CORPSE
The Operating System for Esports
Corpse Privacy Policy
Version 2.0 — Complete Platform Coverage
Account • KYC • Arena • Guild • Payments • ELO • Organiser • Analytics • Consent
Binding on: All Users | All Organisers | All Data Subjects | All Platform Interactions
This Corpse Privacy Policy v2.0 is the single, definitive, and complete document governing how [CORPSE ESPORTS PRIVATE LIMITED] collects, uses, stores, shares, and protects personal data across the entire Corpse platform — for all users, all organisers, and all data subjects.
PART XXI Grievance Officer & Contact
70. Grievance Officer Details
71. How to File a Privacy Complaint
PART I — INTRODUCTION & LEGAL FRAMEWORK
1. Who We Are & What This Policy Covers
[CORPSE ESPORTS PRIVATE LIMITED] ("Company", "we", "us", "our") operates the Corpse platform — a competitive esports infrastructure platform available as a mobile application on iOS and Android ("Platform"). This Corpse Privacy Policy ("Policy") is the single, definitive, and complete document governing how the Company collects, uses, stores, shares, and protects personal data across every feature, function, and interaction on the Platform — for all users and all organisers.
This Policy covers data processing across every aspect of the Platform including:
- Account creation, authentication, and session management.
- Player profile — username, avatar, in-game ID, ELO, and Ecosystem Pipeline tier.
- KYC verification and financial identity for players and organisers.
- Arena participation — registration, match play, result submission, and disputes.
- ELO Engine and Ecosystem Pipeline tier progression.
- Guild creation, membership, roles, and unit tiers.
- Organiser account data, performance metrics, reliability scoring, and dashboard usage.
- Financial transactions — entry fees, prize disbursements, organiser settlements, and TDS compliance.
- Notifications — in-app, email, SMS, and WhatsApp communications.
- Platform analytics — Firebase, Sentry error monitoring, and business intelligence.
- Account deletion and post-deletion data handling.
- App Store and Play Store data — outside the Company's direct control.
2. Who This Policy Applies To
This Policy applies to every individual who interacts with the Platform in any capacity:
- Guest Users — individuals who access the Platform without creating an account.
- Registered Users — individuals who create and maintain an account on the Platform.
- Minor Users — Registered Users below the age of 18 years.
- KYC-Verified Users — Registered Users who have completed KYC verification.
- Captains — Registered Users who lead squads and conduct financial transactions.
- Organisers — Registered Users or entities who create and manage arenas on the Platform.
- Guild Members — Registered Users who are members of guilds on the Platform.
3. Legal Basis for Processing Personal Data
The Company processes personal data on the following legal bases under the Digital Personal Data Protection Act, 2023:
Legal Basis | Description | Data Categories Covered |
Consent | The data subject has given explicit, informed consent to the processing of their personal data for the specific purpose stated at the time of collection. Consent may be withdrawn at any time — see Section 62. | Registration data, optional profile data, marketing communications, WhatsApp notifications, analytics |
Contractual Necessity | Processing is necessary to perform the contract between the Company and the data subject — i.e., to provide the Platform's services. | Account data, session data, arena registration, squad data, organiser data, financial transactions |
Legal Obligation | Processing is required to comply with a legal obligation under Indian law. | KYC data (PMLA), TDS records (Income Tax Act), financial records (RBI guidelines) |
Legitimate Interests | Processing is necessary for the Company's legitimate interests in operating a secure, fair, and commercially viable platform — provided those interests are not overridden by the data subject's rights. | Platform analytics, security monitoring, ELO calculation, fraud detection, organiser reliability scoring |
4. Governing Legislation
Legislation | Relevance |
Digital Personal Data Protection Act, 2023 (DPDP Act) | Primary data protection legislation governing all personal data processing on the Platform. Establishes user rights including consent withdrawal. |
Information Technology Act, 2000 (as amended) | Digital data, electronic records, intermediary obligations, and data security. |
IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 | Grievance redressal, content moderation, and data handling obligations for intermediaries including the requirement for a named Grievance Officer. |
Aadhaar (Targeted Delivery) Act, 2016 | Aadhaar-based eKYC — consent, usage restrictions, and data handling. |
Prevention of Money Laundering Act, 2002 (PMLA) | KYC obligations, financial record-keeping, and suspicious transaction reporting. |
Income Tax Act, 1961 | TDS deduction and reporting on prize winnings. |
RBI Guidelines on Payment Aggregators | Payment data handling, KYC for financial transactions. |
PART II — DATA COLLECTED — ACCOUNT CREATION & AUTHENTICATION
5. Guest User Data
When a user accesses the Platform as a Guest User without creating an account, the following data is collected automatically:
Data Field | Why Collected | Retention |
Device type and OS version | To optimise app performance for the user's device | Duration of guest session only |
App version | To ensure compatibility and direct user to app updates | Duration of guest session only |
General location (city/state) | To display regionally relevant arenas and leaderboards | Duration of guest session only |
Session timestamps | To measure platform engagement and optimise user experience | Aggregated and anonymised — no personal link |
Firebase analytics identifiers | To track app usage patterns without personal identification | Per Firebase Analytics retention settings |
Note: Guest User data is not linked to any individual identity. No name, email, phone number, or government identity document is collected from Guest Users.
