Privacy Policy

No.: CS-VNGG-002

1. INTRODUCTION

1.1. Welcome to the products and services operated and provided by VNG Corporation and/or its subsidiaries, affiliates, and member companies (hereinafter referred to as "VNG" or "We"). VNG takes seriously its obligations regarding the protection of personal data and information in accordance with applicable laws, respecting the privacy of all users of our Services. VNG recognizes the importance of Your personal data and is committed to managing, protecting, and processing it appropriately.

This Personal Data Protection Policy ("Privacy Policy" or "Policy") is designed to help You understand how VNG processes the personal data You provide to VNG, whether currently or in the future, and to assist You in making informed decisions before providing Us with any of Your personal data. This Privacy Policy also serves as a personal data processing notice issued to You. We undertake to collect Your Consent (as defined below) in connection with the relevant Service and upon account registration.

1.2. "Services" means VNG's online games ("Games") and/or website ("Website"), account registration, and/or any other products or services provided by VNG.

1.3. "Personal Data" means digital data or information in other forms that identifies or helps identify a specific individual, including basic personal data and sensitive personal data. Personal Data is provided by You and You are responsible for its accuracy.

1.4. "Sensitive Personal Data" means personal data closely tied to an individual's privacy, the infringement of which directly affects the individual's legitimate rights and interests. Sensitive Personal Data is provided by You and You are responsible for its accuracy. VNG does not currently collect Sensitive Personal Data in the course of providing the Services. In the event that the nature of a specific Service requires the collection of such data, VNG will provide separate notice and obtain Your explicit consent.

1.5. "Terms of Service" means the terms and conditions governing the use of the Services that You agree to comply with upon registering an account or using the Services, including provisions on the rights and obligations of You and VNG, prohibited conduct, and other applicable policies related to the use of the Services.

1.6. "Processing of Personal Data" means any operation performed on Your Personal Data, including one or more of the following: collection, analysis, consolidation, encryption, decryption, modification, deletion, destruction, de-identification, disclosure, publication, transfer of personal data, and/or other actions affecting personal data.

1.7. Prior to using the Services, registering an account, or accessing the Website, You will be required to confirm Your consent to this Privacy Policy. By doing so, You voluntarily and without coercion agree to allow VNG to collect, store, use, and process Your Personal Data for the purposes and within the scope specifically described in this Privacy Policy ("Consent").

1.8. You have the right to withdraw this Consent at any time by following the instructions in Article 12. Withdrawal of Consent does not affect the lawfulness of processing activities carried out prior to such withdrawal. However, in some cases, the withdrawal of Consent may affect Your ability to continue using all or part of the Services. This Privacy Policy applies only to Services directly operated and provided by VNG. When You leave the Services to access third-party websites, applications, or platforms — whether through links contained in the Services or otherwise — this Privacy Policy no longer governs the collection and processing of Your personal data on those platforms. VNG is not responsible for the content, privacy policies, or data processing activities of any third party. In certain cases, when You click a link that leads outside the Services, VNG may display a notice to inform You that You are leaving VNG's Services.

1.9. We may update or amend this Privacy Policy from time to time to reflect changes in data processing activities, legal requirements, or the manner in which We operate the Services.

For changes of a material nature, including but not limited to the expansion of data categories collected, the addition of new processing purposes, or the sharing of data with new third parties, We will notify You through appropriate means (e.g., in-game notifications, email to the registered address, or prominent notice on the Website) at least seven (07) days prior to such changes taking effect. During that period, We will re-collect Your Consent for changes where required by law; and You have the right to disagree and cease using the Services, or to withdraw Your Consent pursuant to the mechanism set out in Article 12.

For changes that do not affect the substance of Your rights and obligations — such as language adjustments, contact information updates, or the addition of clarifying content — We may make such changes without separate notice and without re-collecting Your Consent. Changes will be posted on the Website, in the Games, and/or in Our Services along with the updated date.

If You do not agree with any provision of this Privacy Policy as amended, please stop using the Services and contact Us in accordance with the instructions in Article 12 to exercise Your rights with respect to data already collected.

