1.1 Welcome to the VNG website run by VNG Singapore PTE. LTD. and its affiliates and related corporations (individually and collectively, "VNG", "we", "us" or "our"). VNG takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all users of our VNG games (“Games”) and website (the "Site") (we refer to the Games, Site and the services we provide collectively as the "Services").
1.3 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information.
2.1 We will/may collect personal data about you:
- when you register and/or use our Services, Games or Site;
- 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;
- when you use our electronic services, or interact with us via our Games or Site or use our Services. This includes, without limitation, through cookies which we may deploy when you interact with our Games or Site;
- 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 or game specific events;
- during your gameplay; and
- when you submit your personal data to us for any reason.
3.1 The personal data that VNG may collect includes but is not limited to:
- email address;
- date of birth;
- billing address;
- telephone number;
- any other information about the user when the user signs up to use our Services, and when the user uses the Services, as well as information related to how the user uses our Services; and
- aggregate data on content the user engages with.
3.2 You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inacuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify the information provided by you.
3.3 Your bank account and payment information related to credit/ debit cards will not be collected or archived by VNG. All these payment information is and only is archived by the duly payment services agency which has commitment with VNG to ensure the privacy protection regulations related to personal data.
4.1 As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you use our Services. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our Games and Site.
5.1 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 the Services we offer, or help us offer new services and features. “Cookies” are identifiers 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 website are used or visited, by how many people and to track activity within our Site and Games. We may link cookie information to personal data. Cookies also link to information regarding what items you have selected for purchase pages you have viewed, or games you have played. This information is used to keep track of your shopping cart, for example. Cookies are also used to deliver content specific to your interest and to monitor usage of the Services.
6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
- to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;
- to manage, operate, provide and/or administer your use of and/or access to our Services, Site and Games (including, without limitation, your preferences), as well as your relationship and user account with us;
- to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
- to enforce our Terms of Service or any applicable end user license agreements;
- for identification and/or verification;
- 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 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 use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
- 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;
- to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse 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 and, in this regard, to send you by various modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom VNG may collaborate or tie up with) that VNG (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies;
- to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on VNG or on its related corporations or affiliates;
- to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
- to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
- to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
- to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
- 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 corporation or affiliate of VNG as a participant or involves VNG and/or any one or more of VNG's related corporations or affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation; and/or
- any other purposes which we notify you of at the time of obtaining your consent. (collectively, the “Purposes”).
7.1 We implement a variety of security measures and strive to ensure the security of your personal data on our systems. User personal data is contained behind 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.
7.2 We will retain personal data in accordance with the applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of 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 dispose of your personal data without prior notice to you.
8.1 In conducting our business, we will/may need to disclose your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Such third parties include, without limitation:
- our subsidiaries, affiliates and related corporations;
- other users of our Platform for one or more of the above-stated Purposes;
- contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as mailing houses, 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 a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by VNG about our users is among the assets transferred; or to a counterparty in a business asset transaction that VNG or any of its affiliates or related corporations is involved in; and
- third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.
8.2 This may require, among other things, disclosing your gaming history and/or disclosing records showing which games were viewed by which IP addresses. We will also share statistical and demographic information about our users and their use of the Services with suppliers of advertisements and programming.
8.3 Additionally, you may elect to export your user activity feeds as RSS feeds which may be subscribed to by other users, which may include information regarding your game play, installation of games, connections with other users and other information about your account activity which is published as a feed on the Site or Games.
8.4 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply.
8.5 Third parties may unlawfully intercept or access personal data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours.
9.1 Our Site and Games use the payment services provided by competent third parties (“Payment Services Provider”). The Payment Services Provider will collect and use the specific payment information for the purpose of payment procedures when you use of our Services and in our Site. The Payment Services Provider may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.
9.2 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. Your personal data is contained behind 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. Third party products or services provided through these applications are not owned or controlled by VNG. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.
9.3 We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. 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.
Last modified: 01 October 2020