Please read the "Personal Data and Privacy Protection Policy," "Service Agreement," and "Prohibited Content" below carefully for your protection before confirming your agreement to apply for an account. If you have any questions, please contact us immediately.

VNG SINGAPORE PTE. LTD. TAIWAN BRANCH (hereinafter "VNG," "the Company," "we", "us", or "our") has formulated this "Personal Data and Privacy Protection Policy" (hereinafter the “Privacy Policy” or the “Policy”) statement in regard to your personal data. This statement is designed to inform you about VNG's respect for and protection of your privacy and to provide you with information related to your personal data. To safeguard our members' personal data, privacy, and rights, we inform you in accordance with the provisions of the Personal Data Protection Act before collecting any data.

Regarding VNG’s collection of your personal data, the Policy helps you understand:

1. The name of the Company and the scope of application.
2. The purpose and method of collection.
3. The categories of personal data collected.
4. The time period, territory, recipients, and methods of use of personal data.
5. Your rights and how to exercise them.
6. The impact on your rights if you are unable to provide complete personal data.
7. The security and maintenance measures of personal data.
8. Notification of changes to the content.

I. Scope of Application

The VNG "Privacy Policy" applies to the collection, processing, utilization, international transmission, and protection measures of your personal data when you engage in activities on the VNG website and its affiliated websites, as well as when you download games provided by the Company from the Google Play Store or the App Store. However, it does not apply to websites, web pages, or applications operated by third parties that are linked through the VNG website or applications.

II. Purpose and Method of Collection

The purpose of our data collection is for member marketing, customer management, internal statistical surveys and analysis, member management, de-identification, and other needs that align with our business registration items or articles of incorporation (as specified in the statutory specific purpose item numbers: 040 Marketing, 052 Member Management, 090 Consumer, Customer Management and Service, 157 Investigation, Statistics and Research Analysis, 181 Other Business Operations in accordance with Business Registration or the Articles of Association). The collection methods will be through membership registration, filling out various service forms, or filling out order forms, etc. You may choose whether to provide the data and the completeness of the provided data. However, certain websites or application functions, services, or activities that require the data you provide may not be available if you elect not to provide complete and accurate personal data.

III. Categories of Personal Data Collected

Personal data may be collected by the Company on our website and in our applications includes:

1. Code 001 Identifying Individuals: Such as name, address, phone number, photo, email address, etc.
2. Code 002 Identifying Financial Information: Such as bank account number, etc.
3. Code 003 Identifying Government Information: Such as national ID number, passport number (foreigners), etc.
4. Code 011 Personal Description: Such as age, gender, date of birth, etc.
5. Code 021 Family: Such as marital status, number of children, etc.
6. Code 024 Other Social Relationships: Such as friends, colleagues, etc.
7. Code 035 Recreational Activities and Interests: Such as hobbies, sports, etc.
8. Code 036 Lifestyle: Such as types of consumer goods and details of services used, etc.
9. Code 038 Occupation: Such as driver, school principal, teacher, etc.
10. Code 051 School Records: Such as universities, colleges, etc.
11. Code 064 Work Experience: Such as previous work, military service, etc.
12. Code 132 Unclassified Data, but necessary for providing member services.
13. We use cookies to manage our website and record your activities. Cookies are sent by us to browser directory in your computer and can only be read by our website that set the cookies. You can configure your browser to notify you when cookies are being set or to refuse the setting of cookies.
14. Our website and application management system will record your IP address, browser type, browsing time, and other tracking data. We will store these tracking data in accordance with the Personal Data Protection Depending on the purpose of the services provided by VNG, the following are the types of personal data we may collect and the circumstances in which we may collect them:
• Applying for Membership

When you apply for membership, you will be required to fill out a form with your personal data, including your name, gender, national ID number, address, date of birth, phone number, email address, and other relevant data. You will also need to set up your account password for future login and use of member services.

• Online Transactions

If you choose to use our online transaction services, we will collect the relevant order information you provide, based on the type of online transaction you initiate, to ensure the completion of consumer services such as payment, top-up, and logistics services, etc.

