Privacy Policy

1. INTRODUCTION

This Privacy Policy (“Policy”) explains how VNG CORPORATION and its subsidiaries, affiliates and related corporations, including VNG Singapore Pte. Ltd. (individually and collectively referred to as "VNG", “We”, “us”, "our" or the “Company”) manages your personal data in compliance with the applicable laws and regulations, including the Personal Data Protection Act 2012 of the Republic of Singapore (the “PDPA”).VNG takes its responsibilities relating to information security under applicable data privacy laws and regulations on personal data protection seriously and is committed to respecting the privacy rights and concerns of all users regarding our Services. VNG acknowledges the importance of the personal data that you have entrusted to VNG and believes that it is VNG’s responsibility to properly manage, protect and process your personal data. This privacy policy (“Privacy Policy” or “Policy”) is designed to help you understand how VNG processes the personal data that you have provided to VNG and to assist you in making an informed decision before providing us with any of your personal data. This Privacy Policy shall be considered a notice of personal data processing, which was provided to you before we collect or process any of your Personal Data. This Privacy Policy is also designed to assist our users who live in Singapore or the European Union (the “EU”) to understand their applicable data privacy rights when they use our Services.
“Service” or “Services”: means our VNG’s online games (“Games”), and/or websites (the “Site”), and/or any products or services provided by VNG.
“Personal Data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Such Personal Data may be in the form of symbols, letters, numbers, images, sounds or any similar electronic environment that is associated with you or helps to identify you. You provide the Personal Data to us and thus are responsible for the accuracy of this Personal Data.
“Process Personal Data” means one or more activities that affect your Personal Data, such as collection, recording, analysis, confirmation, storage, correction, disclosure, aggregation, retrieval access, retrieve, revoke, encrypt, decrypt, copy, share, transmit, provide, transfer, delete, destroy, disclose (including to third parties) Personal Data or other related actions which are specified in this Policy.
Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
By clicking the “tick” on the box agreeing to this Privacy Policy before using the Services, registering for an account with VNG (“Account”) or accessing the Site, you acknowledge and agree that you have read, understood, and agree with the provisions of this Policy and that you accept all methods, requirements, and/or policies described in this Privacy Policy, and you hereby agree to allow VNG to Process Personal Data which you have provided to VNG as described in this Privacy Policy.
IF YOU DO NOT CONSENT TO VNG'S COLLECTION AND PROCESSING OF CERTAIN PERSONAL DATA WHICH ARE REASONABLY REQUIRED TO PROVIDE YOU WITH OUR SERVICES (INCLUDING ACCESS TO OUR GAMES), PLEASE DO NOT ATTEMPT TO ACCESS OR OBTAIN SERVICES FROM VNG.
We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Any revisions or changes shall become effective from the time the revised Policy is made available for your access on the Site, inside our Games and/or our Services. Your continued maintaining of your VNG account, use of our Services, or your continued employment or engagement with us constitutes your acknowledgement and acceptance of such changes.
This Policy applies in conjunction with other notices, contractual clauses, and content clauses that apply in relation to the collection, storage, use, disclosure, and/or processing of your Personal Data by VNG. This Policy will not override any of those documents/clauses/notices unless otherwise specified by VNG.

2. WHEN SHALL VNG COLLECT PERSONAL DATA?

We generally collect your personal data where it is voluntarily provided to us by you directly after you have been notified of the purposes for which the data is collected and you have provided written consent to the collection and usage of your personal data for these purposes, or where the collection and use of personal data without consent is permitted or required by the PDPA or other laws. In the event that we are collecting any additional personal data for a purpose which has not been notified to you, we shall seek your consent before doing so (except where permitted or authorized by law).

