Terms of Service & User Agreement | Spin Rummy® Sovereign Charter

1. Statutory Charter, Parties to Contract & Acceptance of Terms

This digital document is an electronic record generated by an electronic system and does not require physical or digital handwritten signatures. By downloading the official mobile application, registering a player account, visiting the website, depositing funds, or joining any skill contest on Spin Rummy Club, you enter into a binding contractual relationship under our Terms of Service & User Agreement. If you do not agree to every covenant codified within this User Agreement and our Terms of Service, you are strictly prohibited from accessing our cardrooms, and you must terminate your session and uninstall our application immediately.

The contractual parties to this Spin Rummy Terms of Service agreement are:

• The Service Provider: Spin Rummy Interactive Labs Ltd., an incorporated technology enterprise having its registered corporate headquarters at Level 8, Sovereign Tower, G-Block, Bandra Kurla Complex (BKC), Mumbai, Maharashtra – 400051, India (hereinafter designated as “Company”, “We”, “Us”, or “Spin Rummy Club”). Detailed corporate governance credentials are documented on our About Us page.
• The Service User: Any natural person who accesses our software, creates a player account, verifies electronic KYC, or participates in real-money or free practice 13-card rummy contests (hereinafter designated as “User”, “Player”, “Contestant”, or “You”).

This Terms & Conditions document incorporates by reference our Privacy & Security Policy, our Refund & Withdrawal Policy, our Responsible Gaming Policy, and our Supreme Court Legality Guide. Together, these documents constitute the complete, integrated Master Service Agreement between the parties under our Terms of Service.

2. Player Eligibility, 18+ Age Verification & Territorial Jurisdiction

Participation in the real-money skill gaming cardrooms of Spin Rummy Club is strictly conditional upon satisfying comprehensive statutory eligibility requirements. Under our Terms of Service & User Agreement, you represent, warrant, and covenant that you possess the full legal capacity to enter into an enforceable contract.

Statutory Age of Majority Mandate (18+ Only)

Real-money contests hosted on our platform are restricted exclusively to natural persons who have achieved at least eighteen (18) completed years of age on the date of account registration. Under Section 11 of the Indian Contract Act, 1872, agreements entered into by minors are void ab initio. Our Spin Rummy Terms of Service enforce strict electronic age verification before allowing any cash deposits or real-money table entries. Minors attempting to register using falsified credentials will face immediate account termination, forfeiture of winnings, and legal reporting, as detailed in our Responsible Gaming Policy.

Territorial State Jurisdiction & Geofenced Exclusion

While the Supreme Court of India in landmark rulings (*State of Andhra Pradesh v. K. Satyanarayana [1968]* and *KR Lakshmanan v. State of Tamil Nadu [1996]*) has firmly established that 13-card Indian Rummy is predominantly a game of skill protected under Article 19(1)(g) of the Constitution of India, specific states within the Union have enacted local legislation prohibiting real-money online games regardless of skill. Under this Terms of Service & User Agreement, residents of restricted states are legally barred from participating in cash contests:

Any attempt by a user located in a restricted territory to circumvent platform geofences using Virtual Private Networks (VPNs), proxy servers, fake GPS applications, or remote desktop software represents a material breach of this User Agreement and our Terms & Conditions, resulting in immediate account freezing and permanent forfeiture of balances under our Terms of Service.

3. Single Account Policy, KYC Authentication & Multi-Accounting Prohibition

Platform integrity begins with absolute player accountability. Under our Terms of Service & User Agreement, each registered individual is strictly entitled to establish, maintain, and operate exactly one (1) verified account on Spin Rummy Club.