• Online Activities, On-site Activities, and Competitions

If you provide personal data, user name, or password while participating in online activities or online surveys conducted by VNG, such information will also be protected under the Privacy Policy.

• Browsing Web Pages

When you browse or search within a VNG website, its affiliated websites, or a VNG application, the VNG server will automatically record the IP address you use for the connection, the time of access, and other records related to the browsing. These data are used only for statistical analysis of traffic and optimization of network services to improve the quality of VNG's services. These data are used solely for aggregate analysis and will not be linked to specific individuals.

• Social Media Accounts

If you register as a VNG member or log into VNG games or services by using a social media account, we may receive the data you voluntarily provide to the social media service provider according to their policies or your agreement with them. We will manage and use such personal data in accordance with this Policy.

• Others

In addition to the personal data you provide directly, you may also voluntarily provide personal data to VNG's partner companies. With your consent or for the purpose of fulfilling a contractual obligation, your personal data may be provided to VNG. This data will only be utilized and processed within the scope of the services agreed upon or for fulfilling the contract, and will not be used for any other purposes.

IV. Time Period, Territory, Recipients, and Methods of Data Use

1. Time Period

The Company will retain your personal data for the duration of our operations. Unless otherwise provided by law, your personal data will be kept until you cease using the VNG website, its affiliated websites, or VNG application services, or until you request the cessation of use. For participants in events, your personal data will be used from the date of authorization to participate in the event until three (3) months after the event ends. According to tax regulations, personal data of event winners may be retained for up to seven (7) years and shall be destroyed thereafter, without being used for any other purposes.

2. Territory

Taiwan and the areas where services of the VNG website, its affiliated websites, and VNG applications are provided.

3. Recipients

Unless otherwise provided by law, your personal data will be used solely for the purposes you have agreed to and within the relevant scope of VNG's internal use. We will not arbitrarily provide your personal data to other third parties or used such data for other purposes. However, for the purpose of fulfilling contractual obligations, relevant data may be provided to co-organizers or partner companies to perform contractual obligations.

4. Methods

In addition to using members' personal data for VNG's member marketing, customer management, internal statistical surveys and analyses, and membership management, the Company may use the data in the following ways based on your actual needs:

• Member Information

The information you provide when joining membership will be subject to e-mail verification by VNG and will be used to analyze your online and consumer behavior to provide detailed information for members’ needs in the future and serve as a basis for designing member activities. For items delivery: your personal data will be used for the delivery by relevant logistics or postal companies to complete the shipment of items.

• Online Transactions

If you choose to use online transaction services, we will collect the order-related information you provide according to the type of online transaction you initiate, and deliver such information directly to financial institutions during the financial transaction process (such as credit card authorization and bank transfers) to complete the financial transaction, ensuring the completion of consumer services such as payment, top-up, and logistics services.

• Subscription of Electronic Newsletters

When you use the VNG website, its affiliated websites, or VNG application services, you may receive related newsletters. If you wish to unsubscribe, please contact us through the VNG online reporting system.

• Online Events, On-site Events, Competitions & Surveys

The personal data you provide for participating in VNG's online events or online surveys will only be used for that specific event or survey. Such data will be destroyed within a reasonable timeframe after the event or survey concludes.

• Delivery of Virtual Goods and Gifts

When delivering relevant goods, your personal data will be used for the purpose of delivery by the relevant logistics or postal companies.

• Statistics and Analysis

VNG may conduct periodic aggregate member behavior analysis and statistics based on the information you provided when joining as a member and the records generated from server logs or while using VNG application services. Individual behavior analysis will not be conducted.

• Game Marketing Campaigns

The Company will use a member's address, email address, and phone number for the promotion and marketing of the Company’s products or those of partner companies.

• Services

The company will use the data you provide to offer various member services, including facilitating interactions with other members through permitted in-game methods, e.g., notifying you when other members send you messages or post feedback for you.