We will/may collect your Personal Data:

when you register for and/or use our Services, Games or Site, or register an Account with us;
when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
when you submit any bug reports or system metrics as part of a troubleshooting process;
when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when you contact with our customer service personnel;
when you use our electronic services, or interact with us via our Games, Site or use our Services. This includes, without limitation, Cookies which we may deploy when You interact with our Games or Site or our Services;
when you link your account with your Social Media Account (defined below) or other external account or use other social media features, in accordance with the provider’s policies;
when you carry out transactions through our Games or Site;
when you provide us with feedback or complaints;
when you register for a contest, for games, events and/or Games-related promotional programs and our Services;
during your gameplay, using VNG’s Sites and Services; and
when you submit your Personal Data to us for any reason.

The above circumstances only set out some common instances of when your personal data may be collected or provided to us by you and is not an exhaustive list.

3. WHAT PERSONAL DATA SHALL VNG COLLECT?

The Personal Data that VNG may collect from you will depend on the nature of your interaction with us. This includes but is not limited to:

Full name;
Email address;
Date of birth;
Information of Identification documents (National Identity Card, Passport, Driver’s License), including the document number, the biodata page, the date and place of issuance;
Address (Registered residential address, contact address);
Telephone number (Mobile or landline);
Gender;
Marital status;
Occupation;
Photo taken of Your face by the device;
Payment-related information (including bank account information and credit or debit card information);
any other information about you when you (i) sign in to use our Services, and (ii) when you use the Services without the creation of an account, as well as (iii) information related to how you use our Services; and
Aggregate data on the content (such as our Games) that you engage with.

You agree not to submit any Personal Data to us which is inaccurate or misleading and you agree to (i) inform us as soon as is practicable of any inaccuracies and provide us with the accurate Personal Data to correct such inaccuracies; and (ii) to update us if there are any changes related to your Personal Data. We reserve the right (at our sole discretion) to (to the extent permissible by the applicable law) request further documentation to verify the Personal Data provided to us by you.
If you use your Social Media Account (such as Facebook or Google), applicable account (such as your Apple ID) (“Social Media Account”), and/or your phone number to log in, use VNG's Services or link to an Account that you have registered with VNG, you fully understand and agree that VNG can access Personal Data only when you and such Social Media Account service provider agrees and allows us to do so.
You reserve the right to correct, request us to correct, request us to provide or delete the Personal Data provided to us, or you may also withdraw your consent at any time if you do not wish for us to continue to collect or Process Personal Data. However, you should note that your refusal or withdrawal of your consent or your request to delete the Personal Data may affect heavily our ability to provide you wish our Services or access to our Games. You can find more information about this matter in Section 12 below

4. COLLECTION OF OTHER DATA

As with most websites and mobile applications, the data that your device automatically sends to us may include data about you that gets logged by a server when you use our Services. This typically includes but not limited to:

the Internet Protocol (IP) address;
computer/mobile device operating system;
browser type;
type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) of your mobile device;
the referring address of a Site (if any);
the website you access which directs you to our Site and mobile applications and the access times, sometimes a "Cookie" (which can be disabled by using your browser setting) to help the Site remember Your last access.

If you are logged in, this information is associated with your personal Account. Such information (excluding your Personal Data) is also included in the statistics which allow us to statistics, evaluate and understand how users use our Games and Site.

VNG's Services may use technologies such as ARKit (Augmented Reality or AR - Virtual reality technology), Camera API, TrueDepth API ... or similar technologies provided by the operating system of mobile devices; these technologies are used to record the user's facial expression information and for in-app features. Such information, We do not use it for any purpose other than those provided in the application; You have the right to refuse camera access for these features at any time (however, You should note that, when You stop allowing camera access to the application, some of the application's features will not work); and We do not save nor share these information with any third parties.
In some cases, while visiting/using VNG’s mobile applications/Games/Services, you may see in-app advertisements that pop up or are displayed before (or after) entering into the applications/Games/Service. If you click on such advertisements, the same aforementioned information may be transmitted to VNG and/or a third party that cooperates with VNG in order to enhance the product coverage or help VNG manage the product data based on your course of activities. By clicking such an advertisement, you are providing your consent for the third party to collect and/or process your information.

