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PRIVACY POLICY

1. INTRODUCTION

1.1. Welcome to SohaGame which is operated by SOHA Company Limited and associated companies ("we" or "SohaGame").

SohaGame strictly undertakes its responsibilities related to information security in accordance with the regulations on personal data information of Vietnamese law and commits itself to respect the privacy and attention of all users to our Services.

User means the person who registers an account/provides information with us to use the Services provided by Us.

We recognize the importance of the personal data you have given us with trust and believe that we are responsible for managing, protecting, and processing your personal data appropriately. This Privacy Policy ("Privacy Policy" or "Policy") is developed to help you understand how we collect, use, disclose, and/or process the personal data you have provided to us and/or keep information about you, whether in present or in the future, as well as to help you make a wise decision before providing us with any of your personal data.

1.2. "Personal Data" or "Personal information" means data, or from such data and other information that an organization has or is likely to access, whether true or not, about an individual, through which the identity can be identified. The data collected according to section 3 of the Policy includes but is not limited to information such as name, age, date of birth, ID card, phone number, address, email, payment information, and other data information provided by you.

1.3. By using the Services, registering your account/providing your information to us means: you acknowledge and agree that you accept the methods, requirements, and/or policies described in this Privacy Policy and/or our Terms of Service, and you hereby acknowledge that you are fully aware of and fully agree to allow our collection, use, disclosure and/or processing of your personal data as described herein. If you do not agree to allow the processing of your personal data as described in this policy, please do not use our services. If we change our Privacy Policy, we will notify you by uploading those changes or the revised Privacy Policy on our website/application or other channels and you can reach them. To the extent permitted by law, your continued access, use, and exploitation of the Services is deemed to be your acknowledgment and agreement to the changes in this Privacy Policy.

1.4. This Policy, along with other notices, terms of service, contractual terms, and consent terms, applies to our collection, storage, use, disclosure, and/or processing of your personal data and is not intended to overwrite, replace, or cancel such notices or terms unless we state otherwise.

2. WHEN WILL SOHAGAME COLLECT PERSONAL DATA?

2.1. We will/may collect personal data about you:

when you register and/or use our Services, or open an account with us;
when you submit any form, including application or other forms relating to any of our products and Services, whether online or otherwise;
when you enter into any agreement or provide documents or other information in connection with your interactions with us, or when you use our products and services;
when you interact with us, such as through phone calls (which may be recorded), correspondence, fax, face-to-face meetings, social media platforms, and email, or any other forms;
when you use our services or interact with us via website/application or other channels. This includes through cookies that we may implement when you interact with our Services;
when you grant permission on your device to share information with our Services/websites/applications or other channels;
when you link your SohaGame account to your social network accounts or other external accounts or use other social network features, in accordance with the provider’s policies;
when you conduct transactions through our Services such as each time you make a payment or provide information to us to use the service or support request;
when you provide feedback or submit a complaint to us;
when you register to participate in a contest, program, or event;
when you submit your personal data to us for any reason; and/or
when you perform other activities on our Website/application or our other channels.

The above cases are not intended to list all cases and only provide some popular cases of time at which your personal data may be collected.

2.2. We may collect your information from you, associated companies, third parties, and from other sources, including but not limited to business partners (for example, payment service providers, solution providers, technical infrastructure, technology, media), credit rating agencies, units and partners providing marketing services, introduction, loyalty programs, other users of our Services or publicly available data sources or government data sources, etc.

2.3. In some cases, you may provide personal data of other individuals to us (for example family members, friends, or people in your contact list). If you provide us with their personal data, you represent and warrant that you have received their consent to process their personal data in accordance with this Policy.

3. WHAT DATA WILL SOHAGAME COLLECT?

3.1. Except as otherwise provided in this Policy, the personal data that SohaGame may collect includes basic personal data and sensitive personal data, which may be a part or all of the information as listed below:

full name;
email address;
date of birth;
address;
bank account and payment information;
phone number;
gender;
ID card;
information sent by or related to the device(s) used to access our Services;
your account information, including your contact list when agreeing to share on your device, and the people and accounts which you interact with;
written, image or audio or video content;
data information and resources created, executed, and displayed by you during the use process of our Services;
personal information issued by government or other information for the purpose of our legal review, customer identification, information verification, and/or fraud prevention;
media or communication data, for example, options of receiving promotional information from us or your third parties, options of means of communication, and history of communications with us, our service providers, and other third parties;
account information and transaction information, performance history, content or other electronic formats that you interact with when using the Service.
account names and profile pictures on social media platforms.
friends lists on social media platforms such as Facebook including but not limited to names, profile pictures of friends, etc..

