PROG Act 2025 & Online Games Rules 2026 Compliance Policy

SECTION 1 — REGULATORY FRAMEWORK

SECTION 2 — SEEKHOBECHO CLASSIFICATION & STATUTORY POSITION

Under PROG Act 2025, online games are classified into three categories. SeekhoBecho falls strictly within the "Online Social Games" category — fully legal, regulated, and operational.

SECTION 3 — THREE-CATEGORY CLASSIFICATION DETAILED

SECTION 4 — ONLINE MONEY GAMES BAN — STRICT NON-EXPOSURE

PROG Act 2025 Section 4 explicitly prohibits the offering, operation, advertising, promotion, or facilitation of Online Money Games to persons in India. Penalties include severe fines (up to INR 1 crore for each violation), imprisonment up to 3 years for repeat offenders, and platform/app blocking.

Specific non-exposure safeguards:

• Pearls have NO cash conversion mechanism — never have, never will
• No Pearl-to-bank-transfer feature, no Pearl-to-UPI feature, no Pearl-to-wallet feature
• Pearls earned from gaming or contests cannot be converted to cash through ANY mechanism — direct or indirect
• MahaJackpot entry is activity-based only (subscription, level progression, streaks) — NOT paid Pearl entry per Memory Rules
• 1v1 Skill Challenge "Entry: 500 Pearls / Winner Prize: 800 Pearls" — language carefully chosen to avoid stake/winnings money-game terminology
• Promotional cash prizes (Selling League INR 50K, Vyapar Championship INR 5L) sourced from subscription revenue, NOT from user-paid Pearl pool — Consumer Protection Act 2019 promotional contests
• No "match-fixing", no "real-money fantasy sport", no "betting odds" elements
• No prediction-market features tied to financial outcomes
• No cryptocurrency / token economy elements
• Marketing copy explicitly avoids "Earn Money", "Income Guaranteed", "Win Cash" language per memory rules
• Internal compliance review of any new gaming feature before launch — Founder + Legal sign-off mandatory
• External legal opinion obtained annually confirming non-Money-Game positioning
• Disclosures across all user-facing surfaces clarifying Pearl status

SECTION 5 — OGAI REGULATOR COORDINATION

SECTION 6 — MANDATORY USER DISCLOSURES

Online Games Rules 2026 mandate specific disclosures to users — SeekhoBecho operationalises these across in-app surfaces, T&C, Privacy Policy, and individual game rules.

SECTION 7 — PLAYER PROTECTION MEASURES

Online Games Rules 2026 require platforms to implement player protection measures — even for non-money games, given engagement and addiction concerns.

• Self-Exclusion Tools: Users may self-exclude for 24 hours / 7 days / 30 days / permanent — Settings → Responsible Gaming. Exclusion is immediately effective; cannot be reversed during exclusion period.
• Time Limits: Daily play-time limits user-settable (default suggested: 2 hours/day); platform enforces with hard stop and re-entry only next calendar day.
• Spending Limits: Monthly Pearl Recharge limits user-settable; default suggested cap of INR 5,000/month for entry-level users; limit can be increased only with 48-hour cooling-off period.
• Reality Checks: In-app reminders every 60 minutes of continuous play: "You've been playing for 1 hour. Take a break?" + visible session-time counter.
• Loss Streak Protection: If user loses 5+ consecutive 1v1 Skill Challenges in a single session, system prompts a "Take a break" message and offers 30-min cool-down.
• Underage Strict Exclusion: Policy 138.0 — under-18 strictly excluded; KYC verification at signup; suspected underage accounts immediately frozen pending verification.
• Vulnerable User Indicators: Trust & Safety team trained to identify behavioural patterns suggesting problematic engagement; outreach with help resources.
• Help Resources: In-app links to recognised behavioural health resources (NIMHANS helpline, iCALL, Vandrevala Foundation); discrete access without stigma.
• Periodic User Wellbeing Surveys: Anonymous user surveys quarterly to assess platform impact on user wellbeing.
• No Targeting of Vulnerable Users: Marketing automation excludes users showing problematic-engagement signals from upsell campaigns.
• Cool-Down Periods: After significant loss events or extended sessions, system-suggested cool-down breaks.
• Family Account Linking (Future): Optional family-account oversight feature for users who consent to family-member monitoring.

SECTION 8 — KYC & AGE VERIFICATION

SECTION 9 — SKILL-BASED GAME DEFENCE & SUBSTANTIATION

While SeekhoBecho's Online Social Games classification (Pearls non-convertible) provides the primary statutory defence, skill-based positioning provides secondary defence under the Public Gambling Act 1867 and Supreme Court jurisprudence.