5. COOKIES

A cookie is a small piece of information that is placed on your computer when you visit certain websites.
We use cookies and other similar technologies for analytics, to provide us with information about how visitors (including you) use our website. This may include using cookies as part of the process to collect anonymous information, including the number of visitors to the website, where they are from, the pages that they visit, the length of time they have spent on our website.
You may refuse the use of Cookies by selecting the appropriate settings on Your browser. However, please note that if you do so, you may not be able to use the full functionality of our website, Games, or the Services.

6. HOW VNG USE THE PERSONAL DATA PROVIDED BY YOU TO US?

We may Process Personal Data for one or more of the following purposes:

to respond to legal proceedings, to comply with applicable laws and the requirements of the competent authorities;
to consider and/or process your application/transaction with us or your transactions/ communications with third parties via the Services;
to manage, operate, provide and/or administer your usage of and/or access to our Services, Site and Games (including, without limitation) your preferences, your Account, as well as your relationship with us;
to respond to, process, deal with, complete a transaction and/or to fulfil your requests for certain Services, products;
to notify you of service issues and unusual actions on the Account;
to enforce our Terms of Use or any other applicable end user license agreements;
to protect the personal safety and the rights, property or safety of others, or safety of the person who is under your guardianship;
to identify and/or verify your Account;
to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
to handle or enable the customer service department to fulfill your reasonable requests, to respond to any inquiries submitted by you or by another person on your behalf, provided that the person acting on your behalf has all documents proving that you have authorized them to perform these works and requests;
to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your usage of our Services, such as but not limited to conveying information to you relating to our Services. You acknowledge and agree that we may contact you by mail or by sending notices to you through appropriate means of communication, which may disclose certain personal information about you (E.g.: your name and mailing address on an envelope);
to allow other users to interact or connect with you, including to inform you when another user has sent you a private message or posted a comment for you on the Games or Site or our Services;
to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys and/or profiling the characteristics of product and Service), to analyze how You use our Services, to improve our Services or products and/or to enhance Your customer experience;
to allow for advertising and other audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with VNG’s Services;
for marketing purposes. In this case, through various communication methods, We will send You information, marketing and promotional materials related to products and/or Services which VNG and our subsidiaries, affiliates, whether such products or Services are current or future products or Services;
to compile statistics and research to satisfy our reporting and/or maintain records requirements internally or in accordance with relevant regulations;
to conduct inquiry, verification or other screening activities (including, but not limited to, background checks) in order to comply with our risk management policies and procedures that may be required by law or that may have been put in place by us;
to check our Services or VNG's operations;
to prevent or investigate any actual or suspected breach of our Terms of Use, including but not limited to fraud, illegality, omission, or any other misconduct, whether or not related to your usage of our Services or any other matter arising from your relationship with us;
to store, host, back up (whether for disaster recovery, including but not limited to war, fire, natural disaster and or other serious or otherwise) of your Personal Data;
to verify eligibility and/or to submit an application or registration request to participate in a competition, event, or any game tournaments and to deliver prizes to you when applicable;
to deal with and/or facilitate a Business asset transaction or a potential Business asset transaction, where such transaction involves VNG as a participant or involves only a related subsidiary or affiliate of VNG as a participant or involves VNG and/or any one of VNG's related subsidiaries or affiliates as participant(s), and there may be other third-party organizations who are participants in such transaction. “Business asset transaction” refers to the purchase, sale, lease, merger or any other acquisition, disposal or financing of an organization or a part of an organization or any business activity or assets of an organization; and/or
any other purposes which we notify to you at the time of obtaining your consent.

(Collectively referred to as the “Purpose” or “Purposes”).