1.10. To use the Services, Your first step is to create a VNG account. We will ask You to set a username and password to log in and access features within the Services. Based on Your Consent to the Processing of Personal Data, We may also request Your date of birth and gender (gender is optional) to personalize the experience for You. When registering an account, please note:

Do not use Your real name, phone number, or any personal information as Your username;
Do not set an easily guessable password; and
Do not share Your password with anyone under any circumstances. Users under the age of 16 may only share or provide their password to a parent or legal guardian for the purpose of managing and supervising the use of the Services as provided in Article 9 of this Policy.

Your username and user ID will only be used by VNG to operate and manage accounts within the scope of the Services and will not be used by VNG to identify Your actual identity for any purpose beyond the stated scope.

2. WHEN DOES VNG COLLECT PERSONAL DATA?

2.1. VNG collects Personal Data about You in the following circumstances:

When You register an Account, or use VNG's Services, Games, or Website;
When You complete and submit forms related to VNG's products or Services, including registration forms, customer support forms, or similar forms;
When You enter into agreements or provide documents and information in the course of transactions with VNG;
When You interact with Us via telephone, mail, fax, in-person meetings, media platforms, social networks, email, or other channels. Telephone calls may be recorded for customer support and quality control purposes; You will be notified prior to the call being recorded;
When You access or use VNG's Games, Website, or Services through automated data collection technologies such as cookies, pixel tracking, and similar technologies. Details regarding the use of cookies, including cookie types, purposes, and opt-out methods, are described in Article 5;
When You conduct transactions or make payments through VNG's Games or Website;
When You submit feedback, reviews, or complaints to VNG;
When You register to participate in contests, events, promotional programs, or other programs organized by VNG;
During Your use of the Games, Website, and VNG's Services; and/or
Other circumstances as permitted by applicable law (if any).

2.2. In each of the above circumstances, the corresponding types of Personal Data collected are described in Article 3 of this Privacy Policy. Based on Your Consent to the Processing of Personal Data, VNG only collects data that is appropriate, necessary, and proportionate to the stated processing purpose.

3. WHAT PERSONAL DATA WILL VNG COLLECT?

3.1. Only upon receipt of Your Consent with respect to each group of purposes for Processing Personal Data under Article 6.1, the Personal Data that VNG may collect includes:

Full name, middle name, and birth name, and other names (if any);
Date, month, and year of birth;
Gender;
Place of birth, place of birth registration, permanent residence address, temporary residence address, current residential address, hometown, and contact address;
Nationality;
Personal photographs;
Phone number, personal identification number, passport number, driver's license number;
Marital status;
Information about family relationships (parents, children, spouse);
Information about the individual's digital accounts;
Information related to transactions and payments;
Other information associated with You or that helps identify You in accordance with applicable law.

3.2. You warrant that all Personal Data You provide to VNG is accurate, complete, and not misleading. You are responsible for notifying VNG promptly of any changes to the data You have provided.

3.3. Where necessary for identity verification or regulatory compliance, VNG may request You to provide additional supporting documents. VNG will clearly inform You of the reason and the scope of documents required.

3.4. If You use a social media account or third-party application account (including but not limited to Facebook, Google, Apple) to log in or link to Your VNG Account, VNG may receive certain Personal Data from that platform — such as Your full name, email address, and profile photo — depending on the scope of access permissions You grant at the time of login. VNG encourages You to review the access permissions being requested before confirming the login. The list of supported platforms may be updated from time to time and will be announced on the Website or within the Services. VNG only accesses data from Your third-party account when You actively grant permission through that platform's authentication mechanism. The data received is used solely for the purpose of creating and managing Your VNG Account, unless You consent to its use for other purposes. You may unlink the third-party account through Your account settings or through the corresponding third-party platform's settings. Unlinking does not affect data that VNG has lawfully received and processed prior to such unlinking. If You wish for VNG to delete data received from the third-party account, please submit a data deletion request in accordance with the instructions in Article 12.

3.5. In addition to other rights under applicable law, You have the right to correct, request correction, request provision, request deletion, restrict, or object to the processing of Personal Data You have provided to Us, or to withdraw Your Consent at any time if You no longer wish Us to continue Processing Your Personal Data as described herein. However, please note that Your refusal or withdrawal of Consent to allow Us to Process Your Personal Data, or Your request to delete Personal Data You have provided to Us, may affect Your ability to use Our Services. Further information on this subject may be found in Article 12 below.

3.6. Some Personal Data is necessary for VNG to provide the Services to You. If You do not consent to VNG's collection and processing of such data, VNG will be unable to create an account or provide the Services to You. With respect to non-essential Personal Data — including data that is not essential for the provision of the Services — You may decline to provide it or withdraw Your Consent at any time without affecting Your right to use the Services.