The above cases are not intended to list all cases and only provide some popular cases of your personal data that may be collected.

3.2. The information you provide to us may be correct or incorrect, and we have no obligation to verify or intervene to edit your information (without your request), you are solely responsible for the accuracy, truthfulness, and legality of the information provided by you.

3.3. If you sign in to become a User of the Service through your social media account ("Social Network Account"), link your account to your Social Network Account, or use any social networking feature, we have the right to access information about you that you have voluntarily provided to your Social Network Account service provider in accordance with the policies of such service providers, and we will manage, process and use your personal data in accordance with the provisions of this Policy at all times.

3.4. If you do not want us to collect the above personal information/data, you can opt-out at any time by notifying us in writing, which means you will stop using the Service.

You can also withdraw consent, request for erasure, restrict processing, protest against processing, request to provide personal data, access or adjust the information you have provided to us through written form. However, please note that refusing, restricting, or withdrawing your permission to collect, use, or process your personal data may affect your rights when using the service.

4. COLLECT OTHER DATA

4.1. Like most other websites and mobile applications, your device sends information that may include data about you, which is recorded by a server when you use our Services. This information typically includes but is not limited to IP address, operating system of the computer/mobile device, browser type, mobile device type, mobile device characteristics, uniform device identifier (UDID), or mobile equipment identifier (MEID) of your mobile device, the referring address of the Website/mobile application (if any), the pages you have visited on our website/application and visit time and sometimes "cookie" (which can be disabled using your browser options) to help the website/application record your last visit. If you log in, this information is linked to your personal account. This information is also put into anonymous statistics to help us understand how visitors use our website/application.

4.2. Applications may collect accurate information about the address of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose, and/or process this information for one or more purposes including but not limited to location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location with other Users as part of the Services provided by our mobile applications. For most mobile devices, you can withdraw your permission for us to collect this information based on your location through your device’s settings. If you have questions about how to disable location services on your mobile device, please contact your mobile device service provider or device manufacturer.

4.3. Such as while you view, access, and use our Services/website/mobile applications, information may be sent to us (including but not limited to IP address, operating system, etc.).

5. COOKIES

5.1. From time to time we or our authorized service providers and advertising partners may use "cookies" or other features to allow us or third parties to collect or share information relating to your use of our Services or Website/mobile application. These features will help us improve our Website/mobile application and the Services provided by us, help us recommend new services and features, and/or enable us and our advertising partners to provide content that is more relevant to you. "Cookies" are identifier codes that are stored on your computer or mobile device that store data about the computer or device, how and when the Services or the Website/mobile application are used or accessed, by how many people, and to track activities in our Websites/mobile applications. We may associate cookie information with personal data. Cookies are also associated with information about what content you have selected/used the websites/mobile applications you have viewed. This information is used to track your usage activities of the service, in order to deliver content suitable for your taste, to enable advertising service partners to provide advertising services on pages through the Internet, and to perform data analysis and or to monitor the use of the Services.

5.2. You may refuse to use cookies by selecting the appropriate settings on your browser or device. However, please note that if you do this, you may not be able to use the full functionality of the Website/mobile application or our Services.

