DATED: 27 August 2024

A. GENERAL OVERVIEW

a. On behalf of PHUOC AN TECHNOLOGY , this Privacy Policy is formulated, thus, any mention of "Company," "we," "us," or "our" within its confines, shall be construed as referring to the pertinent entity within PHUOC AN TECHNOLOGY entrusted with the processing of your personal data.

b. Our unwavering commitment lies in safeguarding your privacy, fostering a culture of trust among our clientele, and adhering to all prevailing global data privacy regulations. This Privacy Policy ("Policy") delves into the mechanics of how your personal information is gathered, its purpose, and the measures we take to ensure its security. We are steadfast in our compliance with regulations such as the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act (VCDPA), and the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), along with any substantially similar provincial legislations.

B. DATA COLLECTION PRACTICES

a. Personal Information encompasses any data pertaining to you, regardless of its authenticity, that either directly identifies you or can reasonably be linked to your identity. When anonymous data is coupled with Personal Information, it too is treated as Personal Information. Conversely, Anonymous Information refers to details that cannot, either directly or indirectly, identify an individual. Aggregate Information, on the other hand, is data compiled about groups or categories of customers, devoid of the ability to identify a specific individual.

b. Our data collection endeavors encompass two fundamental categories: Personal Information and Anonymous Information. Furthermore, we may synthesize these into a third type—Aggregate Information.

c. The scope of our collection includes:

· Contact particulars like your full name, email address, residential location, and mobile or alternative phone numbers;

· Personal attributes such as gender, age, age bracket, or images; account login credentials, including your username, password, and profile pictures;

· Correspondence exchanged bilaterally or within a limited group via email, postal service, or other communication means;

· Insights sourced from third parties, like website or platform providers, regarding your engagement with or interest in our services;

· Location data, including that sourced from mobile devices or other gadgets interacting with our Websites, or tied to your IP address, where legally permissible;

· Behavioral, technical, and device-specific information pertaining to your Game usage, covering viewed content, visit duration and timings, service frequency, how you discovered our Game, preferences, interaction details with Game content, hardware model, device type, unique identifiers, OS version, browser type, and IP address;

· Sensitive information, like biometric data, geolocation, driver's licenses, and financial details, to fulfill legal and regulatory obligations.

C. COLLECTION OF PERSONAL DATA THROUGH TECHNOLOGY

a. Ensuring a seamless and practical engagement with our Game is our utmost priority. Consequently, we, alongside our partners, leverage industry-recognized identifiers, akin to cookies and analogous technologies.

b. Our Game incorporates technologies to enrich your experience, comprising tiny files installed on your devices (computers, tablets, smartphones, etc.) upon website visits. These technologies enable us to log pertinent details during your visits and interactions with the Game. This encompasses, but is not limited to, browser specifics, OS type, device category, an approximation of your geographical location tied to your IP, mobile device whereabouts, served pages, timestamps, referrer URLs, and typical HTTP request data. The compiled statistics illuminate your service utilization patterns, like page engagement levels, content types, and dwell times. Although primarily non-identifying, should the Company associate this data with a particular individual, it will be deemed Personal Information and treated accordingly.

c. Here are illustrations of the aforementioned technologies:

· APIs: Facilitating communication between diverse software types, APIs streamline developers' work and enrich end-user experiences.

· Cookies: Tiny text files nestled in your device browsers, retaining your preferences. Many browsers offer cookie blocking and deletion options, yet this may impair service functionality.

· Event Tagging: Enables tracking of Game-related actions (e.g., app installations, purchases). It fuels analytics, ad performance measurements, and audience creation for targeted ads.

· Mobile Device Identifiers: We might share your mobile/tablet's advertising identifier (e.g., Apple IDFA, Google Advertising ID) with advertisers for internet-based advertising. Visit the NAI's Mobile Choices page for managing ad preferences on popular mobile OSs.

· Pixel Tags/Web Beacons: Embedded codes within the Game, gathering insights into your webpage interactions. They document, for instance, web page visits or ad clicks. Web beacons in emails help assess if messages are opened, acted upon, or forwarded.

D. METHODS OF INFORMATION COLLECTION

a. We adopt diverse approaches to gather information, as outlined below. You affirm the authenticity and precision of all contact details furnished.

b. Information you furnish directly, whether during Game visits, registrations, survey responses, form submissions, or interactions with our Game's activities, services, features, or resources.

c. Apart from our Game, we also collect information via phone, video, or correspondence (email, live chat, postal mail, SMS, social media). Telephone/video conversations with Company representatives may be recorded for training, quality assurance, and compliance. Continuing such calls implies your consent to recording.

d. Additionally, we monitor your product/service usage via technologies like cookies, flash cookies, pixels, tags, and APIs, activated during Website or third-party site/platform app visits (logged in or not).

e. For a comprehensive understanding, refer to the "Personal Data Collected via Technology" section below. We also utilize analytics tools to gather information, inclusive of Game visits and third-party site/platform app/service utilizations.

f. Lastly, we rely on trusted sources to update or complement your provided or collected information, verifying or validating details (e.g., postal addresses, documents, names).

E. UTILIZATION OF GATHERED INFORMATION

a. The information amassed is employed by us to operate our Game, furnish our products and services, address your inquiries, and satisfy all pertinent regulatory prerequisites.

b. Adhering to applicable laws and any options accessible to you, the Company may collect and utilize your information for the subsequent specific objectives:

· To furnish and administer the services you solicit, encompassing, for instance, processing your registration, establishing and maintaining your account, including fraud prevention checks.

· To enhance customer service and our offerings; your provided information aids in responding to your requests more efficiently; we may also utilize your feedback to improve our products and services.

· To tailor the user experience; we might employ aggregated data to comprehend how our users collectively utilize the services and resources available on our Game.

· To communicate with you regarding our services, including marketing purposes, via email, live chat, telephone, SMS, postal mail, or social media platforms.

· To adhere to our legal and regulatory duties; we may utilize your information for regulatory compliance, including detecting, investigating, and preventing activities that contravene our terms and conditions or are potentially illegal.

· To offer alternative dispute resolution services; we may share your collected information with our service provider partners for the express purpose of resolving disputes that remain unresolved through our internal mechanisms.

· To conduct market research and analysis, examining your interactions with our products and services, monitoring and analyzing usage patterns, and for other research, analytical, and statistical endeavors.

c. Our practices do not incorporate automated decision-making within the ambit of global data protection legislation.

d. We collaborate with third-party service providers to display advertisements on our Game or any application accessible through it, or to manage our advertising on external websites. These providers may employ technologies like cookies to gather insights into your activities on our Game and other websites, thereby tailoring advertisements to your browsing activities and interests.

F. RIGHTS

a. In cases where we process your personal information for direct marketing purposes, you reserve the right to object to such processing at any time; this extends to profiling, where applicable, to the extent it's linked to direct marketing.

b. You may unsubscribe from receiving commercial communications from us by adhering to the instructions within those messages or by contacting Customer Support. Upon your objection to processing for direct marketing, we shall cease processing your personal information for these purposes.

c. Recognizing your legal rights, subject to certain conditions, you possess several rights pertaining to the personal information we maintain about you. These rights encompass access to your personal information, objection to data processing, the right to update and rectify your information, and the right to withdraw any previously given consent. Under certain circumstances, you may request the deletion of your personal information held by us.

d. We pledge not to discriminate against you (e.g., by denying products and services or offering differing levels or quality of goods and services) for exercising any of your rights.

e. If you wish to appoint an authorized agent, in accordance with applicable law, to exercise your rights on your behalf, we may request evidence of your authorization, such as a power of attorney or valid written authority, empowering the agent to act on your behalf.

G. SAFEGUARDING YOUR INFORMATION

a. To safeguard the information gathered, we've implemented robust physical, electronic, and operational safeguards. We adhere to stringent data collection, storage, and processing protocols coupled with security measures that shield your personal details, login credentials, transactional data, and game-stored information from unauthorized access, manipulation, disclosure, or eradication. Our security framework undergoes periodic reviews and upgrades in tandem with technological advancements.

b. Reasonable endeavors are undertaken to shield your personal information from misuse, disruption, and loss, alongside guarding against unauthorized access, tampering, or disclosure.

c. In the event of a suspected data breach requiring notification, we adhere to legal mandates to inform you promptly and outline the measures undertaken by our company to contain and investigate the incident.

H. INFORMATION RETENTION PERIOD

a. Your information is retained for a duration necessary to fulfill the objectives outlined in this Privacy Policy, unless mandated by law for a longer retention period.

b. Reasonable measures are undertaken to destroy or permanently anonymize Personal Information when:

· it's no longer required for the original purpose of collection or a related purpose;

· retention is not legally mandated by a regulatory body, court, or tribunal.

I. SHARING YOUR INFORMATION

a. We refrain from selling, trading, or renting your personal information. However, under specific circumstances, we may share your data with:

· Affiliates within our corporate group;

· Service providers assisting us in delivering services to you;

· Third parties engaged with us in relation to our service offerings.

· In such cases, we ensure they uphold the same data protection standards as we do and solely act on our behalf, prohibiting them from using your information for purposes not authorized by us or required by law.

b. Sharing with third parties is limited to instances such as:

· when you grant us permission;

· for product/service delivery and critical updates;

· complying with lawful requests from authorities for national security or law enforcement;

· responding to regulatory or legal directives;

· authorizing financial institutions to disclose information as per regulator requests;

· enforcing our terms, safeguarding rights, detecting fraud, and adhering to legal processes;

· conducting customer due diligence, including identity verification.

J. UPDATES

a. This Privacy Policy may undergo revisions to reflect operational changes or regulatory shifts. Material alterations will be communicated to you, and where mandated by law, your consent will be sought. Notifications may be via in-game announcements or other legally compliant methods.

b. Policy updates take effect upon publication on our Game.

c. Regularly checking this page is advised to stay informed about our efforts to safeguard your personal information.

d. This Privacy Policy, effective as of the last modified date indicated below, supersedes all previous versions.

K. REACHING OUT

For queries about your personal information or its usage, kindly contact our Data Protection Officer directly via email at [email protected].