6. Registration Data
Data Field | Why Collected | Legal Basis | Retention |
Email address | Primary identifier and communication channel | Contractual necessity | Duration of account + 5 years post-deletion per PMLA |
Username | Unique display name — permanent once set | Contractual necessity | Duration of account — anonymised post-deletion |
Date of birth | Age eligibility verification and Minor User classification | Contractual necessity | Duration of account |
State/region | Regional arena display and leaderboard segmentation | Legitimate interests | Duration of account |
Account creation timestamp | Audit log and account management | Legal obligation | 5 years post-deletion |
IP address at registration | Security — detecting fraudulent account creation | Legitimate interests | 90 days |
7. Authentication Method Data
Auth Method | Data Collected | What We Store | What We Never Store |
Magic Link (Email) | Email address. Magic link token generated by Platform. | Email address, token hash, token expiry, usage log. | The magic link itself — single-use, not stored after consumption. |
Google OAuth | Google account email and OAuth token from Google. | Email address, OAuth provider ID, authentication timestamp. | Google account password or any credential beyond the OAuth token. |
Apple Sign-In | Apple-provided email (or relay email) and Sign-In identifier. | Apple Sign-In identifier, email, authentication timestamp. | Apple ID password or any credential beyond the Sign-In token. |
8. Auto-Generated Data at Sign-Up
- Unique user ID (UUID) — a system-generated identifier used internally to reference the user's account.
- Account status flag — active, suspended, or banned.
- ELO starting score — assigned at account creation as the baseline competitive rating.
- Ecosystem Pipeline starting tier — assigned at account creation as the entry-level competitive tier.
- Account creation timestamp — the exact date and time the account was created.
9. Session & Device Data
Data Field | Why Collected | Retention |
JWT session token (hashed) | To maintain the authenticated session on the device | Until sign-out, credential change, suspension, or 90-day expiry |
Device type and OS version | To optimise the app experience and diagnose technical issues | Duration of active session |
Device identifier | To manage multi-device sessions and detect suspicious access | Duration of active session |
Login timestamp | Security audit log | 90 days |
IP address at login | Security — detecting anomalous login patterns | 90 days |
Last active timestamp | To apply 90-day inactivity expiry to sessions | Updated in real time — deleted on session expiry |
10. Phone Number Collection
A phone number is not a mandatory field at account registration on the Platform. Phone numbers are collected only in the following specific circumstances:
- SMS notifications — if a user opts into SMS notifications, their phone number is collected at the time of opt-in. This is entirely optional.
- WhatsApp notifications — if a user opts into WhatsApp communications, their WhatsApp-linked phone number is collected at the time of opt-in. This is entirely optional and requires explicit consent.
- Aadhaar OTP verification during KYC — the phone number linked to the user's Aadhaar account is used by UIDAI's systems to deliver the OTP. The Aadhaar-linked phone number itself is not stored by the Company — only the OTP verification result is recorded.
Phone numbers collected for SMS or WhatsApp notifications are used exclusively for delivering those communications and are not shared with any third party beyond the communication service provider. Users can remove their phone number at any time by disabling SMS or WhatsApp notifications in settings.
11. Cross-Device Data Linkage
The Platform allows users to be simultaneously logged in on multiple devices. The following explains how data from multiple devices is linked to a single user account:
- All devices that a user authenticates on are linked to the same user account via the unique user ID (UUID) assigned at registration.
- Session tokens are device-specific — each device carries its own JWT session token. However, all session tokens reference the same underlying user account.
- Actions taken on one device (e.g., joining an arena, updating a profile) are reflected immediately across all active sessions on other devices — as they are stored at the account level, not the device level.
- The Platform maintains a session log per device — showing the device type, login timestamp, and last active timestamp for each active session. This data is accessible to the Platform's security team for anomaly detection.
- Signing out of one device terminates only that device's session token. Other device sessions remain active.
- A user's complete activity history — match records, ELO progression, guild membership — is account-level data and is accessible from any authenticated device.
Note: The Platform does not currently provide users with a self-service view of all active sessions across their devices. If you believe your account has been accessed on an unrecognised device, contact support@corpsearena.com immediately for a security review.
PART III — DATA COLLECTED — PLAYER PROFILE
12. Profile Fields
Profile Field | Set By | Changeable? | Public? | Retention |
Username | User at registration | No — permanent | Yes | Duration of account. Anonymised post-deletion. |
Avatar | User (optional) | Yes — any time | Yes | Duration of account. Deleted on account deletion. |
State/Region | User at registration | Yes — via settings | No | Duration of account. |
ELO Score | Platform (auto) | No — calculated automatically | Yes | Duration of account. Anonymised post-deletion. |
Ecosystem Tier | Platform (auto) | No — calculated automatically | Yes | Duration of account. |
Guild Tag | Platform (guild join) | Auto-updated on guild change | Yes | Duration of guild membership. |
Match History | Platform (auto) | No — system record | No | Duration of account. Anonymised post-deletion. |
13. In-Game ID Data
- One in-game ID per game title — a player cannot register multiple in-game IDs for the same game.
- The in-game ID is used to verify player identity before Arena matches and to link match performance data to the correct player profile.
- The in-game ID can be updated via profile settings — subject to verification that the new ID belongs to the same player.
- The in-game ID is private — not displayed on the player's public profile and not visible to other Platform users.
- Retained for the duration of the account and deleted upon account deletion.