• In accordance with legal requirements, court orders, requests from regulatory authorities having jurisdiction over the Company, or based on good faith and reasonable necessity, VNG may access, preserve, and disclose your member account information to: (a) comply with legal procedures; (b) execute requests from regulatory authorities having jurisdiction over the Company; (c) perform VNG member system service contracts or this Privacy Policy; (d) respond to any actual or potential claims against the Company or other claims that content on the platform infringing upon third-party rights; (e) respond to your member service requests; or (f) protect the rights, property, or safety of the Company, its members, and/or the public.
• To prevent or investigate any actual or potential violations of VNG member rules, fraud, illegal activities, negligence, or misconduct, and to understand whether such behaviors are related to your use of VNG member services or arise from other relationships between you and us.

V. The Rights and Methods for Members to Exercise Their Personal Data Rights

1. Members who provide personal data to the Company have the rights under the Personal Data Protection Act to:
• Inquire or request access
• Request copies
• Request supplementation or correction
• Request cessation of collection, processing, or use
• Request deletion
2. Limitations on Rights

The above rights may be restricted if you do not comply with VNG's application procedures or if there are legal provisions providing otherwise.

3. Fees

VNG may charge necessary costs/expenses if you request to inquire about, access, or obtain copies of your personal data.

4. Methods to Exercise Your Rights

Members can contact VNG customer service to make their requests. For the application of the aforementioned rights, you should fill out the application form, and VNG may request confirmable identity verification documents. If someone else applies on your behalf, a power of attorney should be provided along with identity verification documents for both the principal and the agent.

5. If you request to cease the collection, processing, or use of your personal data, this may result in the discontinuation of related services being provided to you. We may need to terminate your current relationship and/or contract with us.

VI. Members Should Provide Correct Personal Data

Please ensure that all fields regarding your personal data are filled in accurately. Failure to provide true and complete personal data may impact VNG's ability to communicate with you, complete transactions, provide services, verify identity, or handle consumer transactions and complaints. We recommend that you consistently review and keep your personal data updated at all times. If any harm to you or third party is caused by your incomplete or inaccurate personal data, you will be responsible for all consequences. In case of disputes arising from false information (e.g., identity theft) in the future, VNG may pursue legal action as appropriate. If VNG incurs losses as a result, VNG reserves the right to seek compensation from you.

VII. Security and Maintenance Measures of Personal Data

VNG will adopt appropriate security measures for your personal data in accordance with the Personal Data Protection Act. VNG will make our best efforts to use reasonable technologies and measures to handle security and maintenance matters in accordance with relevant laws and regulations to prevent your personal data from being stolen, tampered with, damaged, lost, or leaked, as well as to avoid any other incidents that may harm member rights. However, inevitably, we cannot guarantee absolute security.

VIII. Self-Protection Measures

1. Please keep your passwords and any personal information secure. Do not share any personal information, especially passwords, with anyone. Avoid using the same password across different games, websites, email accounts, social media, or forums.
2. After completing processes such as making payments, checking emails, or quitting a game, please make sure to log out of your account. If you are using a shared or public computer, make sure to close the browser window to prevent others from accessing your personal information or emails.
3. Avoid opening websites and their attached files from unknown sources; do not install or run programs from unknown sources, or visit plugin websites, forums, etc., to prevent data leakage and avoid the chance of your computer being compromised by trojan programs.
4. Official personnel, event staff, and online game administrators, etc. will never proactively request password information from any players, for any reason. If such a situation is encountered, it should be immediately reported to VNG for handling.

IX. Information Regarding Children

For our website and application services applicable to minors, individuals without legal capacity must have their legal guardians provide consent or refusal regarding the collection, processing, and use of their personal data by the Company's websites and applications. Minors with limited legal capacity must obtain prior permission from their legal guardians before consenting or refusing the collection, processing, and use of their personal data by the Company's websites and applications. We will remove and/or delete any personal data that we believe was submitted by individuals without legal capacity and without consent from their legal guardians, or by minors with limited legal capacity who did not obtain prior permission from their legal guardians.

X. Revising the Privacy Policy

VNG reserves the right to revise the Privacy Policy. Any revisions will be announced on our websites and applications, and all members will be notified via announcement or email. Please pay close attention to such updates to protect your personal rights. By continuing to use the VNG website, its affiliated websites, and application services after any revisions or changes to the Privacy Policy, you indicate that you have read, understood, and agreed to the revised or changed terms. If you do not agree with the Privacy Policy, please discontinue using the VNG website, its affiliated websites, and application services immediately.