4. COLLECTION OF OTHER TECHNICAL DATA

4.1. When You use VNG's Services, Games, or access the Website, VNG's devices and systems may automatically record certain technical data, including but not limited to:

Device and connection data: IP address, browser type and version, device type and model, operating system and version, device identifier, mobile network provider, language settings, and region;
Performance and usage data: access time and duration, pages and screens visited, features used, in-game activity history such as match results and achievements, error reports, and system performance data;
General location data: geographic location at the city or country level inferred from IP address, not the precise location of the device.

4.2. VNG collects and uses the data described in Clause 4.1 for the following technical operational purposes:

Ensuring the performance, stability, and accessibility of the Services;
Detecting, investigating, and resolving technical errors;
System security, fraud detection, and prevention of violations of the Terms of Service;
Aggregate analysis and statistics to improve the Services and user experience;
Optimizing the Services to suit Your device and system configuration;
Other technical operational purposes of a similar nature as those described above and consistent with applicable law.

4.3. VNG does not use the data described in Clause 4.1 to identify individual users beyond the technical operational purposes set out in Clause 4.2. Data that is fully anonymized or aggregated in a manner that does not permit individual identification is not considered personal data and may be used by VNG for analysis and service improvement purposes without storage time limitations.

4.4. Some of the technical data described in Clause 4.1 is collected through Cookies. Details on Cookies, their purposes, and opt-out methods are described in Article 5 below.

5. COOKIES

5.1 VNG uses cookies and similar technologies (collectively, "Cookies") on the Website, in Games, and across VNG's Services. Cookies are small text files or identifiers stored on Your device when You access the Website, Games, or use the Services, enabling VNG to record information about Your session and preferences.

5.2. Pursuant to the Cookie Policy, VNG uses four types of Cookies: Essential Cookies, Performance Cookies, Functional Cookies, and Targeting Cookies. Information collected through Cookies is processed in accordance with the following principles:

Information collected through Performance Cookies and Functional Cookies is aggregated and anonymized prior to processing in a manner that does not permit individual user identification;
With respect to Targeting Cookies, VNG requires advertising partners to process data in accordance with equivalent data protection standards and not to use such data to identify individuals beyond the agreed advertising purposes.

5.3. You have the right to control and manage Cookies, including the right to refuse certain types of Cookies, in the following ways:

Through browser settings: most browsers allow You to view, delete, or block Cookies. Specific instructions can be found in the help section of Your browser;
Through VNG's Cookie management tool: You may customize Your Cookie preferences You can customize your Cookie preferences by following the instructions in VNG's Cookie Policy at [https://privacy.vnggames.net/cookie/en];
Through device settings: for mobile applications, You may control certain types of tracking through the privacy settings on Your device.

Please note that disabling Essential Cookies may affect Your ability to access and use the Services.

5.4. For further details on the types of Cookies VNG uses, their purposes, storage duration, and how to manage Cookies, please refer to VNG's Cookie Policy at [https://privacy.vnggames.net/cookie/en].

6. HOW DOES VNG USE YOUR PERSONAL DATA?

6.1. VNG may Process Your Personal Data for one or more of the following purposes:

6.1.1. Provision of the Company's Services

Creating, managing, and maintaining Your account; verifying identity and authenticating login credentials;
Processing transactions, applications, correspondence, and Your requests related to VNG's Services and products;
Providing, operating, maintaining, and improving the Services, Games, and Website, including personalizing the experience to suit Your device and preferences;
Maintaining and updating software and providing technical support to ensure stable operation of the Services;
Storing match history, achievements, and gameplay data for in-game replay and statistics features;
Notifying You of issues related to the Services and unusual account activity;
Resolving Your support requests, inquiries, and complaints, including requests submitted by a duly authorized representative;
Contacting You by phone, email, mail, message, or other appropriate means for the purpose of relationship management and providing information about the Services;
Notifying You of private messages or interactions from other users within the Games, on the Website, or in the Services;
Other purposes consistent with applicable law.