14. Public vs Private Profile Data
Data Field | Visibility | Who Can See It |
Username | Public | All Platform users and, where applicable, Guest Users |
Avatar | Public | All Platform users and, where applicable, Guest Users |
ELO Score | Public | All Platform users — displayed on profile and leaderboard |
Guild Tag | Public | All Platform users — displayed alongside username |
Ecosystem Tier | Public | All Platform users — displayed on profile |
Match History | Private | Player only — not visible to other users |
In-Game ID | Private | Platform systems only — not visible to any user |
Email Address | Private | Platform only — never displayed to any user |
Date of Birth | Private | Platform only — used only for age verification |
Phone Number | Private | Platform only — used for SMS/WhatsApp notifications if opted in |
State/Region | Private | Platform only — used for regional matchmaking |
KYC Data | Private | Platform and eKYC provider only — never displayed to any user |
PART IV — DATA COLLECTED — KYC VERIFICATION
15. What KYC Data Is Collected
KYC Data | Collected By | Purpose | Legal Basis |
Aadhaar number (12 digits) | eKYC Provider (via UIDAI OTP flow) | Identity verification against UIDAI database | Aadhaar Act 2016 + PMLA 2002 |
Aadhaar-linked name | eKYC Provider (retrieved from UIDAI) | Name matching for identity consistency | Aadhaar Act 2016 |
Aadhaar-linked address | eKYC Provider (retrieved from UIDAI) | Address verification | Aadhaar Act 2016 |
PAN number (10 characters) | eKYC Provider + Corpse | Tax identity for TDS deduction and reporting | Income Tax Act 1961 |
Bank account number | eKYC Provider + Corpse | Prize disbursement and settlement payments | RBI guidelines |
IFSC code | eKYC Provider + Corpse | Bank account routing for disbursements | RBI guidelines |
Account holder name | eKYC Provider + Corpse | Beneficiary identification for payments | RBI guidelines |
UPI ID (if provided) | eKYC Provider + Corpse | Alternative payment method routing | RBI guidelines |
16. What Corpse Stores vs eKYC Provider
Data | Stored by Corpse? | Stored by eKYC Provider? | Form of Storage |
Full Aadhaar number | No — never stored by Corpse | Yes | Encrypted, in compliance with UIDAI regulations |
Masked Aadhaar (last 4 digits) | Yes | Yes | Corpse: masked form only. eKYC Provider: full form. |
Aadhaar XML / eKYC XML | No | Yes | Digitally signed XML per UIDAI format |
PAN number | Yes — encrypted | Yes | Both parties: encrypted form |
Bank account number | Yes — masked and encrypted | Yes | Corpse: masked. eKYC Provider: full form. |
IFSC code | Yes | Yes | Plain text — not sensitive |
KYC verification status | Yes | Yes | Verified / Pending / Rejected |
eKYC reference ID | Yes | Yes | Transaction reference for audit |
Verification session logs | No | Yes | IP address, timestamps, session metadata |
Important: The Company does not store your full Aadhaar number. Only the last 4 digits are retained on Corpse servers. Your full Aadhaar data is held exclusively by the authorised eKYC service provider in compliance with UIDAI regulations.
17. KYC Data Sharing — Razorpay
The following KYC-verified data is shared with Razorpay India Private Limited, our payment gateway partner, strictly for processing financial transactions:
- Verified bank account details — account number, IFSC code, account holder name — for prize disbursement and organiser settlement transfers.
- PAN number — for TDS deduction and reporting to the Income Tax Department.
- Name as per KYC — for payment beneficiary identification.
This data sharing is mandatory for regulatory compliance and cannot be opted out of. By completing KYC on the Platform, you consent to this data being shared with Razorpay for the stated purposes.
18. KYC Data Retention
- Financial transaction records including KYC data are retained for a minimum of 5 years from the date of the last transaction — as mandated by PMLA 2002.
- The eKYC provider retains KYC data per their own regulatory obligations — the Company does not control the eKYC provider's retention schedule.
- Razorpay retains KYC-related payment data per their own privacy policy and RBI requirements.
PART V — DATA COLLECTED — ARENA & MATCH PARTICIPATION
19. Arena Registration Data
- Arena ID — the unique identifier of the Arena registered for.
- Squad ID — the unique identifier of the squad registered with.
- Player role in squad — Captain or Member.
- Registration timestamp — the exact date and time of registration.
- Payment record (paid arenas only) — Razorpay order reference, payment status, amount paid, timestamp.
- KYC verification status at time of registration — confirming Captain's KYC was valid at registration.
20. Match Result & Screenshot Data
- Match result screenshot — captured via the auto-capture system — stored for result verification.
- Verified match result — officially verified result including squad rankings, kill counts, and game-mode statistics.
- Result submission timestamp — date and time of submission.
- Organiser result submission — organiser's screenshot and submission timestamp.
- Dispute record (if any) — dispute raised, evidence submitted, and Platform determination.
Match result data and screenshots are retained for the duration of the account and for 2 years after account deletion to maintain the integrity of historical competitive records.
21. Squad & Room Card Data
- Squad composition record — the list of players (user IDs) in a squad for each Arena.
- Squad invite token log — records of invite tokens generated, used, and expired.
- Room card data — the custom room ID and password. Deleted from active records after the Arena concludes.
22. Dispute & Support Data
- Support ticket content — the player's description of the issue.
- Evidence submitted — screenshots or files attached to the dispute.
- Support agent interaction log — communications between the player and the support team.
- Resolution record — the outcome of the dispute or support interaction.
Support and dispute data is retained for 2 years from the date of resolution.
PART VI — DATA COLLECTED — ELO & ECOSYSTEM PIPELINE
23. ELO Score Data
- Player ELO score — individual competitive rating, updated in real time after every Arena. ELO can increase or decrease.
- Squad ELO — collective ELO of a squad for a specific Arena.
- Guild ELO — collective ELO of the guild, calculated from guild squad performance.
- ELO history log — record of ELO changes after each Arena including Arena ID, result, change amount, and new total.
ELO data is publicly visible on the player's profile and Platform leaderboard. ELO history is retained for the duration of the account and anonymised after deletion.
24. Ecosystem Tier Data
- Current tier — the player's current tier in the Ecosystem Pipeline (tier names to be confirmed before launch).
- Tier history — a log of tier changes including the date and trigger.
- Seasonal reset record — at each seasonal reset, 60% of the player's ELO is carried forward. Pre-reset and post-reset ELO are both recorded.
25. Match Performance Analytics
- Total arenas participated in — both free and paid.
- Total wins, losses, and placement records.
- Game-mode specific statistics — kill counts, survival times, and statistics derived from verified match results.
- Win/loss ratio and performance trends over time.