PLAYER ACCOUNT LIFECYCLE & REGULATORY COMPLIANCE ARCHITECTURE

KYC & ESCROW AUDITED

Mandatory Electronic KYC (Know Your Customer)

In compliance with guidelines issued by the Reserve Bank of India (RBI), the Prevention of Money Laundering Act, 2002 (PMLA), and Ministry of Finance directives, all users must complete two-factor electronic identity verification:

• NSDL PAN Verification: Direct integration with the National Securities Depository Limited (NSDL) database to authenticate full legal name, date of birth, and Permanent Account Number for Section 194BA income tax withholding.
• UIDAI Aadhaar Verification: Real-time Aadhaar OTP verification or secure DigiLocker integration to validate permanent residential address, state of residence, and adult age status under our Terms of Service.
• Verified Bank Account & UPI VPA: Withdrawals are permitted exclusively to bank accounts or UPI IDs where the beneficiary name matches the verified PAN card with 100% lexical precision. Third-party bank accounts are strictly rejected.

Strict Prohibition of Multi-Accounting & Ghost Profiles

Operating multiple accounts under aliases, utilizing identity credentials belonging to family members or associates, or registering disposable accounts to exploit welcome promotions is categorized as severe platform fraud under our Spin Rummy Terms of Service. Our automated identity graph algorithms actively cross-reference hardware UUIDs, SIM IMSI numbers, IP subnets, and financial transaction fingerprints. If duplicate accounts are discovered:

• All duplicate and secondary profiles are instantly and permanently deactivated.
• All accumulated winnings, promotional credits, and referral commissions are completely voided.
• The primary user is barred from participating in sovereign leaderboards and tournament prize pools under our User Agreement.

4. Device Integrity, Hardware Fingerprinting, Emulators & Bot Prohibitions

Spin Rummy Club provides a peer-to-peer cardroom engineered exclusively for human competitors using authentic physical devices. Our Terms of Service & User Agreement expressly forbid any form of automated gameplay, external assistance software, or system virtualization.

Banned Technical Environments & Software Vectors

The installation, execution, or connection of the following software tools while accessing Spin Rummy Club constitutes an irremediable breach of our Terms & Conditions:

• Android Emulators & Virtual Machines: Utilizing BlueStacks, LDPlayer, Nox, Genymotion, or custom QEMU/KVM virtualized environments to execute the mobile application on desktop computing hardware.
• Autonomous Bots & AI Engines: Deploying algorithmic card-counting bots, heuristic decision engines, automated decision-making scripts, or macro clickers to execute table actions.
• Memory Invalidation & Packet Sniffing: Utilizing Cheat Engine, Frida, GameGuardian, Wireshark, or man-in-the-middle (MITM) proxies to inspect network packets, decrypt TLS streams, or alter client-side memory pointers.
• Screen Scrapers & Odds Calculators: Employing optical character recognition (OCR) overlays or background telemetry scripts designed to calculate opponent discard probabilities in real time.
• Jailbroken & Rooted Environments: Devices exhibiting system-level Magisk, SuperSU, or Substrate hooks that circumvent platform security integrity checks.

Our client application incorporates proprietary security daemons that generate cryptographic hardware attestations. Any detection of virtualized environments or memory tampering results in immediate session disconnection and account blacklisting under our Terms of Service.

5. Table Conduct, Anti-Collusion Engine & Fair Play Guardrails

Indian Rummy is a test of strategic foresight, memory, card mathematics, and psychological fortitude. To preserve the purity of every hand, our Spin Rummy Terms of Service establish uncompromising fair play standards overseen by our real-time Anti-Collusion Telemetry Engine.

Victims of collusive activity are protected under our Fair Play Restitution Protocol. Upon verification of collusion by our security panel, affected innocent players receive a 100% refund of their table entry fees, funded directly from the seized balances of the infringing accounts, in strict alignment with our Terms of Service & User Agreement.

6. Financial Ledger: Real-Money Deposits, Escrow Security & Wallet Architecture

Spin Rummy Club operates a world-class financial ledger system engineered with institutional-grade security. All monetary transactions are processed in Indian Rupees (INR) through RBI-authorized payment aggregators (including Cashfree, Razorpay, and PayU) under our Terms of Service & User Agreement.

Segregated RBI Escrow Protection

In strict accordance with RBI guidelines and Ministry of Corporate Affairs norms, player funds are never commingled with the operational working capital of Spin Rummy Interactive Labs Ltd. 100% of user balances are held in a segregated, interest-free Escrow Account maintained with a leading scheduled commercial bank in India. This guarantees that your funds remain untouchable, fully liquid, and available for instantaneous settlement 24 hours a day, 365 days a year, as affirmed under our Spin Rummy Terms of Service.