6.1.2. Compliance with Legal Obligations

Complying with applicable laws and regulations and requirements of competent state authorities, and other related purposes;
Fulfilling commitments or agreements with domestic or foreign competent authorities;
Enforcing the Terms of Service and applicable user agreements;
Detecting, preventing, and investigating fraud, deception, violations of the Terms of Service, and other unlawful conduct;
Monitoring text chat and voice content within the Services for the purpose of detecting and addressing violations, harassment, or harm to other users;
Protecting the safety, rights, and assets of VNG, users, and third parties;
Conducting verification, screening, and risk control processes as required by law or VNG's internal policies;
Preparing statistics and reports for internal purposes or as required by law;
Complying with applicable legal requirements regarding identity verification and personal data protection.

6.1.3. Legitimate Interests

Data analysis, surveys, and research to improve the Services and user experience;
Developing new features and product enhancements based on user behavior analysis and feedback;
Testing and evaluating the performance of the Services and VNG;
Storing, backing up, and restoring Personal Data in the event of technical incidents or disasters;
Processing Personal Data to the extent necessary in connection with corporate transactions such as acquisitions, mergers, consolidations, or restructurings in which VNG participates, provided that the receiving party commits to protecting data to an equivalent standard;
Other purposes consistent with applicable law.

6.1.4. Advertising and Marketing

Providing relevant advertisements, surveys, and promotional programs;
Measuring advertising effectiveness and verifying the size and composition of VNG's target audience;
Contacting You regarding promotional programs, events, and information about VNG's new products and Services.

Where You consent to the Processing of Your Personal Data for Our advertising and marketing purposes, We will provide advertising and marketing information with the following content, methods, formats, and frequency:

Content: Information related to products, services, promotional offers, and new products and services that may be of benefit to You, in accordance with Vietnamese law.
Methods: Email, text message, telephone call, through the Company's applications and website, depending on the specific advertising, marketing activity, or campaign, in accordance with Vietnamese law.
Format: Images, videos, textual content, charts, illustrative and simulation tools for products and services, depending on the specific advertising, marketing activity, or campaign, in accordance with Vietnamese law.
Frequency: Depending on the Company's specific advertising and marketing activities; however, within any 24-hour period, We will not send more than three (03) advertising messages to Your phone number, three (03) advertising emails to Your email address, and will not make more than one (01) advertising call to Your phone number. Messages and calls will only be sent and made between 07:00 and 22:00 each day (for messages) and between 08:00 and 17:00 each day (for advertising calls), in accordance with Vietnamese law.

(collectively referred to as "Processing Purposes")

6.2. Legal Bases for Processing

VNG processes Your Personal Data on one or more of the following legal bases:

Provision of Services: the purposes set out in Clause 6.1.1 above are necessary for VNG to provide the Services pursuant to the agreement with You;
Compliance with legal obligations: the purposes set out in Clause 6.1.2 above are carried out to comply with legal requirements and requirements of competent authorities;
Legitimate interests: the purposes set out in Clause 6.1.3 above serve VNG's legitimate interests in operating, protecting, and improving the Services; and/or
Consent: the advertising and marketing purposes set out in Clause 6.1.4 above are only carried out upon Your explicit consent. Your refusal or withdrawal of such Consent at any time in accordance with the instructions in Article 12 will not affect Your right to use the Services.

6.3. New Processing Purposes

In the event that VNG needs to process Your Personal Data for a new purpose beyond those set out in Section 6.1, VNG will notify You and obtain Your Consent prior to doing so, except where applicable law permits processing without consent.

6.4. Automated Processing

Certain Processing of Your Personal Data may be carried out through automated methods, such as algorithms, artificial intelligence, and machine learning. VNG uses these tools for the following purposes:

Detecting and preventing fraudulent, deceptive, and Terms of Service-violating conduct through behavioral analysis and anomaly pattern recognition;
Analyzing text chat and voice content to detect violations, harassment, or harm; and/or
Personalizing user experience based on behavioral analysis and in-game preferences.

In the event that an automated decision significantly affects You — such as account restriction or suspension — VNG will ensure human review is available upon Your request. You have the right to object to such automated decisions through the process set out in Article 12.

7. HOW DOES VNG PROTECT AND STORE YOUR PERSONAL DATA?

7.1. VNG implements appropriate technical and organizational measures to protect Your Personal Data, including but not limited to:

Access controls: Personal Data is accessed only by authorized personnel and systems, in accordance with the principle of least-privilege access;
Encryption: Personal Data is encrypted during transmission and storage in accordance with applicable technical standards;
Monitoring and detection: VNG maintains monitoring systems to detect and respond promptly to security incidents;
Personnel training: Employees with access to Personal Data receive training on data protection obligations; and
Other measures consistent with applicable law.

