1. INTRODUCTION

1. Welcome You to the product(s), services operated by VNG SINGAPORE PTE. LTD and its subsidiaries, affiliates and related corporations (individually and collectively referred to as "VNG", “We”, or "our"). VNG strictly takes its responsibilities relating to information security under applicable data privacy laws and regulations on personal data protection 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 data privacy policy (“Privacy Policy” or “Policy”) is designed to assist You in understanding how VNG processes the personal data that You have provided to VNG, whether now or in the future, as well as to assist You in making an informed decision before providing us with any of Your personal data. This Privacy Policy is considered as a notice of personal data processing, which sent to You before We process Your Personal Data. This Privacy Policy is also designed to assist our users who does live in the European Union (the “EU”) and Thailand to understand their applicable data privacy rights when they use the Services.
2. “Service” or “Services”: means our VNG’s online games (“Games”), and/or websites (the “Site”), and/or any products or services provided by VNG.
3. “Personal Data” means information 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 us the Personal Data and You are responsible for the accuracy of this Personal Data.
4. “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 Personal Data or other related actions.
5. By clicking “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 voluntarily, affirm Your permission to Process Personal Data and You accept all methods, requirements, and/or policies described in this Privacy Policy, and You hereby agree to allow VNG to Process Personal Data as described in this Privacy Policy (“Consent”).
6. IF YOU DO NOT CONSENT AND ALLOW VNG TO PROCESS PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT REGISTER ACCOUNT, USE OUR SERVICES OR ACCESS OUR GAMES OR SITE. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on the Site, inside our Games and/or our Services. We reserve the right to amend this Privacy Policy at any time without sending notice to You.
7. 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?

1. We will/may collect your Personal Data:
• when You register 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 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.
2. The above circumstances only set out some common instances of when your personal data may be collected and does not purport to be exhaustive.
3. This collection/Processing could be terminated following your request/demand as specified in this Privacy Policy; or the closure of such Games/Services of VNG that You chose to use/access; or otherwise specified in this Privacy Policy.

3. WHAT PERSONAL DATA SHALL VNG COLLECT?

1. The Personal Data that VNG may collect includes but is not limited to:
• Full name;
• Email address;
• Date of birth;
• Information of the ID documents (National ID card, passport), including date of issuance, place of issuance;
• Address (Registered residential address, contact address);
• Telephone number;
• Gender;
• Marital status;
• Occupation;
• Photo taken of Your face by the device;
• Payment-related information;
• any other information about You when You (i) sign in to use the Services of VNG, and (ii) when You use the Services, as well as (iii) information related to how You use our Services; and
• Aggregate data on the content that You engages with.
2. You agree not to submit any information to us which is inaccurate or misleading, and You agree to inform us of any inaccuracies or changes related to such information. We reserve the right (at our sole discretion) to request further documentation to verify the information provided to us by You.
3. If You use Your social media account (such as Facebook, Google), applicable account (such as Apple account) (“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.
4. 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 desire us to continue to Process Personal Data. However, You should note that Your refusal or withdrawal of Your Consent or request to delete the Personal Data may affect heavily Your usage of the Services. You can find more information about this matter in Section 12 below.

4. COLLECTION OF OTHER DATA

1. As with most websites and mobile applications, the data that Your device 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 direct 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.

2. 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.
3. In some cases, while visiting/using VNG’s mobile applications/Games/other Services, You may see in-app advertisements that pop up or are displayed before (or after) entering into the applications/Games/Service. In case You click on such advertisements, almost the same information can 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.

5. COOKIES

1. We may from time to time implement "Cookies" or other features to allow us or third parties to collect or share information that will help us improve our Site, Games and Services, or help us offer new services and features. “Cookies” are identified code we transfer to Your computer or mobile device that allow us to recognize Your computer or device and tell us how and when the Services or Site are used or accessed, by how many people and to track activities within our Site and Games. We may link Cookies information to Personal Data. Cookies also link to information regarding what items selected by You on the online shopping website that You have viewed, or Games that You have played. Cookies are also used to deliver content specifying Your interest and to monitor Your usage of the Services.
2. You may refuse the use of Cookies by selecting the appropriate settings on Your browser. However, please note that if You do this, You may not be able to use the full functionality of our Site, Games or the Services.

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

1. 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 guardian;
• 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: disclosure of Personal Data indicated on a letter 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”).

2. 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, unless Process Personal Data without Your Consent is permitted under the law of personal data protection or other legal provisions.
3. Some of Your Personal Data may be transferred to, stored or processed overseas. However, VNG will only transfer it in accordance with the personal data protection regulations. By agreeing to this Privacy Policy, You acknowledge, agree, and give VNG your Consent in full to do so. VNG will implement adequate safeguards to protect Your Personal Data.
4. 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.
5. By your Consent, You allow us to Process Your Personal Data for all of the Purposes set forth above. In case You only agree to one or several 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 VNG PROTECT AND RETAIN YOUR PERSONAL DATA?