PART VII — DATA COLLECTED — GUILD SYSTEM
26. Guild Membership Data
- Guild ID — the unique identifier of the guild the player is a member of.
- Guild membership timestamp — the date and time the player joined the guild.
- Guild join history — all guilds the player has been a member of, with join and departure dates.
- Guild membership status — active member, departed, or removed.
27. Guild Role & Unit Tier Data
- Guild role — Captain, Vice Captain, Manager, or Member — displayed on the guild profile.
- Unit tier — Apex, Specialized, Core, or Rising — displayed on the member's profile within the guild context.
- Role change history — a log of role changes within the guild.
- Unit tier assignment history — a log of unit tier assignments and changes.
28. Guild ELO & Leaderboard Data
- Guild ELO score — the guild's collective competitive rating, updated after each qualifying Arena.
- Guild leaderboard ranking — the guild's current rank on the Platform's public guild leaderboard.
- Guild ELO history — a log of ELO changes after each qualifying Arena.
Guild ELO and leaderboard data are publicly visible. Upon guild dissolution, data is removed from public display but retained in internal records for 2 years.
PART VIII — DATA COLLECTED — ORGANISER DATA
29. Organiser Account & Identity Data
When a user creates an Organiser account or acts in an organiser capacity on the Platform, the following data is collected in addition to their standard Registered User data:
- Organiser role flag — a system designation indicating the user holds Organiser privileges on the Platform.
- KYC verification status — organisers must complete KYC before depositing security pools or receiving settlements. KYC data collection follows the same framework described in Part IV.
- Organiser account creation timestamp — the date and time the user first created an arena as an organiser.
- Organiser subscription tier — the organiser's current subscription tier (Starter, Pro, or Elite), if applicable.
30. Organiser Performance & Reliability Data
The Platform collects and maintains the following organiser performance data to operate its reliability scoring and trust index systems. This data is used to ensure the quality and integrity of arenas hosted on the Platform:
- Arenas created — a complete record of all arenas the organiser has created on the Platform, including arena ID, creation date, format, and status.
- Arenas completed — a record of arenas successfully run to completion.
- Arenas cancelled — a record of arenas cancelled by the organiser, including the stage at which the cancellation occurred and any refund actions triggered.
- Cancellation rate — the percentage of arenas cancelled relative to arenas created, calculated by the Platform's analytics system.
- Reliability score — a composite score calculated by the Platform based on the organiser's completion rate, cancellation history, participant feedback, and payment consistency. This score is used internally for trust assessment and may be displayed on the organiser's public profile.
- Trust index — a broader metric incorporating the reliability score, account age, KYC status, and dispute history.
- Streak performance — consecutive arena completion records used to reward high-performing organisers.
- Dispute records — any disputes raised by participants against arenas organised by the organiser, including the nature of the dispute and the Platform's determination.
Organiser performance data is used to:
- Display reliability and trust information on the organiser's public profile — enabling players to make informed decisions about which arenas to join.
- Determine the organiser's eligibility for advanced Platform features and subscription benefits.
- Identify and investigate organisers with patterns of conduct that may indicate bad-faith operation.
Important: Organiser performance data — including cancellation rate, reliability score, and dispute history — may be visible to Platform users on the organiser's public profile. Organisers should be aware that their operational track record is a public-facing metric on the Platform.
31. Organiser Dashboard Usage Data
When an organiser uses the Platform's organiser dashboard tools, the following usage data is collected:
- Arena creation and configuration actions — the parameters set when creating an arena, including preset selection, entry fee configuration, prize structure, and scheduling.
- Participant management actions — slot fill status monitoring, squad list reviews, and payment status checks.
- Result submission actions — the organiser's result screenshot submissions, submission timestamps, and the 60-second upload window interactions.
- Dashboard access logs — timestamps of organiser dashboard sessions for audit purposes.
Dashboard usage data is used to improve the organiser tools, diagnose technical issues, and maintain audit trails for dispute resolution. It is not shared publicly.
32. Organiser Financial Data
All financial data related to organiser transactions is governed by Part IX of this Policy. For organisers specifically, the following additional financial data is collected:
- Security deposit records — the amount deposited, deposit timestamp, Razorpay reference, and escrow allocation for each arena.
- Organiser settlement records — the final settlement amount, deductions applied (platform commission, GST, bank payout fee), and transfer reference for each completed arena.
- GST invoice records — copies of all GST invoices issued to the organiser for platform commission charged, retained for 7 years per Income Tax Act requirements.
- Refund records — any security deposit refunds issued to the organiser, including partial refunds triggered by cancellation.
33. Organiser Public Profile Data
The following organiser data is publicly visible on the organiser's Platform profile:
Data Field | Visibility | Notes |
Organiser name / username | Public | The organiser's registered Platform username |
Reliability score | Public | Displayed as a rating on the organiser's profile |
Total arenas hosted | Public | Aggregate count of all arenas hosted |
Completion rate | Public | Percentage of arenas completed vs cancelled |
Verified badge (if earned) | Public | Awarded based on KYC status and performance threshold |
Active subscription tier | Public | Starter, Pro, or Elite — displayed on profile |
Cancellation history details | Private | Internal use only — not displayed publicly |
Individual arena financial details | Private | Internal use only — not displayed publicly |
PART IX — DATA COLLECTED — FINANCIAL TRANSACTIONS
34. Entry Fee & Payment Transaction Data
- Razorpay order reference — the unique transaction identifier generated by Razorpay.
- Payment amount — the entry fee amount paid.
- Payment method — UPI, net banking, debit card, credit card, or mobile wallet.
- Payment status — initiated, pending, verified, failed, or refunded.
- Payment timestamp — the date and time of the transaction.
- Razorpay webhook log — the server-side confirmation record of payment verification.
- PG charge amount — the 2% payment gateway fee paid by the player.
