guidelines, we have appointed a Grievance Officer to address Data Principal concerns and complaints:

Acceler Edtech Private Limited

Name: Aditi Jaiswal

Designation: Grievance Officer

Email: grievance@fragnado.com

Phone: +91 920987907 

Address: Acceler Edtech Private Limited, 304, KBC Towers, next to SRK K52, Karvenagar, Pune, Maharashtra 411052

17.3 Grievance Redressal Process

Our grievance redressal mechanism operates as follows:

• Step 1 – Complaint Submission: Submit complaints via email to grievance@fragnado.com or through the in-app grievance form. Include: (i) your contact details; (ii) description of grievance; (iii) supporting documents if any; and (iv) preferred resolution
• Step 2 – Acknowledgment: Receipt acknowledged within 24 hours with a unique complaint reference number
• Step 3 – Investigation: Grievance Officer reviews complaint, investigates facts, and coordinates with relevant teams
• Step 4 – Resolution: Complaint resolved within 15 days from receipt as mandated under Intermediary Guidelines. Resolution communicated via email with actions taken
• Step 5 – Escalation: If unsatisfied, you may escalate to the Data Protection Board of India or approach appropriate legal forums

17.4 Escalation to Data Protection Board

If your grievance is not resolved satisfactorily, you have the right to lodge a complaint with the Data Protection Board of India established under Section 18 of the DPDP Act, 2023. Board contact details will be published once operational and will be updated in this Privacy Policy.

18. GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by and construed in accordance with the laws of India, including:

• The Digital Personal Data Protection Act, 2023
• The Information Technology Act, 2000 and rules thereunder
• The Promotion and Regulation of Online Gaming Act, 2025
• The Consumer Protection Act, 2019

Any disputes arising out of or relating to this Privacy Policy, our data practices, or your rights as a Data Principal shall be subject to the exclusive jurisdiction of the courts located in Mumbai, India. The courts of Mumbai shall have sole and exclusive jurisdiction over any disputes.

19. FINAL ACKNOWLEDGMENT

By registering for and using the Fragnado Platform, you confirm that:

• You are at least 18 years of age and have full legal capacity
• You understand that Fragnado is an esports platform with no betting, wagering, or gambling activities
• Where applicable, you confirm student eligibility for collegiate tournaments
• You understand your rights under the DPDP Act, 2023 and how to exercise them as described in Section 11

Your consent to data processing and other terms are detailed in Section 5 above.

For questions or to exercise your rights under the DPDP Act, 2023,

contact our Privacy Officer at privacy@fragnado.com

or our Grievance Officer at grievance@fragnado.com