The Purposes listed may continue to apply even in situations where a person’s relationship with us has been terminated or altered in any way, for a reasonable period thereafter.
As the Purposes for which we will/may collect, use, disclose or Process Your Personal Data depend on the existing circumstances, such purpose may not appear above. However, we will notify you of such other Purpose at the time of obtaining your consent in respect of that particular Purpose which is not found in Clause 1 above, unless we are permitted to Process Personal Data without your consent under applicable laws.
We may disclose or permit the disclosure of your personal data to:

Third party service providers or other organizations, whether located in Singapore or outside of Singapore, for fulfilling any of the Purposes;
where such disclosure is required for, or in connection with, the provision of the Services to you;
comply with any applicable laws, regulations, codes of practice, guidelines, rules or requests by public agencies, or to assist in law enforcement and investigations;
any other party to whom you authorised us to disclose your personal data to, or where necessary to undertake any action requested by you;
our professional advisers (including but not limited to lawyers, accountants and auditors) to the extent that it is necessary to disclose such information; and
service providers which provide services to or conduct business activities on our behalf, including cloud data storage services.

Some of your Personal Data may be transferred to, stored or processed overseas. However, VNG will only transfer your Personal Data in accordance with the applicable law. By agreeing to this Privacy Policy, you acknowledge, agree, and give VNG your written consent to do so. VNG will implement adequate safeguards, including making reasonable arrangements to ensure that the recipients are bound by legally enforceable obligations (such as laws, contracts, binding corporate rules or any other legally binding instrument), so that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. However, we do not provide any warranty or take any responsibility on the manner or care in which these third parties maintain, protect or utilise your Personal Data, or any misuse by such third parties.
As the result of the Processing Personal Data of VNG, you fully understand and agree to accept the following potential unexpected damages/harms that may occur following Your Consent:

Despite VNG’s best efforts and attempt to protect your Personal Data, it can still be exploited/hacked or unlawfully accessed by third parties;
Your Personal Data could be used for further unlawful approaching/contacting from unauthorized parties without your prior consent/awareness.

By providing us with your consent, you allow us to Process Your Personal Data for all of the Purposes set forth above. If you only agree to some and not all of the Purposes, please do not tick on the box to agree to this Privacy Policy. However, you should note that this may affect your usage of our Services.

7. HOW DOES VNG PROTECT AND RETAIN YOUR PERSONAL DATA? WHAT HAPPENS IN THE EVENT OF A DATA BREACH?

We implement a variety of security measures and strive to ensure the security of your Personal Data on our systems. Personal Data is kept in our secured networks and is only accessible by a limited number of employees who have special access rights to such systems. Further, all of VNG’s staff are required to keep Personal Data confidential.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is 100% secure. While security cannot be guaranteed, we strive to protect the security of the personal data and will constantly review and enhance our information security measures. If you have reason to believe that your interaction with us is no longer secure, please immediately notify our Data Protection Officer at the contact details located at Article 16
The period for which we retain Personal Data will commence from the date on which your consent is provided, up to a period of five (5) years from the date on which you last access or use our Services, Games, and/or our Site. In the event that you have made a request for us to delete your Personal Data in accordance with Section 12 below, please note that we may continue to retain and/or use Personal Data in accordance with this Privacy Policy to comply with our obligations under the applicable law on personal data protection and other relevant regulations.
Personal Data will be retained by VNG (as permitted under the PDPA) to retain Personal Data so long as there is a purpose to be served by the retention of the personal data, or that such retention of personal data is necessary for legal or business purposes.Subject to the applicable law, we may securely delete Personal Data without prior notice to you.
In the event of a data breach that is a notifiable data breach under the PDPA, we will notify the affected individuals (including their parent or legal guardian if the affected individual falls within the category of persons to whom Article 9 below applies) and/or the Personal Data Protection Commission Singapore in accordance with the PDPA’s requirements. We will use reasonable efforts to communicate with the affected individuals using the contact information provided to us or through other appropriate means where necessary. Our communication may include a notification on our Site or Games or any platform through which you access our Services.
If you suspect that a data breach has occurred, you may inform our Data Protection Officer at the contact details set out in Article 16 below.