Payment transaction data is retained for a minimum of 5 years from the date of the transaction in compliance with PMLA and RBI requirements.
35. Prize Disbursement Data
- Disbursement amount — gross prize amount and net amount after TDS and bank payout fee deduction.
- TDS amount deducted — the 30% TDS deducted before disbursement.
- Bank payout fee — the Rs 5.90 bank transfer fee deducted.
- Recipient bank account details — masked account number and IFSC code.
- Disbursement timestamp — the date and time the transfer was initiated.
- Bank transfer reference — the NEFT/IMPS reference number.
- Disbursement status — initiated, credited, or failed.
36. TDS & Tax Compliance Data
- TDS amount deducted per disbursement.
- Recipient PAN number — used for TDS reporting to the Income Tax Department.
- TDS challan reference — the government reference number for TDS deposited.
- Form 26AS filing record — confirmation that TDS deducted has been reported and will appear in the recipient's Form 26AS.
TDS and tax compliance data is retained for a minimum of 7 years in compliance with Income Tax Act record-keeping requirements.
37. Escrow & Financial Record Retention
All financial transaction records — including entry fees, organiser deposits, prize disbursements, platform commissions, TDS deductions, and refunds — are retained for a minimum of 5 years from the date of the transaction as required by PMLA 2002 and RBI guidelines. These records are not deleted upon account deletion.
PART X — DATA COLLECTED — NOTIFICATIONS & COMMUNICATIONS
38. Notification Channels & Data
Channel | Data Used | Purpose | Opt-Out Available? |
In-App Notifications (FCM) | Firebase Cloud Messaging device token, notification content, read/unread status, delivery timestamp. | Real-time event notifications — room card, arena updates, result posting, prize disbursement, flag/suspension notices. | Transactional notifications cannot be opted out of. Marketing notifications can be managed in settings. |
Registered email address, email content, delivery status. | Account communications, magic link authentication, payment receipts, prize disbursement confirmations, policy updates, disciplinary notifications. | Transactional emails cannot be opted out of. Marketing emails include an unsubscribe link. | |
SMS | Phone number (if provided and opted in), SMS content, delivery status. | Critical transactional alerts where email or push notification may be insufficient. | Yes — SMS is opt-in. Can be disabled in settings. |
Phone number linked to WhatsApp (if provided and opted in), message content, delivery status. | Supplementary communications for important platform updates. | Yes — WhatsApp requires explicit opt-in and can be disabled in settings at any time. |
39. Communication Logs
The Platform maintains logs of all communications sent to users for audit and compliance — confirming required communications were sent, supporting dispute resolution, and troubleshooting delivery failures. Communication logs are retained for 2 years from the date of the communication.
PART XI — DATA COLLECTED — PLATFORM ANALYTICS
40. Firebase Analytics & App Usage Data
The Platform uses Firebase Analytics (provided by Google LLC) to collect aggregated, anonymised data about how users interact with the Platform. This data is used to improve platform features and optimise user experience. Data collected includes:
- Screen views and navigation flow — which screens users visit and in what order.
- Session duration — how long users spend on the Platform per session.
- Feature usage rates — which features are used most and least frequently.
- Crash and error reports — technical errors experienced by users.
- Device and OS distribution — the range of devices on which the Platform is used.
- Geographic distribution — which regions have the highest Platform usage.
Firebase Analytics data is processed by Google LLC on the Company's behalf under a data processing agreement. For information about how Google processes analytics data, refer to the Google Privacy Policy at policies.google.com.
41. Performance & Error Monitoring — Sentry
The Platform uses Sentry (provided by Functional Software Inc.) for application error tracking and performance monitoring. Sentry captures unhandled exceptions and performance metrics to enable the engineering team to identify and resolve technical issues.
The following data may be captured by Sentry in connection with error events:
- Error stack traces — technical descriptions of application errors. These do not contain personal data in standard operation.
- Device type and OS version — to help diagnose device-specific issues.
- App version — to identify which version of the application experienced the error.
- Anonymised user ID — a hashed, non-reversible identifier used to determine how many unique users experienced a given error. The full user ID or any personally identifying information is never sent to Sentry.
- Breadcrumb events — a log of recent user actions immediately before an error occurred — used to reproduce the error. These are limited to technical events (screen navigation, API calls) and do not include personal data.
Sentry data is used exclusively for debugging and improving application stability. It is not used for marketing or user profiling. Sentry retains error data per their own data retention settings.
Sentry is a third-party service provided by Functional Software Inc. For information about how Sentry processes data, refer to sentry.io/privacy.
42. Business Analytics
The Company uses aggregated and anonymised Platform data for internal business intelligence including tournament metrics, engagement metrics, and financial reporting. Business analytics data does not identify individual users and is retained for the duration of the Company's operations.
43. App Store & Play Store Analytics
When users download, install, or use the Corpse app through the Apple App Store or Google Play Store, Apple Inc. and Google LLC respectively collect their own analytics data about app downloads, installation rates, and usage patterns. This data is collected directly by Apple and Google and is subject to their own privacy policies.
- The Company receives aggregated, anonymised analytics reports from Apple App Store Connect and Google Play Console — such as total download counts and crash reports. These reports do not contain individual user data.
- The Company does not control what data Apple or Google collect from your device in connection with the App Store or Play Store. Please refer to Apple's Privacy Policy at apple.com/privacy and Google's Privacy Policy at policies.google.com for information about their data collection practices.
- The App Store and Play Store analytics are entirely separate from the Platform's own analytics described in Sections 40, 41, and 42.
