1.2. “Service” or “Services”: means our VNG’s online games (“Games”), and/or websites (the “Site”), and/or any products or services provided by VNG.
1.3. “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.
1.4. “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.
2. WHEN SHALL VNG COLLECT PERSONAL DATA?
2.1. We will/may collect your Personal Data:
(a) when You register and/or use our Services, Games or Site, or register an Account with us;
(b) 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;
(c) 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;
(d) 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;
(e) when You use our electronic services, or interact with us via our Games, Site or use our Services. This includes, without limitation, through Cookies which we may deploy when You interact with our Games or Site or our Services;
(f) when You carry out transactions through our Games or Site;
(g) when You provide us with feedback or complaints;
(h) when You register for a contest, for games, events and/or Games-related promotional programs and our Services;
(i) during Your gameplay, using VNG’s Sites and Services; and
(j) when You submit your Personal Data to us for any reason.
2.2. 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. WHAT PERSONAL DATA SHALL VNG COLLECT?
3.1. The Personal Data that VNG may collect includes but is not limited to:
(a) Full name;
(b) Email address;
(c) Date of birth;
(d) Information of the ID documents (National ID card, passport), including date of issuance, place of issuance;
(e) Address (Registered residential address, contact address);
(f) Telephone number;
(h) Marital status;
(j) Photo taken of Your face by the device;
(k) Payment-related information;
(l) any other information about You when the 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
(m) Aggregate data on the content that You engages with.
3.2. For the avoidance of doubt, We will not process any of Your Personal Data, in any case, which is considered as sensitive Personal Data in accordance with applicable data protection laws.
3.3. You agree not to submit any information to us which is inaccurate or misleading or which is considered as sensitive personal data, 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.
3.4. 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.
3.5. 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 Your usage of the Services. You can find more information about this matter in Section 12 below.
4. COLLECTION OF OTHER DATA
4.1. 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:
(a) the Internet Protocol (IP) address;
(b) computer/mobile device operating system;
(c) browser type;
(d) type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) of Your mobile device;
(e) the referring address of a Site (if any);
(f) 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.
4.2. 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.
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 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.
6. HOW VNG USE THE PERSONAL DATA PROVIDED BY YOU TO US?
6.1. We may Process Personal Data for one or more of the following purposes:
(a) to respond to legal proceedings, to comply with applicable laws and the requirements of the competent authorities;
(b) to consider and/or process Your application/transaction with us or Your transactions/ communications with third parties via the Services;
(c) 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;
(d) to respond to, process, deal with, complete a transaction and/or to fulfil Your requests for certain Services, products;
(e) to notify You of service issues and unusual actions on the Account;
(g) to protect the personal safety and the rights, property or safety of others, or safety of the person who is under Your guardian;
(h) to identify and/or verify Your Account;
(i) 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;
(j) 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;
(k) 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);
(l) 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;
(m) 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;
(n) 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;
(o) 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;
(p) to compile statistics and research to satisfy our reporting and/or maintain records requirements internally or in accordance with relevant regulations;
(q) 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;
(r) to check our Services or VNG's operations;
(t) 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;
(u) 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
(v) any other purposes which we notify to You at the time of obtaining your Consent.
(Collectively referred to as the “Purpose” or “Purposes”).
6.2. 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.
7. HOW VNG PROTECT AND RETAIN YOUR PERSONAL DATA?
7.1. 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.
7.3. We will maintain Personal Data in accordance with the applicable laws on personal data protection and/or other related law. That is, VNG is entitle 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?
8.1. 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:
(a) our subsidiaries, affiliates and related corporations;
(b) 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;
(c) 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;
(d) competent authorities; and
(e) 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.
8.2. 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.
8.3. 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.
8.4. 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)
9.1. 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.
9.2. 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.
9.4. 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.
9.5. 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.
10. PERSONAL DATA COLLECTED BY THIRD PARTIES
10.2. Our Services 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.
10.3. 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.
10.4. 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
11.1. 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.
11.2. 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.
11.3. 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?
12.1. Withdrawing Consent
(b) You understand that, Your withdrawal of Consent will not affect the lawfulness of our processing of data which You agreed before withdrawing Consent.
(c) However, Your withdrawal of Consent means that we will not be able to continue providing the Services 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.
12.2. Correct or request to correct, provide or delete Personal Data
(c) 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.
(d) 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.
(e) 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.
(f) We reserve the right to refuse to provide or delete Your Personal Data in the cases prescribed by law.
13. ADDITIONAL PROVISIONS FOR EU USERS ONLY
(a) 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.
(b) 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).
(a) 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.
(b) 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.
(c) 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.
13.3. Retention of Personal Data
We may retain Your Personal Data as long as needed to provide services or products to You, or as required or permitted by applicable laws, such as game online, tax and accounting laws or for the exercise or defense of legal claims. If You make a request for erasure of Your Personal Data and we determine that there is a valid basis for Your request, we will endeavor to delete the Personal Data within 30 days from the date You request and end the aforementioned Retention Term, or inform You if it will take longer.
13.4. 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.
13.5. Restriction of Processing for Storage Only
You have a right to request that we restrict the Process Personal Data for storage purposes only, where:
(a) You believe the Personal Data is not accurate, for the period it takes for us to verify whether the Personal Data is accurate;
(b) We wish to delete the Personal Data but You want us to just store it instead;
(c) 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
(d) 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.
13.6. 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.
13.7. 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. WHERE TO STORAGE PERSONAL DATA AND TRANSFER TO OTHER COUNTRIES
14.1. 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.
14.2. For EU users' Personal Data, it will be in accordance with the provisions of Article 13 of this Policy.
15. QUESTIONS, RESPONSES OR CONTACT TO VNG
Last updated in June 2023