8. DOES VNG DISCLOSE PERSONAL DATA?

In operating our business, VNG may need to disclose your Personal Data to other third parties like Game developers, service providers, agents and/or subsidiaries and/or affiliates of VNG, and/or other third parties, for one or more of the foregoing Purposes. Such aforementioned third parties will Process Personal Data or on our behalf to Process Personal Data for one or more of the Purposes. Such third parties include, but not limited to:

our subsidiaries, affiliates and related corporations;
contractors, agents, service providers and other third parties that we hire or have a contractual relationship to support our business. These include but are not limited to those which provide administrative service or other services to us such as postal companies, telecommunication companies, information technology companies and data centers;
a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of VNG’s assets, whether as an on-going event or in process of bankruptcy, liquidation or similar proceeding, in which Personal Data of user held by VNG contain in the transferred assets; or to a counterparty in a Business asset transaction that VNG or any of its subsidiaries, affiliates or related corporations is involved in;
competent authorities; and
third parties, to whom disclosure by us, use for one or more Purposes and such third parties shall collect and process Your Personal Data for one or more Purposes.

In this case, third parties may request us, to disclose your game play history and/or disclose records showing which IP addresses have accessed Games. We will also share with these third parties the statistical information about your use of the Services. In this case, the information disclosed to these third parties does not include any Personal Data.
For the avoidance of doubt, we may disclose your Personal Data without your consent where permitted by the applicable laws.
Where your Personal Data is being disclosed to any third party, VNG shall make reasonable arrangements to ensure that the third parties will provide an undertaking or undertake contractual obligations to provide a standard of protection, or are by the applicable law required to provide a standard of protection, for the transferred Personal Data that is comparable to that of the PDPA.
Third parties may unlawfully intercept or access Personal Data transmitted to or contained on the Site, software, applications, technologies which leads to malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. However, We will implement reasonable security measures to protect Your Personal Data in accordance with the law of personal data protection; however, We cannot guarantee absolute security because a third party may gain unauthorized access to Personal Data submitted to or contained in the Game, available on the Site or other software, applications, technology applied which leads to malfunction, or someone may access, abuse or misuse Personal Data through no fault of ours.

9. CHILDREN’S PERSONAL DATA (EXCEPT CHILDREN LIVE IN EU)

Our Services are diverse and catered to a wide range of age groups. For children under the age of 16 or the applicable threshold age (for which a minor may give consent to their personal data being collected) in the relevant jurisdiction, the creation of an Account and use of our Services requires the consent of and supervision of the child's parent or legal guardian.
As a parent or legal guardian of a child under 16 or the applicable threshold age (for which a minor may give consent to their personal data being collected) in the relevant jurisdiction, please take note that children under the age of 16 are not allowed to create or register for an Account on their own, without the supervision of a child’s parent or legal guardian who is required to provide the consent on behalf of a child.
In the event that the parent or legal guardian of a child under 16 or the applicable threshold age (for which a minor may give consent to their personal data being collected) in the relevant jurisdiction, agrees to provide VNG with the Personal Data of such children, the parent or legal guardian hereby consents to our processing and usage of Personal Data in accordance with this Policy on behalf of the child. At the same time, for the case of children from 07 years old, the parent or legal guardian commits and ensures that they get Consent from such children, together with the Consent of the parent or legal guardian, before the Personal Data of children is provided to VNG.
Parents or legal guardians of children under 16 or the applicable threshold age (for which a minor may give consent to their personal data being collected) in the relevant jurisdiction agree that, in addition to Personal Data of children under 16 provided by parent or legal guardian, we may request to be provided the Personal Data of such parent or legal guardian for the Purpose listed at Article 6.1(g) of this Policy.
We will freeze, delete, or block any Accounts used by children that do not comply with the requirements set forth above and will remove and/or delete any Personal Data that we believe has been submitted by the user who is a child under 16 and who does not meet the aforementioned requirements, in VNG’s sole discretion.
For the avoidance of doubt, as the precise identification of whether or not the registration/creation of an Account and providing Personal Data is executed by a child with the consent of or under the supervision of such child’s parent or legal guardian is not feasibly done by VNG, VNG shall not be liable for any losses or damages arising out of and/or in connection with the creation of or use of an Account for VNG’s Games and Services by a child under the age of 16 or the applicable threshold age (for which a minor may give consent to their personal data being collected) in the relevant jurisdiction without the child’s parent’s or legal guardian’s consent or supervision.