1. 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. However, there can inevitably be no guarantee of absolute security.
2. The term of Process Personal Data is counted from the time We obtain Your Consent until the last time You use our Services, and continues for at least another 05 (five) years counted from that time. Even in the event that You request us to delete your Personal Data pursuant to Section 12.2, We may continue storing, using and/or disclosing your 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.
3. We will maintain Personal Data in accordance with the applicable laws on personal data protection and/or other related law. That is, VNG is entitled to delete Your Personal Data when we have reasonably determined that (i) the purpose of retention of such Personal Data no longer serves the purpose of processing such Personal Data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interest warrant further retention of such Personal Data. Subject to applicable law, we may securely delete Personal Data without prior notice to You.

8. DOES VNG DISCLOSE PERSONAL DATA?

1. 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.
2. In this case, third parties may request us, to disclose Your game play history and/or disclose records showing which IP addresses have viewed 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 will not include any information that can be used to specifically identify You or disclose Your Personal Data.
3. For the avoidance of doubt, We may disclose Your Personal Data without your Consent where permitted by the law of personal data protection or other applicable laws which allow us to conduct such action.
4. 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 AND THAILAND)

1. Our Services are diverse and catered to a wide range of age groups. For children under the age of 16, the creation of an Account and use of our Services requires the Consent and supervision of the child's parent or legal guardian.
2. As a parent or legal guardian of children under 16, please do not allow such children, by her/himself to create/register Account to use our Services or submit such children’s Personal Data to VNG without the Consent, supervision of the child's parent or legal guardian.
3. In the event that parent or legal guardian of children under 16 agree to provide VNG the Personal Data of such children, the parent or legal guardian hereby consents to our processing and usage of Personal Data, and the parent or legal guardian consents to be governed by this Privacy Policy on behalf of such children. 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.
4. Parents or legal guardians of children under 16 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 Purposes at point (e) Section 6.1 of this Policy.
5. We will 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. For the avoidance of doubt, since the precise identification of whether or not the registration/creation of an Account and providing Personal Data is executed by a child under the permission/surveillance of such child’s parent or legal guardian is nearly impossible by VNG end, You, as a result of this, confirm and agree that will bind no responsibility to VNG in completely/fully/entirely preventing/classifying/stopping any unauthorized/incompetent users.

10. PERSONAL DATA COLLECTED BY THIRD PARTIES

1. 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.
2. 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.
3. Our Services may use TrueID, a facial recognition application and ID (such as identity card, passport) provided by VNG Software Development Company Limited – a member of VNG (“TrueID”) to enhance identification to secure Your Account. TrueID will use the camera on Your device to record and capture Your face and ID, using algorithms and AI (artificial intelligence) to process to detect anomalies (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.
4. 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

1. WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY WEBSITES/APPLICATIONS. We do implement a variety of security measures to maintain the safety of Your Personal Data that is in our possession or under our control. Your Personal Data is kept in our secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the Personal Data confidential. When You use the Services or access Your Personal Data, we offer the use of a secure server. All Personal Data You provide is encrypted into our databases to be only accessed as stated above.
2. In an attempt to provide You with increased value, we may choose various third-party websites to link to, and frame within, the Site or Games. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our users. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. 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.
3. We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites and application of third party. We protect the integrity of our Site and Games and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work) to the contact information stated in Section 15 of this Policy.

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

1. Withdrawing consent
• You may withdraw Your Consent to the collection, usage and/or disclosure of Your Personal Data that We keep or control 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 our obligations as set forth by law.
• You understand that, Your withdrawal of Consent will not affect the lawfulness of our processing of data which You agreed 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 and We are not responsible to compensate for any of Your losses.
2. 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 Consent, through our available systems. If You have not registered an Account with us, or for some of your Personal Data that We have separate procedures for correcting, You may request to correct Your Personal Data by the methods specified in 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 our obligations as set forth by law.
• You may monitor Your Personal Data that We store or control by checking the Personal Data displayed on Your Account settings page or 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 our obligations as set forth by law.
• You may request us to delete your Personal Data stored and managed by us in case You (i) become aware that Your Personal Data is no longer needed for the Consent Purposes, (ii) withdraw Consent under Section 12.1, (iii) object to our Process Personal Data and We do not have any reasonable reason to continue to Process Personal Data, (iv) our Process Personal Data is not consistent with the Consent Purposes, and/or other reasons as required by the law of personal data protection. You may request to delete Your Personal Data by the methods specified in our 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 without any responsibility 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 We charge a fee, We will provide You the detail cost and deadline for payment in writing or by email. Please noted to make payment on time the above fees (if any) so that the We can response or settle Your request in a timely manner.
• We reserve the right to refuse to provide or delete Your Personal Data in the cases prescribed by law.
3. In the following special cases, Your request may not be accepted when:
• (i) deletion are prohibited by the law regulations;
• (ii) the Personal Data is being processed by the competent governmental authority for the purpose of such authority operation in accordance with the law;
• (iii) public Personal Data following the law;
• (iv) Processed Personal Data following the request of jurisdiction request, survey, or scientific research according to the law;
• (v) in case of emergency situation relating to national security, national defense, social safety and security, disasters, pandemic, or in the thread of national security, national defense but not yet to be deemed as an urgency situation; preventing and fighting against terror or criminal activities.
• (vi) facing any urgent situation that threatens other users’ lives, or safety.

13. ADDITIONAL PROVISIONS FOR EU USERS ONLY

To the extent permitted by the law of the location which you access our service, the provisions in this Section only apply if You are an user that is subject to European Union General Data Protection Regulation These provisions take precedence over any inconsistent provisions in the remainder of this Privacy Policy.

1. 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).
2. 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.
3. 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.

4. Refuse against Profiling and Targeted Marketing

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.

5. 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.
6. 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.

7. 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. ADDITIONAL PROVISIONS FOR USERS FROM THAILAND ONLY

These provisions in this Section apply to users residing in Thailand only and take precedence over any provisions in the rest of this Privacy Policy.

1. Data Protection Rights

Subject to the right indicated in Section 12 of this privacy policy, You have rights regarding your personal data in accordance with the Thai Personal Data Protection Act (PDPA). These rights are outlined below.

• Right to Access

You have the right to access and request a copy of your personal data. You also have the right to request disclosure of the acquisition of your personal data obtained without your consent.

• Right to Data Portability

In cases where we arrange your personal data in a structured, commonly used, and machine-readable format that can be transmitted via automated means, You have the right to transmit that data to another data controller using automated means. You also have the right to receive your personal data in such a format, except in situations where technological limitations prevent this.

• Right to Objection

In circumstances where we are processing personal data that concerns You on the lawful basis of legitimate interest or for direct marketing purposes, You have the right to object to the processing of your personal data carried out by us or on our behalf.

• Right to Restriction

You have the right to have our processing of your personal data restricted in the following circumstances:

• When your request to correct your personal data is pending.
• When your personal data should be deleted, but You have requested for restriction of processing instead.
• When the periods of the processing have expired, but You have requested for restriction of processing instead due to legal reasons
• During the verification process of your objection to the processing of personal data.
• Right to Complaint

If You believe that we have not complied with the requirements of the PDPA as it applies to your personal data, and in addition to your rights set out above, you have a right to lodge a complaint with the Personal Data Protection Commission Office (PDPC) in Thailand.

2. Transfer of Personal Data outside Thailand

Your Personal Data may be transferred outside Thailand when it meets one of the following conditions, in accordance with the PDPA:

• Your consent has been obtained, authorizing the transfer of your personal information to a destination country that have inadequate personal data protection standards.
• The destination countries that receive your personal information have an adequate level data protection as prescribe by the PDPC.
• The transfer is for compliance with Thai law.
• The transfer is necessary to fulfill contractual obligations with you.
• The transfer is necessary to carry out a contractual agreement between two entities for your benefit.
3. Collection of Personal Data from Minors in Thailand

The Services are not intended for minors under the age of 20 who residing in Thailand without the consent of a parent or legal guardian of such minor. We do not knowingly collect or maintain any personal data from anyone under the age of 20 residing in Thailand, nor is any part of our Site, Games or other Services directed to minors under the age of 20 living in Thailand. We will close any Accounts used exclusively by such minors and will remove and/or delete any personal data we believe was submitted by any minor under the age of 20 residing in Thailand without the consent of a parent or legal guardian of such minor.

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

1. 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.
2. For EU users' Personal Data, it will be in accordance with the provisions of Article 13 of this Policy.

16. YOUR OBLIGATION

As the owner of the Personal Data, You are obliged to:

1. Be responsible for protecting Your own Personal Data; request other relevant organizations, entities, or individuals to protect Your Personal Data;
2. Be respectful and protect other users’ Personal Data;
3. Provide fully, truly, and precisely Your Personal Data after allowing others to process Your Personal Data;
4. Strictly comply with any law regulations relating to the Personal Data protection.
5. Fully read, understand and consent with all the terms stipulated in this Privacy Policy of VNG before using VNG’s Games/Services.

17. QUESTIONS, RESPONSES OR CONTACT TO VNG

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

Last updated in July 2024

THE END.