Tripartite Wallet Structure

Your user ledger is segmented into three distinct financial compartments under our Terms of Service:

• Unutilized Deposit Wallet: Contains real cash deposited through UPI, net banking, or debit/credit cards that has not yet been wagered in cash contests. These funds can be utilized for table entry fees or refunded back to the original funding source in compliance with our Refund & Withdrawal Policy.
• Winnings Wallet: Contains net earnings accrued from successfully winning cash tables or tournament prize pools. Balances in this compartment are 100% withdrawable to your verified bank account at any time, subject to statutory Section 194BA TDS calculations.
• Promotional Bonus Wallet: Contains non-withdrawable promotional game credits granted through bonus codes, VIP rewards, or loyalty programs. Bonus credits are released into your cash wallet incrementally as you participate in real-money contests, pursuant to specific promotional rules under our User Agreement.

7. Winnings Settlement, Payout SLAs & In-Game Auto-Drop Shield

Settlement integrity is the hallmark of our cardroom. At the conclusion of every 13-card rummy deal, the game engine automatically validates all declared melds, pure sequences, and second sequences against our certified RNG rules. Winnings are credited to the victor’s Winnings Wallet instantaneously under our Terms of Service & User Agreement.

Instant 60-Second Cashout SLAs

We recognize that prompt access to your winnings is a fundamental right. Spin Rummy Club maintains a 60-second automated payout engine integrated directly with the National Payments Corporation of India (NPCI) Immediate Payment Service (IMPS) and Unified Payments Interface (UPI) networks:

• Minimum Withdrawal Ceiling: The minimum withdrawable threshold is set at a player-friendly ₹100 per transaction under our Terms of Service.
• Zero Platform Processing Fees: Spin Rummy Club levies 0% handling fees on standard bank withdrawals. The full approved amount is disbursed directly to your account.
• Automated Execution: 99.4% of eligible withdrawal requests are approved and wired within 60 seconds without manual administrative friction, as guaranteed in our Spin Rummy Terms of Service.

In-Game Auto-Drop Shield for Technical Failures

In the event that a player suffers an unexpected cellular network drop, incoming telephone interruption, or hardware crash during an active cash deal:

• The system activates the Auto-Drop Shield, automatically saving the player’s position and attempting reconnection for the duration of the turn timer.
• If reconnection fails, the engine executes a strategic First Drop (20 points in 101/201 Pool Rummy) rather than penalizing the user with a Full Drop (80 points), minimizing financial exposure under our Terms & Conditions.

8. Statutory Taxation: Section 194BA Net Winnings TDS & 28% GST Rules

Spin Rummy Club operates in strict compliance with the statutory tax laws of the Republic of India. Participation in real-money skill gaming contests is subject to direct and indirect tax withholding mandated by the Ministry of Finance and the Central Board of Direct Taxes (CBDT) under our Terms of Service & User Agreement.

Direct Taxation: Section 194BA Net Winnings TDS (30%)

Effective April 1, 2023, the Finance Act, 2023 introduced Section 194BA to the Income Tax Act, 1961, governing tax deducted at source (TDS) on net winnings from online games. Key principles enforced under our Terms of Service include:

• 30% Flat Withholding Rate: Tax is deducted at a statutory rate of 30% (plus applicable surcharge and cess) exclusively on Net Winnings upon withdrawal or at the fiscal year-end (March 31).
• Statutory Net Winnings Formula: Pursuant to CBDT Rule 133, Net Winnings are computed as:
  Net Winnings = Total Withdrawals – (Total Deposits + Opening Ledger Balance + Prior TDS Deducted Winnings)
• Zero Tax on Deposits or Principal Capital: If you withdraw an amount less than or equal to your cumulative unutilized deposits, your net winnings are zero, and no TDS is deducted under our User Agreement.
• Official Form 16A Issuance: Every rupee deducted under Section 194BA is deposited directly with the Government of India against your verified PAN. Quarterly digitally signed Form 16A certificates are generated and delivered directly to your registered email address, enabling you to claim full credit when filing your annual Income Tax Return (ITR).