10. PERSONAL DATA COLLECTED BY THIRD PARTIES

Our Services and Games may use analytics tools (such as Google Analytics, Facebook Pixel, etc.) (“Analytics Tools”). These Analytics Tools shall use cookies, which are text files placed on your device, to help the website analyze how users use our Services. The information generated by the Cookie about your use of website (including your IP address) will be transmitted to and stored by the providers of Analytics Tools. Providers of Analytics Tools will use this information for the purpose of evaluating your usage of our Services, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage.
Our Services and Games may use measurement tools (such as AppsFlyer, Adjust, Firebase, etc) (“Mobile Measurement Partner” or “MMP”). MMPs use a Software Development Kit (“SDK”) placed on your device to help us monitor and optimize the delivery of Services. Information generated by the SDK about your usage of our applications (including Your IP address) will be sent to and stored by MMP providers. MMP providers will use this information to evaluate your usage of our Services, make reports for other developers and operators, and provide other related services related to the Internet usage.
Our Services may use TrueID, a facial recognition application (“TrueID”) and your ID which is provided to us (including your Identity Card, Passport, or other equivalent document) to verify your identity. TrueID is provided by VNG Software Development Company Limited – a member of VNG to enhance identification and to secure your Account. TrueID will use the camera on Your device to record and capture Your face and ID, using algorithms and Artificial Intelligence (“AI”) to process to detect anomalies during the verification of identity process (such as fraud, faces and photos on ID are incorrect). TrueID will assist us in detecting anomalies, giving recommendations and suggestions to verify your Account. TrueID may send this information to a third party for storage and processing where such is required by law or where such third-party processes information on TrueID's behalf. TrueID also has an obligation to keep your Personal Data confidential, which TrueID stores and treats, similar to VNG's confidentiality obligations.
We, and third parties, may make software application downloads available to You for use on or through the Services. These applications may privately access, and allow a third party to view your identifying information, such as your name, User ID, your device's IP address, or other information such as the Game you are playing during any particular session, and any previous Cookies, SDKs you may have installed or have been installed for you by a software application or website of third party. In addition, these applications may ask you to provide additional information directly to third parties. Third-party products or services offered through these applications are not owned or controlled by VNG. You should read the terms and other policies published by such third parties on their websites or elsewhere.

11. DISCLAIMER REGARDING SECURITY OBLIGATION AND THIRD-PARTY WEBSITES/APPLICATIONS

WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE TO THIRD PARTY WEBSITES/APPLICATIONS.
In an attempt to provide you with increased value, we may choose various third-party websites to link to within the Site or Games. These links may appear as Uniform Resource Locators (“URLs”) or in-game advertisements, or clickable elements that users may interact with. We are not responsible for the privacy policies and practices of third parties or third-party websites to which links are provided. You should check the privacy policies on these sites before providing any Personal Data. Further, Personal Data collected by our co-brand partners or third-party web sites (even if offered on or through our Site or Games) may not be received by us. We may also participate in co-branding and other relationships to offer our users access to e-commerce and other features or services provided and/or operated by third parties. For the avoidance of doubt, such co-branding and other relationships do not fall within the definition of our Services and VNG is not liable for any loss and/or damage arising out of and/or in relation to the any co-branding and other relationships.
If you wish to provide any feedback about the linked sites (for example, if a specific link does not work) to the contact information stated in Section 16 of this Policy.