Although VNG endeavors to protect Your Personal Data, no security system can guarantee absolute safety. The transmission of data over the internet cannot be guaranteed to be 100% secure, and therefore VNG cannot warrant absolute security for information You share with Us. To the extent permitted by law, VNG shall not be liable for any inadvertent disclosure of information resulting from causes beyond VNG's reasonable control.

7.2. VNG may contact You via email or in-app notifications regarding security, privacy, and account management matters. In the event of an incident that may constitute a personal data breach as defined by applicable law, VNG will notify You and take remedial measures in accordance with applicable law.

7.3. VNG retains Your Personal Data for the period necessary to fulfil the Processing Purposes set out in Clause 6.1 above, or as required by law, whichever is longer. Specifically:

Account and transaction data: retained for the duration that Your Account remains active and for a minimum of five (05) years from the date the Account is closed or from the date You last used the Services, in order to comply with legal obligations regarding financial record retention and dispute resolution (if any);
Customer support data: retained for a reasonable period to resolve requests and for the purpose of improving the Services;
Behavioral and technical data: retained for the period necessary for analysis and security purposes, after which it is anonymized or deleted.

In the event You request the deletion of Your Personal Data in accordance with Article 12, VNG will fulfill such request to the extent permitted by law. VNG may continue to retain certain Personal Data in the following circumstances: compliance with legal obligations; resolution of ongoing disputes; enforcement of agreements with You; or other lawful reasons under applicable law.

7.4. When Personal Data is no longer necessary for any of the purposes set out in Clause 7.3, VNG will delete or anonymize such data using appropriate technical measures. In the event VNG proactively deletes data on a scheduled basis, VNG will notify You within a reasonable period prior to such deletion so that You may exercise Your data portability right if desired, unless not required by law or technically impracticable to do so.

8. DOES VNG SHARE YOUR PERSONAL DATA?

8.1. In the course of conducting its business operations, and only upon Your consent, We may share Your Personal Data with the following parties to fulfil one or more of the Processing Purposes set out in Clause 6.1:

VNG's subsidiaries, affiliated companies, and member companies;
Contractors, agents, service providers, and other third parties that We engage to support Our business operations, including but not limited to providers of administrative, information technology, data storage, analytics, payment, customer support, marketing, postal, and telecommunications services;
Buyers or other successors in the event that VNG participates in corporate transactions such as acquisitions, mergers, restructurings, reorganizations, dissolutions, liquidations, sales, or transfers of some or all of VNG's assets, whether as an ongoing concern or as part of bankruptcy, insolvency, or similar proceedings, where Personal Data VNG holds about its users is among the assets being transferred; or to a counterparty in a business asset transaction in which VNG or any of its subsidiaries, affiliates, or member companies participates;
Competent state authorities upon request in accordance with applicable law; and
Third parties with whom We share information for one of the Purposes referred to in Article 6.

8.2. VNG may share with third parties aggregated statistical data on how users use the Services, including in-game activity history and technical data. VNG takes reasonable anonymization and aggregation measures prior to sharing in order to limit the ability to identify You individually from such data.

8.3. VNG may share Your Personal Data without Your Consent in circumstances permitted or required by law, including but not limited to: compliance with requirements of competent state authorities; fulfillment of legal obligations; protection of the life, health, honor, dignity, rights, and interests of individuals; or serving the public interest in accordance with applicable law.

9. CHILDREN'S PERSONAL DATA

9.1. Our Services cater to a wide range of users across various age groups. With respect to children under the age of 16, VNG requires the consent and supervision of a parent or legal guardian prior to the child creating an Account or using Our Services.

9.2. Parents or legal guardians are responsible for supervising and ensuring that children under the age of 16 do not independently register an Account, use the Services, and/or provide their Personal Data to VNG without the Consent and supervision of their parent or legal guardian.

