Privacy Policy

1 Who We Are (Data Controller)

Come AAP (comeaap.com) is the data controller for all personal information collected through this website and gaming platform. Come AAP is the official gaming and sportsbook platform at comeaap.com, operated for the purpose of providing real-money gaming entertainment to Indian adults.

2 Data We Collect

Come AAP collects minimal personal data. Here is a full breakdown:

We do not collect: payment information, Aadhaar numbers, PAN numbers, Come AAP account credentials, or any sensitive personal data as defined under the IT Act, 2000.

3 How We Use Your Data

We use collected data for the following purposes only:

• Contact form data (name, email, message): To respond to your enquiry. We do not add you to any mailing list without explicit consent.
• Analytics data: To understand how users navigate Come AAP, which pages are most popular, and how we can improve the site.
• Server logs (IP, browser): For security monitoring, abuse prevention, and technical troubleshooting only.
• Platform analytics data: To understand player behaviour and improve the Come AAP platform. Analytics data is processed in aggregated, anonymised form and never used to identify individual players without consent.

We do not sell, rent, or trade your personal information to any third party for their marketing purposes.

4 Legal Basis for Processing

Under GDPR principles and the Indian Information Technology Act, 2000, we process personal data on the following legal bases:

• Consent: For analytics cookies — you may withdraw consent at any time via browser settings
• Legitimate interest: For server security logs and basic website analytics
• Contract performance: When you submit a contact form, processing your name and email to respond
• Legal obligation: Retaining records as required by Indian law

5 Third-Party Services

Come AAP uses the following third-party services that may process data on our behalf:

• Google Analytics (GA4): Website analytics. Google may collect anonymised usage data. Google Privacy Policy. You can opt out via Google Analytics Opt-Out.
• Formspree: Contact form processing. When you submit our contact form, your data is processed by Formspree. Formspree Privacy Policy.
• UPI Payment Processors: When you make deposits or withdrawals via UPI, your transaction data is processed by the relevant payment gateway under their own privacy policy and RBI-compliant data protection standards.
• Cloudflare (if applicable): CDN and security services. Cloudflare Privacy Policy.

6 Platform Analytics & Tracking

Come AAP uses analytics cookies and session tracking to improve platform performance and user experience. When you visit comeaap.com, analytics tools may collect anonymised data about your browsing behaviour, pages visited, and time spent on the platform.

Our analytics tracking:

• Collects anonymised, aggregated data — individual players are not personally identified
• Does not involve sharing your personal gaming data with third-party advertising networks
• Is managed via Google Analytics (GA4) under Google's data processing terms
• Can be opted out of via your browser's cookie settings at any time

7 Cookie Policy

Come AAP uses the following types of cookies:

To manage or delete cookies, use your browser's settings (Chrome: Settings → Privacy → Cookies; Firefox: Options → Privacy; Safari: Preferences → Privacy). Disabling analytics cookies will not affect your ability to use Come AAP.

8 Data Retention

• Contact form submissions: Retained for 12 months after your enquiry is resolved, then securely deleted
• Server logs: Retained for 90 days for security purposes, then automatically purged
• Analytics data: Retained per Google Analytics default settings (up to 14 months for aggregated data)
• Session/performance data: Retained for 30 days, then automatically purged

9 Data Security

Come AAP implements reasonable technical and organisational measures to protect your personal data:

• HTTPS/SSL encryption for all data transmission between your browser and our website
• Contact form data transmitted securely to Formspree via encrypted connection
• No sensitive payment or financial data stored on our servers
• Access to any collected data restricted to authorised team members only

While we implement industry-standard security measures, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security of data transmitted to or from our site.

10 Your Rights

Under GDPR principles and the Indian Information Technology Act, 2000 (and the proposed Digital Personal Data Protection Act), you have the following rights regarding your personal data:

• Right of Access: Request a copy of all personal data we hold about you
• Right to Rectification: Request correction of inaccurate personal data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restriction: Request that we limit how we use your data
• Right to Data Portability: Request your data in a machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw analytics consent at any time via browser settings

To exercise any of these rights, contact us at hello@comeaap.com. We will respond within 30 days. Identity verification may be required before fulfilling your request.

11 Children's Privacy

Come AAP is strictly intended for adults aged 18 and above. We do not knowingly collect personal data from persons under 18 years of age. If we become aware that a person under 18 has submitted personal data to us, we will delete it immediately. If you believe we have inadvertently collected data from a minor, please contact us immediately at hello@comeaap.com.

12 International Data Transfers

Some of our third-party service providers (such as Google Analytics and Formspree) may transfer and process your data outside of India. Where such transfers occur, we rely on appropriate safeguards including Standard Contractual Clauses and the service provider's compliance with applicable international data protection laws.

13 Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically. Continued use of Come AAP after changes constitutes acceptance of the updated policy.

14 Contact for Privacy Concerns

For any privacy-related questions, requests to exercise your data rights, or to report a privacy concern, please contact our privacy team: