DATED: 22 October 2024
a. The Privacy Policy you are reading is brought to you by KINH THUAN COMPANY LIMITED. In this document, when we refer to "the Company," "we," "our," or "us," we are talking about the specific entity within KINH THUAN COMPANY LIMITED that is in charge of handling your data.
b. Our commitment to safeguarding your privacy is unwavering. We value the trust our customers place in us. This Privacy Policy (the "Policy") is designed to explain the collection, purpose, and security measures surrounding your personal data. We are dedicated to fulfilling our obligations under all relevant global data privacy laws, including but not limited to the General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act ("CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), and the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), as well as any provincial laws that are substantially similar.
a. Personal Data refers to any information pertaining to you, regardless of its veracity, where your identity is apparent or can be reasonably deduced from that information. When anonymized information is linked, either directly or indirectly, with Personal Data, the resulting set of information is also treated as Personal Data. Anonymized information is data that does not identify an individual and cannot be reasonably used for such identification. Aggregated information refers to data concerning groups or categories of customers that does not identify, nor can it reasonably be used to identify, a specific customer.
b. We collect two primary types of data: Personal Data and anonymized information. We may also derive a third type, aggregated information, by combining Personal Data with anonymized data.
c. The data we collect includes:
√ Your contact details, such as your given name, surname, email address, home address, and mobile or other telephone numbers;
√ Personal details, such as your gender, age, age range, or your image; account sign-in information, including your username, password, and any pictures associated with your profile; Information exchanged in a bilateral manner or within a small group, using email, mail, or other communication methods;
√ Information obtained from third parties, such as site or platform providers, regarding your use of or interest in our services;
√ Location data, including location information provided by a mobile or other device interacting with our Websites, or linked to your IP address, where processing this information is permitted by law;
√ Activity, technical, and device data regarding your use of our Game, such as the content you view, the duration of your visit to our Game, the frequency of your service use, how you first learned about our Game, your preferences, and data about your interaction with the content provided through our Game, your hardware model, device type, other unique device identifiers, operating system version, browser type, and IP address;
√ Sensitive information, such as biometric data, geolocation, driver's licenses, and financial information, to fulfill our legal and regulatory purposes.
a. When you engage with our Game, we aim to make your experience as seamless and beneficial as possible. We and our partners utilize industry-standard identifiers, such as cookies or similar technologies.
b. Our Game may employ technologies to enhance your experience. These technologies are small files placed on your computer, tablet, mobile phone, or other devices when you visit a website. They enable us to record certain pieces of information every time you visit or interact with the Game. Usage data may include, among other things, browser type, operating system, device type, an approximation of your geographic location associated with your IP address, the location of your mobile device, the page served, the time, referring URLs, and other information typically transmitted in HTTP requests. This statistical data provides us with insights into your use of the services, such as general engagement with a page, the type of content on that page, and the duration of your stay on that page. Usage data is generally non-identifying, but if the Company associates it with you as a specific and identifiable individual, the Company will treat it as Personal Data.
c. Here are examples of these technologies:
√ APIs facilitate communication between different types of software. They simplify the lives of programmers and enhance the end-user experience.
√ Cookies are small text files placed in your device's browsers to store your preferences. Most browsers allow you to block and delete cookies. However, doing so may impair the service's functionality.
√ Event tagging allows us to track actions that occur within the Game, such as application installations and purchase events. By tracking these events, we can analyze data, measure ad performance, and create audiences for ad targeting.
√ Mobile device identifiers may be shared with advertisers to identify your device for internet-based advertising. For instructions on using the advertising choice mechanisms provided by the most popular mobile operating systems, visit the NAI's Mobile Choices page.
√ Pixel tags/web beacons are snippets of code embedded in the Game that gather information about your engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a specific web page or clicked on a specific advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted upon, or forwarded.
a. We gather information in a variety of ways, as outlined below. You confirm that any contact details you provide are accurate and up to date.
b. Information you provide directly to us, including when you visit our Game, register on the Game, respond to a survey, complete a form, and engage in other activities, services, features, or resources available on our Game.
c. In addition to collecting information through our Game, we collect data from you via telephone, video, or correspondence, including email, live chat, mail, text message, or social media. All telephone or video calls between you and Company representatives may be recorded for training, quality control, and compliance purposes, and by continuing with any such call, you consent to the recording.
d. We also collect information about your use of our products and services through various technologies present when you visit our Websites, including the Game, or use our applications on third-party sites or platforms (whether or not you are logged in or registered), including cookies, flash cookies, pixels, tags, and APIs.
e. Please refer to the section titled "Personal Data Collected via Technology" for further information. Analytics tools are also employed by us to collect data, including when you visit our Game or use our applications or services on third-party sites or platforms.
f. Lastly, we utilize trusted sources to update or supplement the information you provided or that we have collected, including for the purpose of verifying or validating information (for example, postal addresses, documentation, and names).
a. The information collected is utilized to operate our Game and provide our products and services, respond to your inquiries, and fulfill all applicable regulatory requirements.
b. In accordance with applicable laws and any options made available to you, the Company may collect and use your information for the following specific purposes:
√ To deliver and manage the services you request—this includes, for instance, processing your registration, setting up and maintaining your account, including fraud prevention checks.
√ To enhance customer service and our services—information you provide helps us respond more efficiently to your customer service requests; we may use your feedback to improve our products and services.
√ To tailor user experiences—we may use aggregated information to understand how our user base utilizes the services and resources provided on our Game.
√ To communicate with you about our services, including marketing—via email, live chat, telephone, text message, mail, or social media.
√ To meet our legal and regulatory obligations—we may use the information we collect about you for regulatory compliance (including detecting, investigating, and preventing activities that violate our terms and conditions or may be illegal).
√ To offer alternative dispute resolution services—we may provide the information we collect about you to our service provider partner for the specific purpose of resolving any disputes that have not been satisfactorily resolved through our internal processes.
√ To conduct market research and analysis—to analyze how you interact with our products and services, monitor and analyze usage and activity trends, and for other research, analytical, and statistical purposes.
c. We do not engage in automated decision-making as defined by global data protection laws.
d. We may collaborate with third-party service providers to display advertising on our Game or any application accessible via our Game or to manage our advertising on other websites. Our third-party service providers may use technologies such as cookies to gather information about your activities on our Game and other websites to provide you with advertising based on your browsing activities and interests.
a. If we process your personal information for direct advertising purposes, you have the right to object to this processing at any time; this also applies to profiling, where relevant, insofar as it is related to such direct advertising.
b. You may opt-out of receiving commercial messages from us by following the instructions in those messages or by contacting Customer Support. If you object to processing for direct advertising purposes, we will cease processing your personal information for these purposes.
c. By law and subject to certain conditions, you have several rights regarding the personal information we hold about you. These rights include accessing the personal information we hold about you, object to the processing of your data, updating and correcting the information we hold about you, and withdrawing any consent you have provided. In certain circumstances, you may request that we delete the personal information we hold about you.
d. We will not discriminate against you (e.g., by denying products and services or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.
e. If you wish to use an authorized agent to exercise your rights in accordance with applicable law, we may request evidence that you have granted such an agent power of attorney or that the agent has valid written authority to exercise those rights on your behalf.
a. We have implemented physical, electronic, and operational procedures to safeguard the information we collect. We adopt appropriate data collection, storage, and processing practices, along with security measures, to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, including your username, password, transaction information, and data stored on our Game. Our security measures are regularly reviewed and updated to keep pace with technological advancements.
b. We take reasonable steps to protect your personal information from misuse, interference, or loss, as well as from unauthorized access, modification, or disclosure.
c. If we believe that a notifiable data breach has occurred, we will comply with legislative requirements to notify you of the breach and any actions taken by the Company to contain and investigate the incident.
a. We will retain your information for a duration sufficient to fulfill the purposes specified in this Privacy Policy, unless a longer retention period is mandated by law.
b. We will take reasonable measures to destroy or permanently de-identify any Personal Information when: We no longer require the Personal Information for any purpose for which it was collected or for a related purpose; and
We are not obligated by law, a regulator, or a court/tribunal order to retain the Personal Information.
a. We do not sell, trade, or rent your personal information. However, there are circumstances under which we share your personal data with the following categories of third parties:
√ Affiliates—other companies within the Company;
√ Service providers—other companies that provide services to you on our behalf; and
√ Third parties that interact with us in connection with the services we offer.
b. If data is to be shared with a third party, we require them to maintain the same protections over your data that we provide directly to you and to only perform services on our behalf. In simple terms, they are prohibited from using your personal information for purposes other than those requested by us or mandated by law.
c. We only share information with third parties in limited circumstances, including:
√ When you authorize us to share your information with third parties;
√ When providing you with products and services and informing you about important changes or developments regarding those products and services;
√ In response to lawful requests by public authorities, including to meet national security or law enforcement requirements, when ordered to do so by any regulatory body, and/or under any legal provision contained in the governing law of a specific jurisdiction;
√ When instructing and authorizing the financial institution holding a user's account to disclose any information requested by a regulator concerning the user's account;
√ To enforce our terms and conditions set forth on our Game, protect our rights and property, and the rights and property of our customers and third parties, detect fraud or other illegal activities, and comply with laws or legal processes;
√ To conduct customer due diligence, including ID verification.
a. This Privacy Policy may be updated periodically to reflect changes in our operations or regulatory requirements. We will notify you of significant changes and, where required by law, will obtain your consent. Notice may be provided by posting such changes on our Game or through other means in accordance with applicable laws.
b. Any modifications to the Privacy Policy will take effect once the updated policy is posted on our Game.
c. We encourage you to regularly check this page for any updates to stay informed about how we are protecting the personal information we collect.
d. This Privacy Policy, effective as of the last modified date indicated below, supersedes and replaces any and all previous Privacy Policies.
a. If you have specific questions regarding your personal information or how we utilize it, please reach out to our Data Protection Officer directly via email at [email protected].