• Each game on SeekhoBecho substantiated as skill-based — outcome materially determined by user skill, knowledge, timing, strategy, engagement
• Supreme Court jurisprudence: K.R. Lakshmanan v. State of Tamil Nadu (1996) — games of skill protected from gambling characterisation
• State High Court rulings recognising rummy, fantasy sports, certain card games as skill-predominant
• SeekhoBecho's specific games designed and documented as skill-predominant per Policy 17.0
• Game design documentation maintained showing skill-element analysis for each game
• External legal opinion on skill-classification for each material game category
• RNG (Random Number Generator) elements minimised; where present, RNG audited by certified labs
• Tournament structure analysed for skill-determinant brackets (better players consistently rank higher)
• Player skill ratings, leaderboards, certificate tiers (Silver/Gold/Platinum/Elite) demonstrate skill-progression
• Knowledge Quiz League course-linked, demonstrating educational/skill nature
• Annual skill-game audit by independent expert (statistical analysis of player performance distribution)
• State-level legal compliance monitored — some states (Telangana, Andhra Pradesh, Tamil Nadu, Karnataka) have additional restrictions even on skill games; SeekhoBecho operates within state-specific limits where applicable

SECTION 10 — GRIEVANCE & REPORTING MECHANISMS

SECTION 11 — AUDIT & RECORD-KEEPING

• Game logs: All game-play events logged — start, in-game decisions, outcomes, time stamps; retained 3 years
• Transaction logs: All Pearl Recharge, Earn, Spend, Redemption events logged with transaction IDs; retained 7 years per Income Tax + GST requirements
• KYC records: Aadhaar verification logs, PAN match logs, video KYC frames (90 days raw; verification decision permanent); retained per DPDP Act 2023
• Grievance logs: All user complaints, internal tickets, resolutions; retained 7 years
• Investigation logs: PI-01, PI-02, PI-03, PI-04, PI-05 investigation records; 7 years
• Audit trail of game design changes — version control of game rules, mechanics, payout structures
• Annual independent audit by certified gaming/regulatory auditor — covers compliance, financials, player protection, technical fairness
• External legal opinion annually — confirming PROG Act 2025 + Online Games Rules 2026 compliance and Pearl non-convertibility
• OGAI inspection cooperation — documents production on lawful request
• Trade secret protection — sensitive game-design IP protected; sanitised documents shared with regulators where permitted
• System security audits — annual penetration testing + DPDP-aligned security review
• Backup & disaster recovery — encrypted off-site backups; tested annually

SECTION 12 — PENALTIES & ENFORCEMENT EXPOSURE

SECTION 13 — GOVERNING LAW & GENERAL PROVISIONS

• Governing Law: Laws of India — primarily PROG Act 2025, Online Games Rules 2026
• Coordination with Other Statutes: DPDP Act 2023, IT Act 2000, IT Rules 2021, Consumer Protection Act 2019, BNS 2023, RBI PSS Act 2007, Aadhaar Act 2016, CGST Act 2017, Income Tax Act 1961
• Jurisdiction: Courts of Gurugram, Haryana — exclusive (subject to OGAI / Tribunal jurisdiction for regulator-specific matters)
• Modifications: This Policy may be modified at any time to reflect regulatory developments; published with effective date
• Severability: Invalid provisions severable; remainder survives
• Survival: Compliance obligations survive user account termination; data retention obligations continue per statutory timelines
• Coordination Policies: REG-01 (Master Regulatory), REG-03 (DPDP), REG-04 (IT Act/IT Rules), Policies 17.0-23.0 (Gaming Master), Policies 105.0 (Regulatory Compliance Policy), 140.0 (OGAI Registration Disclosure)
• Founder + Legal Sign-Off: Required for all material PROG Act-related decisions
• External Counsel: Annual specialist review by online-gaming / regulatory counsel
• Training: Internal personnel trained on PROG Act 2025 + Online Games Rules 2026 implications

Contact: support@seekhobecho.com | compliance@seekhobecho.com | grievance@seekhobecho.com | privacy@seekhobecho.com | Legal Basis: PROG Act 2025, Online Games Rules 2026, DPDP Act 2023, IT Act 2000, IT Rules 2021, Consumer Protection Act 2019, BNS 2023, RBI Payment & Settlement Systems Act 2007, Aadhaar Act 2016, Public Gambling Act 1867, CGST Act 2017, Income Tax Act 1961, Indian Contract Act 1872, Arbitration & Conciliation Act 1996 | Arbitration Seat: Gurugram, Haryana