PART XII — HOW WE USE YOUR DATA — PURPOSE MAPPING
44. Full Purpose Mapping Table
Data Category | Purpose of Use |
Email address | Account authentication (magic link), transactional communications, policy updates, disciplinary notices, prize/payment confirmations. |
Username | Unique display identity across the Platform — profile, leaderboard, squad, guild. |
Avatar | Visual identity on profile and squad listings. |
Date of birth | Age eligibility verification — applying Minor User restrictions where applicable. |
State/region | Regional arena discovery, leaderboard segmentation, regional analytics. |
Phone number (if provided) | SMS and/or WhatsApp notifications — only if explicitly opted in by the user. |
In-game ID | Pre-match identity verification — confirming the player in the game room matches the registered player. |
Session tokens | Maintaining authenticated access to the Platform across devices and sessions. |
Device & IP data | Security monitoring — detecting suspicious login patterns, anomalous activity, and potential account compromise. |
Cross-device session data | Linking all device sessions to the correct user account — enabling consistent experience across devices and security monitoring. |
KYC data | Financial identity verification, prize disbursement, TDS deduction and reporting, PMLA compliance. |
Arena registration records | Managing tournament participation, slot allocation, duplicate registration prevention, payment verification. |
Match result & screenshots | Result verification, prize disbursement, dispute resolution, ELO calculation, historical competitive records. |
Squad & guild data | Squad management, guild management, ELO calculation, leaderboard rankings, talent discovery. |
ELO scores | Competitive ranking, leaderboard display, Ecosystem tier assignment, matchmaking, talent discovery. |
Ecosystem tier data | Competitive progression display, feature gating, talent pipeline identification. |
Organiser performance data | Reliability score calculation, trust index display, feature eligibility assessment, fraud detection. |
Organiser dashboard usage data | Product improvement, audit trail maintenance, dispute resolution. |
Financial transaction data | Payment processing, prize disbursement, refund processing, PMLA compliance, financial reporting, tax compliance. |
TDS records | Income Tax Department reporting, Form 26AS credit, regulatory compliance. |
Notification data | Delivering transactional communications — room cards, results, prizes, disciplinary notices. |
Firebase analytics data | Product improvement, feature optimisation, platform reliability, engagement analysis. |
Sentry error data | Application stability — identifying and resolving technical errors and crashes. |
Support & dispute data | Resolving player and organiser complaints, dispute adjudication, audit trail maintenance. |
PART XIII — DATA SHARING & THIRD PARTIES
45. Third-Party Service Providers
Third Party | Data Shared | Purpose | Privacy Policy |
Razorpay India Private Limited | KYC-verified bank details, PAN, name, payment transaction data. | Processing entry fee payments, prize disbursements, organiser settlements, TDS reporting. | razorpay.com/privacy |
Authorised eKYC Service Provider (confidential) | Aadhaar number (via UIDAI OTP), PAN, bank account details, user identity. | Digital KYC verification via Aadhaar OTP, PAN verification, bank account verification. | Per eKYC provider's privacy policy |
Google LLC (Firebase) | Anonymised app usage data, device type, OS, crash reports, FCM device tokens. | App analytics, performance monitoring, push notification delivery. | policies.google.com |
Functional Software Inc. (Sentry) | Anonymised error data, device type, OS version, app version, hashed user identifier. | Application error tracking and performance monitoring. | sentry.io/privacy |
Cloud Infrastructure Provider (Render/Neon) | Application logs (anonymised), database backups. | Hosting the Platform's backend API and database. | render.com/privacy |
Apple Inc. (Apple Sign-In) | Apple Sign-In identifier, Apple-provided email. | OAuth authentication for users who sign in with Apple. | apple.com/privacy |
Google LLC (Google OAuth) | Google account email, OAuth token. | OAuth authentication for users who sign in with Google. | policies.google.com |
SMS Service Provider | Phone number (if opted in), SMS message content. | Delivering transactional SMS notifications — only for users who have opted in. | Per SMS provider's privacy policy |
WhatsApp / Meta Platforms | Phone number linked to WhatsApp (if opted in), message content. | Delivering WhatsApp notifications — only for users who have explicitly opted in. | whatsapp.com/legal/privacy-policy |
46. No Sale of Personal Data
The Company does not sell, rent, trade, lease, or otherwise transfer personal data to any third party for commercial, marketing, or advertising purposes. Personal data is shared only with the service providers listed in Section 45 for the specific operational purposes stated, and with government or regulatory authorities where required by law.
Important: If you receive any communication claiming to be from Corpse that asks you to share personal data, payment credentials, OTPs, or account information outside the official Platform — it is fraudulent. Contact support@corpsearena.com immediately.
47. Legal & Regulatory Disclosures
The Company may disclose personal data to government authorities, law enforcement agencies, or regulatory bodies where required by law, court order, or government directive — including under the IT Act 2000, PMLA 2002, Income Tax Act 1961, or any other applicable Indian law. The Company will notify the affected user of any such disclosure to the extent permitted by law.
48. Business Transfers
In the event of a merger, acquisition, restructuring, or asset sale involving the Company, personal data may be transferred to the acquiring or successor entity. Users will be notified at least 30 days before such a transfer takes effect, to the extent permitted by applicable law. The acquiring entity will be required to honour the privacy commitments made in this Policy.
PART XIV — DATA STORAGE & SECURITY
49. Where Data Is Stored
- Backend database — PostgreSQL hosted on Neon's managed cloud database service with automated daily backups and point-in-time recovery.
- Application server — Node.js/Express.js API hosted on Render's managed cloud infrastructure.
- Payment data — processed and stored by Razorpay's PCI-DSS compliant infrastructure.
- KYC data — stored by the authorised eKYC service provider on their regulated infrastructure and by Corpse in encrypted form.
- Analytics data — Firebase Analytics data stored by Google LLC. Sentry error data stored by Functional Software Inc.
All Platform data is stored in India to the extent technically feasible and in compliance with applicable data localisation requirements.
50. Security Measures
- HTTPS — all client-server communication is encrypted over TLS. Plain HTTP is rejected.