12. HOW TO WITHDRAW CONSENT, CORRECT OR REQUEST TO CORRECT, PROVIDE OR DELETE PERSONAL DATA?

Withdrawing consent

The consent that you provide for the collection, use, disclosure and transfer of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the Purposes listed above by the methods specified in our Account setup page. We will process the request in accordance with the provisions of this Privacy Policy, the instructions and procedures in the Account setup page, and the applicable law.
You understand that your withdrawal of consent does not affect the lawfulness of our processing of Personal Data which you had agreed to before withdrawing Consent.
However, your withdrawal of consent means that we will not be able to continue providing the Services/Games to You, and we may need to terminate your existing relationship and/or the contract that you have with us. In such event, VNG shall notify you of any potential impact (including any implications on your rights and liabilities in relation to us) but shall not responsible to compensate you for any of your losses in any event.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

Correct or request to correct, provide or delete Personal Data

Once you have registered an Account with us, you can access to view, edit your Personal Data that we have collected, stored or controlled pursuant to your consent and this Policy, through our available systems. If you have not registered an Account with us, or if the Personal Data you wish to correct requires separate procedures for correction, you may request to correct your Personal Data by the methods specified at our Customer Support and Customer Care We will process the request in accordance with the provisions of this Privacy Policy, the Customer Support and Care procedures, and the applicable law.
You may monitor your Personal Data that we store or control by checking the Personal Data displayed at your Account settings page or by requesting us to provide it by other methods in accordance with our Customer Care and Support procedures. Your legal guardian or person authorized by you may also make requests on your behalf. We will process the request in accordance with the provisions of this Privacy Policy, the Customer Support and Care procedures, and the applicable law.
You may request us to delete your Personal Data stored and managed by us in case you (i) are of the view that your Personal Data is no longer needed for the Purposes, (ii) withdraw consent under Section 12.1. You may request to delete your Personal Data by the methods specified in the Account setup page. However, you should note that your request to delete your Personal Data shall mean that we will no longer be able to provide the Services to You, and we may need to terminate our existing relationship and/or your contract with us. In such event, VNG shall notify you of any potential impact (including any implications on your rights and liabilities in relation to us) but shall not be responsible to compensate for any of your losses.
You should note that, in all cases, we shall need sufficient information from You to determine Your identity as well as the nature of Your request, in order to be able to process Your request in accordance with our procedures.
We may charge you a reasonable fee to process your request. If so, we will inform you of the applicable fee and the deadline for payment in writing or by email. Please note that we will require full settlement of the applicable fee (if any) before processing your request.
To the extent permissible under law, we may refuse any such requests if deemed unreasonable.

13. ADDITIONAL PROVISIONS FOR EU USERS ONLY

The provisions in this Section only apply if You are an user living in the EU. These provisions take precedence over any inconsistent provisions in the remainder of this Privacy Policy.

Portability

You have the right to obtain from us the Personal Data that You have previously provided to us, and which we process on the basis of Your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such Personal Data to another party.
If You wish us to transfer the Personal Data to another party, please ensure that You can ensure the detail of such party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party. We also may not provide You with certain Personal Data if providing it would interfere with another’s rights (e.g. where providing the Personal Data we hold about You would reveal information about another person).

Deletion

You reserve the right to request us to delete the Personal Data in the following circumstances:

You believe that it is no longer necessary for us to keep the Personal Data;
We Process Personal Data on the basis of Your Consent, and You wish to withdraw Your Consent. At the same time, We no longer have any other reasons or purposes to continue processing this Personal Data;
We Process Personal Data on the basis of our legitimate interest and You are the object to such processing. Please provide us with detail as to Your reasoning so that we can assess whether there is an overriding interest for us to process and retain such Personal Data;
You no longer wish us to use the Personal Data in order to send You promotions, special offers, marketing and lucky draws; and/or
You believe that the Personal Data is being unlawfully processed.