9.3. In the event that a parent or legal guardian consents to providing the Personal Data of a child under the age of 16 to VNG, the parent or legal guardian shall ensure that the child consents to VNG's processing of the child's Personal Data in accordance with this Privacy Policy. For children aged seven (07) to under sixteen (16), VNG requires the consent of both the child and the parent or legal guardian; the parent or legal guardian is responsible for ensuring that the child has been fully informed and has consented before providing the child's Personal Data to VNG. VNG may take steps to verify such consent to the extent technically feasible. By providing the child's Personal Data to VNG, the parent or legal guardian confirms that they have full legal authority to do so and that the child has been informed of the data processing under this Privacy Policy.

9.4. In certain cases necessary to verify the guardianship relationship, fulfil legal obligations, or communicate regarding the child's Account, VNG may request the parent or legal guardian to provide certain Personal Data of their own. The collection and processing of the parent's or legal guardian's Personal Data in such cases is subject to the provisions of this Privacy Policy.

9.5. In the event that VNG discovers that a child under the age of 16 has registered or used the Services without meeting the above requirements, or upon any indication of such a violation, VNG reserves the right to suspend the relevant Account and delete the Personal Data collected as soon as reasonably practicable, unless retention is required by law.

10. DATA COLLECTED BY THIRD PARTIES

10.1. Our Services may integrate third-party analytics tools (including but not limited to Google Analytics, Facebook Pixel, and similar tools) to help VNG understand how users use the Services, generate activity reports, and improve operational efficiency. These tools may collect technical data including IP addresses and information about the use of the Services through Cookies, SDKs, or similar technologies depending on the deployment environment. Data collected is transmitted to and processed by the respective tool provider in accordance with their privacy policy.

10.2 Our Services may integrate third-party measurement tools (including but not limited to AppsFlyer, Adjust, Firebase, and similar tools) to track and optimize the delivery of the Services to users, including measuring advertising effectiveness and application installation sources. These tools operate through SDKs integrated into the application and may collect technical data including IP addresses and device information. Data collected is transmitted to and processed by the respective tool provider in accordance with their privacy policy.

10.3. VNG's Services may allow You to download or use third-party software applications. These applications may access certain information about You within the Services, including username, user ID, device IP address, and information about the Games You are using. These applications may also request You to provide additional information directly to the third party. Third-party applications, products, and services are not owned or controlled by VNG. You are encouraged to read and review the privacy policies of such third parties before using them.

11. DISCLAIMER OF CONFIDENTIALITY OBLIGATIONS AND THIRD-PARTY WEBSITES

11.1. VNG does not guarantee the security of personal data and/or other information You provide on third-party websites or applications, even if those websites or applications are linked from VNG's Services.

11.2. To provide added value to users, VNG's Services may contain links to third-party websites or applications, integrate content from partners, or collaborate with third parties to provide marketing, e-commerce, advertising, and other services and features. Such third-party websites, applications, and services have their own privacy policies and security measures that are independent of VNG, even if the third party is affiliated with Us. Data collected by marketing partners or third-party websites through VNG's Services may not be received or controlled by VNG. VNG recommends that You read and review the privacy policies of such third parties before providing any information to them.

11.3. VNG is not responsible for the content, privacy policies, or data processing activities of third-party websites or applications. If You have feedback regarding third-party links on VNG's Services, please contact VNG using the contact information in Article 14.

12. HOW CAN YOU WITHDRAW CONSENT, CORRECT, REQUEST CORRECTION, ACCESS, DELETE, RESTRICT, OR OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA?

12.1. Withdrawal of Consent

You may withdraw Your Consent to VNG's processing of Your Personal Data through the Account Settings and VNG's Customer Care page. We will process Your request in accordance with the provisions of this Privacy Policy, the instructions and procedures on the Account Settings page, and applicable law.
Withdrawal of Your Consent does not affect the lawfulness of processing activities carried out prior to such withdrawal.
Withdrawal of Consent only affects processing activities based on consent as the legal basis under Clause 6.2(d), including advertising and marketing purposes. For processing activities necessary for the performance of a contract or compliance with legal obligations or legitimate interests under Clauses 6.2(a), (b), and (c), VNG may continue to process data even after You withdraw Your Consent. In the event that withdrawal of Consent affects VNG's ability to provide the Services, VNG will inform You clearly before processing Your request.

12.2. Correction, Request for Correction, Access, Deletion, Erasure, Restriction, and Objection to Processing

(a) If You have registered an Account with Us, You may access and modify Your Personal Data through the Account Settings page. If You have not registered an Account with Us, or for certain Personal Data for which We have a separate correction process, You may submit a correction request through the customer support process at https://support.vnggames.com. VNG will process Your request in accordance with this Privacy Policy and applicable law.