Indirect Taxation: 28% Full Nominal Value GST Compliance

Pursuant to the Central Goods and Services Tax (Amendment) Act, 2023 and notifications issued under Rule 31A of the CGST Rules, Goods and Services Tax (GST) is levied at 28% on the full value of cash deposited by a player into their gaming wallet. Spin Rummy Club remits 100% of collected GST directly to the GST Network (GSTN) under valid sovereign tax invoices provided with every top-up under our Terms & Conditions.

9. Bonus Credits, Promotional Currency & Wagering Requirements

Spin Rummy Club may, from time to time, distribute promotional bonus credits, referral rewards, deposit match incentives, or VIP cashback under our Terms of Service & User Agreement. All promotional allocations are governed by strict contractual stipulations designed to preserve game economy integrity.

Non-Cashable Nature & Incremental Release Mechanism

Promotional bonus balances do not constitute legal tender, bank deposits, or cashable securities. Bonus credits cannot be directly withdrawn to bank accounts or transferred between player accounts under our Spin Rummy Terms of Service. Instead:

• Bonus credits are released into your real-money cash balance incrementally as you participate in cash tables (typically at a rate of 10% of table rake contributions per deal).
• Bonus credits carry an expiration timeline (default: 30 days from issuance, unless specified otherwise in specific tournament rules). Expired bonus balances are automatically reclaimed by the platform.
• Spin Rummy Club reserves the absolute right to audit, suspend, or revoke bonus credits if abusive promotion exploitation, referral fraud, or sybil account creation is detected under our User Agreement.

10. Intellectual Property Rights, Software Licensing & Anti-Decompilation

The complete software architecture, server game engine, visual art assets, UI/UX designs, animations, sound effects, trademarks, logos, and proprietary code bases associated with Spin Rummy Club are the exclusive intellectual property of Spin Rummy Interactive Labs Ltd., protected under the Indian Copyright Act, 1957, the Trade Marks Act, 1999, and international intellectual property conventions under our Terms of Service & User Agreement.

Limited, Revocable End-User License

Subject to your ongoing compliance with this User Agreement and our Terms of Service, the Company grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to download, install, and execute the mobile client application solely for personal, non-commercial entertainment purposes on compatible hardware.

Strict Prohibition of Reverse-Engineering

Under this Terms of Service & User Agreement, you agree that you shall not:

• Decompile, reverse-engineer, disassemble, or attempt to derive the underlying source code of our Android APK, iOS package, or server APIs.
• Modify, adapt, translate, or create derivative works based upon the platform software or visual assets.
• Rent, lease, lend, sell, redistribute, or sublicense access to the platform software.
• Remove, obscure, or alter any copyright notices, trademark symbols, or proprietary legal legends embedded within the client application.

Any violation of our intellectual property rights will be prosecuted to the fullest extent of civil and criminal law under the Copyright Act, 1957 and Section 66 of the Information Technology Act, 2000, as enforced by our Terms & Conditions.

11. Service Availability, Network Disconnections & Force Majeure Handling

Spin Rummy Club utilizes enterprise-grade cloud server infrastructure hosted in high-availability Tier-4 data centers with automated multi-zone failover. However, online gaming across distributed cellular networks involves external technical variables beyond the platform’s direct control under our Terms of Service & User Agreement.

Platform Service Level Commitments (SLAs)

We strive to maintain a 99.98% platform uptime standard. Scheduled maintenance windows requiring temporary lobby closures are broadcast through in-app alerts at least 24 hours in advance, typically during non-peak early morning hours, in alignment with our Spin Rummy Terms of Service.

Force Majeure & Server Failure Restitution Policy

The Company shall not be held liable for failure or delay in software performance resulting from acts of God, natural catastrophes, war, cyber warfare, distributed denial of service (DDoS) attacks, regional fiber cuts, failure of public telecommunications networks, power grid collapses, or government regulatory shutdowns (Force Majeure events).