- JWT-based authentication — all authenticated API requests carry signed session tokens validated on every request.
- Password-free authentication — the Platform does not store passwords, eliminating password-related data breach risks.
- Encrypted storage — sensitive data including PAN numbers and bank account details are stored in encrypted form.
- Input validation — all API inputs are validated against strict schemas. SQL injection is prevented through Prisma's parameterised query interface.
- Webhook signature verification — all Razorpay payment callbacks are verified using HMAC signature validation before any action is taken.
- Role-based access control — Platform staff access to user data is restricted on a need-to-know basis.
- Secure credential management — all sensitive credentials are stored as environment variables and never committed to source control.
- Session token security — JWT session tokens are stored in iOS Keychain / Android Keystore on device — never in plain local storage.
51. Data Breach Response
In the event of a personal data breach likely to result in a risk to data subjects, the Company will:
- Notify the Data Protection Board of India within 72 hours of becoming aware of the breach, as required under the DPDP Act 2023.
- Notify affected users as soon as reasonably practicable via in-app notification and email, describing the breach, data affected, and steps taken.
- Immediately take all reasonable technical measures to contain the breach.
PART XV — DATA RETENTION PERIODS
52. Retention by Data Category — Full Table
Data Category | Retention Period | Basis for Retention |
Email address | Duration of account + 5 years post-deletion | PMLA 2002 — financial record-keeping |
Username | Duration of account — anonymised post-deletion | Competitive record integrity |
Avatar | Duration of account — deleted on account deletion | No ongoing purpose post-deletion |
Date of birth | Duration of account | Age verification |
Phone number (if collected) | Until user removes it or deletes account | Notification delivery — consent-based |
Session tokens | Until sign-out, expiry, or termination | Authentication necessity |
Device & IP at login | 90 days | Security monitoring |
KYC data (Corpse-held) | 5 years from last financial transaction | PMLA 2002 |
KYC data (eKYC provider-held) | Per eKYC provider's regulatory obligations | Aadhaar Act 2016, PMLA 2002 |
Arena registration records | Duration of account + 2 years post-deletion | Competitive record integrity |
Match results & screenshots | Duration of account + 2 years post-deletion | Competitive record integrity, disputes |
Support & dispute records | 2 years from resolution | Audit and compliance |
Payment transaction records | 5 years from transaction date | PMLA 2002, RBI guidelines |
Prize disbursement records | 5 years from disbursement date | PMLA 2002, Income Tax Act |
TDS records | 7 years from deduction date | Income Tax Act 1961 |
Organiser performance records | Duration of organiser status + 2 years | Audit, dispute resolution, platform integrity |
Organiser GST invoice records | 7 years from invoice date | Income Tax Act 1961, GST Act |
ELO history | Duration of account — anonymised post-deletion | Competitive record integrity |
Guild records | Duration of account — anonymised post-deletion | Competitive record integrity |
FCM tokens | Until sign-out or device change | Notification delivery necessity |
Email communication logs | 2 years | Audit and dispute resolution |
SMS/WhatsApp communication logs | 2 years (if applicable) | Audit and dispute resolution |
Firebase analytics data | Per Firebase/Google Analytics retention settings | Business analytics |
Sentry error data | Per Sentry retention settings | Technical operations |
API error logs | 90 days | Technical operations |
Cross-device session logs | 90 days | Security monitoring |
PART XVI — DATA AFTER ACCOUNT DELETION
53. Data Deleted Immediately
- Avatar image.
- Active session tokens — all devices signed out immediately.
- FCM device tokens — push notification delivery disabled.
- In-game ID registration.
- Active squad and guild memberships — removed immediately.
- Active arena registrations — subject to financial consequences per the Money Deposit & Receive Policy.
- Phone number (if provided) — removed from notification systems.
54. Data Retained After Deletion
- Email address — retained for 5 years per PMLA.
- Username — anonymised and retained for competitive record integrity.
- ELO history and match records — anonymised and retained for competitive record integrity.
- Financial transaction records — retained for 5 years per PMLA.
- TDS records — retained for 7 years per Income Tax Act.
- KYC data — retained for 5 years per PMLA.
- Support and dispute records — retained for 2 years.
- Organiser performance records — retained for 2 years post-deletion.
Note: 'Anonymised' means the retained data is stripped of all directly identifying information and linked only to an internal reference ID that cannot be used to identify the individual without additional information held separately.
55. Financial Data Retention Post-Deletion
Account deletion does not affect the Company's legal obligations to retain financial records. All transaction records are retained for the mandatory periods regardless of account deletion status and may be required for regulatory audit, tax compliance, and legal proceedings.
PART XVII — MINOR USERS — SPECIAL PROTECTIONS
56. Classification & Age Verification
The Platform collects date of birth at registration to classify users as Minor Users (below 18 years) or adult users. Minor Users cannot complete KYC verification, cannot engage in any financial transaction, and can only participate in Arenas as squad members invited by a KYC-verified adult Captain.
57. Data Minimisation for Minors
- No financial data is collected from Minor Users.
- No KYC or in-depth personal identification beyond registration data.
- Minor Users are not shown in financial leaderboards or prize-related features.
58. DPDP Act Parental Consent Framework
- At registration, users below 18 are classified as Minor Users.
- The Platform presents the DPDP Act parental consent requirement and requests confirmation that a parent or legal guardian has approved the registration.
- Minor User accounts are not permitted to engage in any activity involving sensitive personal data processing without adult account oversight.
- Parents or guardians may request access to, correction of, or deletion of their child's account data by contacting legal@corpsearena.comwith proof of guardianship.
PART XVIII — YOUR RIGHTS UNDER THE DPDP ACT 2023
59. Right to Access
You have the right to obtain confirmation as to whether your personal data is being processed, and if so, to access a summary of the personal data held about you. Submit a request to legal@corpsearena.com from your registered email address. The Company will respond within 30 days.