(b) You may view the Personal Data about You that We are storing or controlling through the Account Settings page or by requesting Us to provide it through the customer support process at https://support.vnggames.com. Your legal guardian or duly authorized representative may also make requests on Your behalf. VNG will process Your request in accordance with this Privacy Policy, the Customer Support process, and Our obligations under applicable law.

(c) You may request VNG to delete, restrict, or object to the processing of Your Personal Data that We are storing or controlling in the following circumstances:

Your Personal Data is no longer necessary for the stated Processing Purposes;
You withdraw Your Consent pursuant to Clause 12.1 and there is no other legal basis for processing;
You object to the processing of Your Personal Data and VNG has no overriding legitimate grounds to continue processing;
Your Personal Data has been processed in a manner inconsistent with the stated Processing Purposes; and/or
Other grounds as provided by applicable law.

You may submit a request for deletion, restriction, or objection to the processing of Your Personal Data that We are storing or controlling through the methods provided on the Account Settings page or through the customer support process. However, please note that requesting deletion, restriction, or objection to the processing of Your Personal Data may affect VNG's ability to continue providing some or all of the Services to You. In such case, if the Services are partially or wholly terminated or suspended, We shall not be required to compensate You for any losses to the extent permitted by law. VNG will clearly inform You of the specific implications prior to acting on Your request.

(d) To process Your request, VNG requires sufficient information from You to verify Your identity and the substance of the request. VNG may request additional verification information where necessary. Such verification information will only be used for the purpose of processing the request and will not be retained longer than necessary.

(e) VNG does not charge fees for routine requests. In exceptional cases permitted by applicable law — such as repeated requests submitted within a short period or requests without clear grounds — We may charge You a reasonable fee to process Your request and will notify You in advance of such charge.

(f) VNG reserves the right to refuse, in whole or in part, requests to access, delete, or restrict the processing of Your Personal Data in circumstances permitted by law, including but not limited to:

The deletion or provision of data would affect VNG's legal obligations, including record retention obligations under tax, accounting, or other applicable regulations;
The Personal Data is related to an ongoing dispute, claim, or legal proceeding;
The processing is necessary to protect the legitimate rights and interests of VNG or a third party;
The request is unsubstantiated or repetitive in a manner that disrupts VNG's normal operations; and/or
Other circumstances as provided by applicable law.

In the event of a refusal, VNG will notify You of the grounds for refusal in writing within a reasonable timeframe.

12.3. In addition to the above rights, You have the right to file complaints, make denunciations, bring legal action, seek compensation for damages as prescribed by law, and request that competent authorities or relevant organizations and individuals involved in personal data processing take measures and implement solutions to protect Your personal data in accordance with the law.

13. STORAGE LOCATION AND CROSS-BORDER TRANSFER OF PERSONAL DATA

13.1. For Services provided to the Vietnamese market by VNG and/or its subsidiaries, affiliated companies, and member companies whose registered principal offices are located in Vietnam, Your Personal Data will be stored in Vietnam in full compliance with Vietnamese law.

13.2. In certain circumstances, Your Personal Data may be transferred to and stored on servers located outside the territory of Vietnam, including where VNG uses services from third-party providers whose infrastructure is located abroad, or where data is shared with companies within the VNG Group that are headquartered overseas. The personal data protection laws of those countries may not be consistent with Vietnamese law.

13.3. VNG will only carry out cross-border transfers of Personal Data after fulfilling the applicable obligations under the Personal Data Protection Law and related regulations.

13.4. Regardless of where Your Personal Data is stored or processed, VNG commits to implementing appropriate protective measures to ensure that Your privacy continues to be protected to a standard equivalent to that set out in this Privacy Policy, including by entering into binding agreements with data recipients regarding data protection obligations.

14. QUESTIONS, FEEDBACK, AND CONTACT

If You have any questions, feedback, or inquiries regarding this Policy, please contact Us through Our online customer support channel in accordance with VNG's Complaint Resolution Process in effect at the time of submission, including: (i) within the Games or Services; (ii) through the Customer Care channel in the support section of the Game's homepage or the Service's Website; or (iii) the hotline telephone number.

The Personal Data Privacy Policy, Version CS-VNGG-002, effective June 19, 2026.

Version history available here