If a verified platform-wide server crash or infrastructure failure interrupts an ongoing real-money cash table or tournament:

• All active tables are immediately frozen by the master server monitor.
• Table entry fees for interrupted deals are refunded 100% back to each participating player’s cash balance within 60 minutes.
• Tournament prize pools are redistributed equitably among surviving non-eliminated contestants based on their chip proportions at the moment of system interruption under our Terms of Service.

12. Account Termination, Voluntary Self-Exclusion & Disciplinary Freezes

Maintaining a secure, ethical, and transparent gaming arena requires clear procedures for account termination, disciplinary suspensions, and voluntary retirement under our Terms of Service & User Agreement.

Voluntary Account Closure & Self-Exclusion

You retain the absolute right to terminate your account or activate voluntary self-exclusion at any time. Under our comprehensive Responsible Gaming Policy, players may select from short timeouts (24 hours to 7 days) up to permanent lifetime exclusion. Upon permanent account closure, all unutilized cash deposits and verified net winnings are settled and wired to your registered bank account via NPCI IMPS within 24 hours under our Terms of Service.

Company Termination for Material Breach

Spin Rummy Club reserves the unilateral right to suspend, freeze, or permanently terminate any player account immediately and without prior notice upon the occurrence of any of the following material breaches under our User Agreement and Terms & Conditions:

• Submitting fraudulent, forged, or stolen PAN / Aadhaar identity documentation.
• Colluding with other players, dumping chips, or participating in soft play at cash tables.
• Executing automated bots, scripts, screen-scrapers, or running the game inside desktop emulators.
• Attempting to exploit software defects, system glitches, or memory leaks for unjust financial gain.
• Disgorging chargeback disputes or payment gateway reversals after consuming cash table services.
• Harassing, threatening, or defaming other players or platform customer support representatives.

13. Dispute Resolution, Arbitration & Exclusive Mumbai Jurisdiction

Spin Rummy Club believes in transparent, equitable, and expeditious dispute resolution. All disputes, controversies, or claims arising out of or relating to this Terms of Service & User Agreement, including its breach, validity, or termination, shall be resolved exclusively through the structured mechanism codified herein under our Terms of Service.

MULTI-TIER DISPUTE RESOLUTION & ARBITRATION MATRIX

MUMBAI JURISDICTION

Informal Grievance Escalation Procedure

Before initiating formal arbitration, you agree to submit a detailed written statement of your grievance directly to our Nodal Grievance Redressal Officer at grievance@spinrummy.club. In compliance with Rule 3(2) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021:

• Our Grievance Desk will acknowledge receipt of your complaint within twenty-four (24) business hours.
• The Nodal Grievance Officer will conduct a thorough evidentiary investigation and deliver a formal written resolution within fifteen (15) calendar days.

Binding Arbitration under Arbitration and Conciliation Act, 1996

If a dispute cannot be amicably resolved through informal grievance redressal within thirty (30) days, the matter shall be referred to and finally settled by binding arbitration in accordance with the Arbitration and Conciliation Act, 1996 (as amended). The arbitration protocol governed by our Spin Rummy Terms of Service establishes that:

• The arbitral tribunal shall consist of a sole independent arbitrator appointed mutually by the parties (or appointed in accordance with the High Court of Bombay if agreement is not reached).
• The seat and legal venue of arbitration shall be Mumbai, Maharashtra, India.
• The arbitral proceedings shall be conducted in the English language.
• The arbitral award shall be final, conclusive, and binding upon both parties, enforceable in any court of competent jurisdiction.

Exclusive Judicial Jurisdiction & Governing Law

This Terms of Service & User Agreement shall be construed, interpreted, and governed exclusively in accordance with the substantive laws of the Republic of India. Subject to the arbitration agreement above, the civil courts located in Mumbai, Maharashtra shall possess exclusive territorial and subject-matter jurisdiction over any judicial proceedings arising hereunder under our Terms & Conditions.

14. Frequently Asked Agreement Questions (FAQs)