Please provide as much detail as possible on Your reasons for the request to assist us in determining whether You have a valid basis for deletion. However, we may retain the Personal Data if there are valid grounds under applicable law for us to do so (e.g., to comply with the law system where the subsidiaries, affiliates of VNG places its head office or for the exercise or defense of legal claims, where we have a legal obligation or right to retain certain information, freedom of expression, etc.) but we will let You know if that is the case. Please note that after deleting the Personal Data, we may not be able to provide the same level of servicing to You as we will not be aware of Your preferences and in some cases, our services may no longer be available to you.
You should note that, regulations in some countries (such as Vietnam) and territories require that service providers such as VNG are required to keep Personal Data of the user for a certain period (may be up to 05 (five) years) (“Retention Term”) from the last time that user uses the Service; You agree that, in this case, the provisions of the above-mentioned countries and territories shall prevail; therefore, a request to delete your Personal Data will only be possible after the end of the aforementioned Retention Term.

Retention of Personal Data

At any time, You have the right to refuse us to Process Personal Data in order to send you promotions, special offers and marketing messages, including where we build profiles for such purposes and we will stop Processing Personal Data for that purpose. Please provide as much detail as possible on Your reasons for the request to assist us in determining whether You have a valid basis for objection. However, we may retain the Personal Data if there are valid grounds under law for us to do so.

Refuse against Profiling and Targeted Marketing

Restriction of Processing for Storage Only

You have a right to request that we restrict the Process Personal Data for storage purposes only, where:

You believe the Personal Data is not accurate, for the period it takes for us to verify whether the Personal Data is accurate;
We wish to delete the Personal Data but You want us to just store it instead;
We wish to delete the Personal Data as it is no longer necessary for our purposes but You require it to be stored for the establishment, exercise or defense of legal claims; or
You against us processing Personal Data on the basis of our legitimate interest and you wish us to stop processing Personal Data whilst we determine whether there is an overriding interest in us processing and retaining such Personal Data.

Transfer of Personal Data outside the EU

Your Personal Data may be transferred outside of the EU. We take appropriate steps to ensure that recipients of Your Personal Data are bound to duties of confidentiality and we implement measures such as appropriate contractual clauses to ensure that the recipients of such transfer protect and treat Your Personal Data in accordance with all applicable personal data protection laws.

Information on Children

The Services are not intended for children under the age of 16 who living in the EU. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 16 living in the EU, nor is any part of our Site, Games or other Services directed to children under the age of 16 living in the EU. We will close any Accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted by any children under the age of 16 living in the EU.

14. WHERE TO STORAGE PERSONAL DATA AND TRANSFER TO OTHER COUNTRIES

For Services provided to the Vietnamese market, by VNG and/or its subsidiaries, affiliates, member companies with headquarters located in Vietnam, Your Personal Data shall be stored in Vietnam in accordance with the provisions of Vietnamese law.
For EU users' Personal Data, it will be in accordance with the provisions of Article 13 of this Policy.
For users in Singapore, if your Personal Data is transferred out of Singapore, Article 6.5 shall apply.

15. YOUR OBLIGATION

Be responsible for protecting your own Personal Data and securing your Account;
Be responsible for the accuracy of the Personal Data you have provided to us;
Strictly comply with any laws and regulations relating to the protection of Personal Data; and
Fully read, understand and agree to all the terms stipulated in this Privacy Policy of VNG before using VNG’s Games/Services.

16. QUESTIONS, RESPONSES OR CONTACT TO VNG

If You have any concerns responses or questions about this Privacy Policy, please do not hesitate to contact our Data Protection Officer at privacy@vng.com.vn.

Last updated in May 2024

THE END.

PRIVACY POLICY