60. Right to Correction
You have the right to request correction of inaccurate or incomplete personal data held about you. For editable profile data, corrections can be made directly in settings. For data requiring support assistance, contact support@corpsearena.com.
61. Right to Erasure
You have the right to request erasure of your personal data — subject to the Company's legal retention obligations described in Part XV. Account deletion is the primary mechanism for exercising this right. Data that must be retained for legal compliance cannot be erased before the mandatory retention period expires.
62. Right to Withdraw Consent
Under Section 6 of the DPDP Act 2023, you have the right to withdraw consent for the processing of your personal data at any time for processing activities that are based on consent. The Company has designed its consent withdrawal mechanism to be as simple as the original consent process.
How to Withdraw Consent:
- WhatsApp notifications — disable in Settings > Notifications > WhatsApp. Withdrawal takes effect immediately.
- SMS notifications — disable in Settings > Notifications > SMS. Withdrawal takes effect immediately.
- Marketing email communications — click the unsubscribe link in any marketing email. Withdrawal takes effect within 48 hours.
- Analytics data collection — contact legal@corpsearena.com to opt out of Firebase Analytics data collection. Note that transactional and security-related data processing is based on contractual necessity or legal obligation and cannot be withdrawn.
Consequences of Consent Withdrawal:
- Withdrawing consent for SMS or WhatsApp notifications — you will no longer receive communications through these channels. Transactional notifications will continue via in-app and email.
- Withdrawing consent for marketing communications — you will no longer receive promotional emails but will continue to receive transactional emails required for Platform operation.
- Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.
- Withdrawing consent for processing that is necessary for Platform operation (contractual necessity or legal obligation) may result in the Company being unable to provide certain services. In such cases, account deletion may be the appropriate course of action.
Important: Consent withdrawal applies only to processing activities based on consent. Processing based on contractual necessity (operating your account), legal obligation (KYC, TDS), or legitimate interests (security monitoring, ELO calculation) continues regardless of consent withdrawal.
63. Right to Grievance Redressal
You have the right to have any grievance related to the processing of your personal data addressed by the Company's Grievance Officer within 30 days. If unsatisfied with the response, you may escalate your complaint to the Data Protection Board of India once established under the DPDP Act 2023.
64. Right to Nominate
Under the DPDP Act 2023, you have the right to nominate another individual to exercise your data rights on your behalf in the event of your death or incapacity. To register a nominee, contactlegal@corpsearena.com with the nominee's details and your relationship to them.
65. How to Exercise Your Rights
Subject Line | DPDP Right Request — [Right Being Exercised] |
Include | Your registered email address, the specific right being exercised, and any supporting information |
Response Timeline | 30 days from receipt of a valid request |
Identity Verification | The Company may request identity verification before processing data rights requests |
PART XIX — COOKIES & LOCAL STORAGE
66. What We Store Locally
The Corpse mobile app stores the following data locally on the user's device:
- Account identifier (non-sensitive) — enabling the app to pre-populate the login screen on return visits.
- UI preferences — notification settings and display preferences configured by the user.
- App state data — locally cached non-sensitive profile data (username, avatar) for faster app load times.
The Platform does not use browser cookies as it is a native mobile application. Local storage is managed by the app's local data management layer.
67. Session Tokens
Authenticated session tokens (JWTs) are stored in the device's secure storage — iOS Keychain or Android Keystore. These tokens are invalidated and deleted on sign-out, expire automatically after 90 days of inactivity, and cannot be used to access account data without a valid, non-expired token.
PART XX — UPDATES TO THIS POLICY
68. How We Notify You of Changes
When a material change is made to this Policy, the Company will send an in-app notification and email to all Registered Users summarising the key changes. The updated Policy is published within the Platform's settings under Legal > Privacy Policy and the 'Last Updated' date is revised.
69. Continued Use & Mandatory Acceptance
Continued use of the Platform following notification of a Policy update constitutes acceptance of the revised Policy — regardless of whether the user has actively reviewed the updated document. This acceptance is mandatory — the Company does not offer an opt-out from updated Privacy Policy terms without account deletion, as the Policy governs necessary data processing for Platform operation.
For material changes that significantly affect user rights — such as changes to data sharing practices or retention periods — the Company will provide a minimum of 14 days notice before the revised Policy takes effect.
PART XXI — GRIEVANCE OFFICER & CONTACT
70. Grievance Officer Details
In accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the Digital Personal Data Protection Act, 2023, the Company has designated a Grievance Officer:
Grievance Officer | [TO BE DESIGNATED — Name to be updated before launch] |
Designation | Grievance Officer — [CORPSE ESPORTS PRIVATE LIMITED] |
Address | Silchar Road Ghat Line, Subashnagar, Karimganj - 788710, Assam, India |
Response Timeline | Acknowledgement within 24 hours. Resolution within 30 days. |
Escalation | Data Protection Board of India — once established under DPDP Act 2023 |
71. How to File a Privacy Complaint
- Step 1 — Email legal@corpsearena.com with subject: PRIVACY COMPLAINT — [Brief Description].
- Step 2 — Include your registered email address, a clear description of the complaint or request, and any supporting evidence.
- Step 3 — The Grievance Officer will acknowledge receipt within 24 hours.
- Step 4 — The Company will investigate and provide a written response within 30 days of acknowledgement.
- Step 5 — If the response does not resolve your complaint satisfactorily, you may escalate to the Data Protection Board of India (once operational under the DPDP Act 2023) or seek other legal remedies available under Indian law.
This Corpse Privacy Policy v2.0 was last updated in April 2026 and is effective from May 1, 2026.
Version 2.0 | Corpse — [CORPSE ESPORTS PRIVATE LIMITED]
This is the single, definitive, and complete privacy policy for the entire Corpse platform.