XI. Comments and Suggestions

If you have any comments or questions regarding the VNG Privacy Policy or related issues concerning personal data, please contact: Customer Service

XII. The Company reserves the right to revise the member "Personal Data Protection Policy" to comply with changes in relevant laws and regulations.

XIII. Changes to the Content of this Policy

VNG reserves the right to revise this notification at any time. When VNG makes changes to the collection, processing, or use of personal data, we will update the content of this web page.

The Policy will be continuing announced on the VNG website and applications. Members are advised to pay close attention on their own. When the Policy is revised, all members will be notified via announcement or email.

XIV. Additional Terms for EU Members Only

1. These terms apply only to EU citizens and supersede other provisions of the Privacy Policy in case of any discrepancies.
2. Data Portability

You have the right to receive the personal data you provided to us in a structured, commonly used, machine-readable, and interoperable format, and we have the right to transfer it to a third party. If you would like us to transfer the data to a third party, please ensure that you inform the third party in detail and be aware that we can only do so when it is technically feasible. We are not responsible for the security of personal data received or processed by the third party. If providing personal data infringes on the rights of others (e.g., providing your personal data reveals information about others), we may not provide you with personal data related to others.

3. Data Deletion

Under the following circumstances, you may request us to delete your personal data that we hold:

• You believe we no longer need to collect such personal data;
• We are possessing personal data based on your consent, and you wish to withdraw your consent, and we have no other basis to continue possessing the data;
• We are processing the personal data based on our legitimate interests, and you object to such processing. Please provide as much detail as possible about your reasons so we can evaluate if there are overriding legitimate grounds for processing and retaining such personal data;
• You no longer wish us to use the personal data to send you promotional information, special offers, marketing, and sweepstakes activities;
• You believe we are processing the personal data unlawfully.

Please provide detailed reasons for your request to delete the data to ensure you have a valid basis for the deletion ruest. However, this will not apply if we have valid legal grounds to process such data, such as defending legal rights or freedom of speech. We will notify you if such exceptions occur. Please note that deleting personal data may result in us being unable to provide you with the same level of service or may require us to terminate our services to you.

4. Retention of Personal Data

When we need to provide services or products to you, or as required or permitted by applicable laws (such as tax and accounting laws), we will retain your personal data. If you request the deletion of your personal data according to Subparagraph 3 of this clause and we determine that the request is valid, we will make our best efforts to delete your personal data within thirty (30) days of the request, or notify you of an updated deletion time if the deletion time is about to exceed thirty (30) days, except as otherwise provided by the Policy or applicable laws.

5. Refusal to Profile Creation and Targeted Marketing

You have the right to refuse our processing of your personal data at any time, such as for sending promotional information, special offers, and marketing activities, including any personal data profiles we have created for this purpose. Once you submit a refuse request, we will cease processing your personal data for the aforementioned purposes. Please provide as much detail as possible regarding your reasons for refusal to our processing of your personal data to help us determine whether you have the right to refuse. However, this will not apply if we are legally required to retain your personal data.

6. Processing Restrictions on Data Storage

You have the right to request that we restrict the processing of your personal data under the following circumstances:

• You believe the personal data is incorrect. During such time, we need to verify the accuracy of the personal data;
• We wish to delete the personal data, but you wish us to retain it;
• We no longer need the personal data and wish to delete it, but you need access to it to establish, exercise, or defend a legal claim;
• You object to our processing of the personal data based on our legitimate interests, and you want us to stop processing such personal data regardless if we have overriding legitimate grounds to continue processing and retaining such personal data.
7. Transferring Personal Data Outside of EU

In accordance with this clause, your personal data may be transferred outside the EU. We will take appropriate measures to ensure that the recipient of your personal data is obliged to maintain confidentiality. We will implement appropriate contractual clauses and other measures to ensure that the recipient of such transfer will protect and process your personal data in accordance with all applicable personal data protection laws.

Last updated on: July 2024.