6. HOW DO WE USE THE INFORMATION YOU PROVIDE TO US?

6.1. We may collect, use, disclose, and/or process your personal data for part or all following purposes:

to review and/or process your service requests with us or payment transactions when you use our Services;
to manage, operate, provide, and/or manage your use of the Services;
to meet, process, resolve, or complete a transaction and/or meet your requirements for certain products and services and to notify you of service issues and unusual account activities;
to execute our Terms of Service;
to protect personal safety and the rights, property, or safety of others;
for the purposes of identification, verification, legal assessment, or customer identification;
to maintain and manage any software updates and/or other updates and support as may be required from time to time to ensure the smooth operation of our Services;
to address or facilitate customer service, fulfill your requests, resolve or respond to any inquiries made by you or on your behalf;
to contact you for example by telephone, text message and/or fax message, zalo, email and/or letter, or otherwise for administrative purpose and/or managing your relationship with us or your use of our Services;
to allow other users to interact or communicate with you or see some of your activities;
to conduct research, analysis, and development activities (including but not limited to data analysis, surveying, developing and/or characterizing products and services), to analyze how you use our Services, to recommend products and/or services according to your interest, to improve our Services or products and/or to improve your customer experience;
to allow other tests and surveys in order to, in addition to other activities, validate the size and composition of our target, and understand their experiences with the SohaGame's Services;
for marketing and promotional purposes, in this case, to send you via various marketing and promotional information and materials relating to the products and/or services through different means and methods of communication (including, but not limited to, products and/or services of third parties which SohaGame may cooperate or associate) which SohaGame (and/or its associated parties or related companies) may sell, market or promote, whether products or services;
to provide frequent customer programs and incentives, partners and promotional events, as well as marketing campaigns of SohaGame or associated partners;
to meet legal procedures or to comply with or according to prevailing laws, and the requests of competent state agencies or when we truly believe that the disclosure of the information is necessary, including but not limited to, meeting the required disclosure requirements for SohaGame or associated and cooperated companies;
to make statistics and research to meet requirements for reporting and/or regulatory or internal management maintenance;
to perform inquiry process and verification or other screening activities (including but not limited to background checks) in compliance with obligations under the law or a competent governmental authority, or our risk control procedures, which may be required by law or may have been applied by us;
to check our Services or SohaGame’s operations;
to prevent or investigate any actual fraudulent or suspected activity regarding our Terms of Service, fraud, illegal acts, omissions, or misconduct, whether in connection with your use of our Services, or any matter arising from your relationship with us;
to meet any confirmed threat or factual actual requirements against SohaGame or other requests related to content that violates regulations of third parties;
to store, set up a server, backup (whether for disaster recovery or otherwise) of your personal data;
to process and/or facilitate a business asset transaction that involves SohaGame as a participating party or solely involves a company or associated companies of SohaGame. "Business asset transaction" means the transactions of purchase, sale, lease, merger, consolidation, or any activities of acquisition, liquidation, or sponsorship of an organization or part of an organization or any business activities or assets of an organization;
any other purposes that we notify you at the time of obtaining your permission.

(below collectively referred to as “Purposes”)

6.2. Your consent to provide personal information and the use of our services means that you acknowledge, authorize, and agree that we may access, store, process, and disclose Your Account information and Content if required to do so by law or by order of a court or of any government agency or any management agency which have jurisdiction over SohaGame or SohaGame’s branches, associated partners or have legitimate reasons which make SohaGame believe that such access, storage or disclosure is necessary and legitimate in order to: (a) comply with legal process; (b) comply with the request from any government agency or any management agency which have jurisdiction over SohaGame or SohaGame’s relevant branches, associated partner; (c) execute our Terms of Service or this Privacy Policy; (d) respond to any complaints that is considered as a risk or is actually happening against SohaGame or relevant branches or other complaints that are considered as having any Content infringing the rights of a third party; (e) meet your requirements for customer service; or (f) protect the rights, property or personal safety of SohaGame or relevant branches, users and/or the public.

7. HOW DOES SOHAGAME PROTECT AND STORE CUSTOMER INFORMATION?

7.1. We implement various security measures and strive to ensure the safety of your personal data on our systems. User’s personal data is stored behind secure networks and can only be accessed by certain employees who have special access rights to our systems.

7.2. We will keep personal data in accordance with the laws on the protection of personal information confidentiality and/or other applicable laws. That is, we will destroy or delete identifying information from your personal data when we receive your request in accordance with prevailing laws or when we have reasonable grounds to determine that (i) the storage of such personal data no longer serves the purpose of collecting such personal data; (ii) the storage is no longer necessary for any legal or business purpose and (iii) there are no other legitimate interests in order to continue storing such personal data. If you stop using our Services, or your right to use the Services is terminated or canceled, we may continue to store, use, and/or disclose your personal data in accordance with this Policy and our obligations under the laws on protecting the confidentiality of personal information. Subject to the laws, we may safely destroy your personal data without prior notice to you.

7.3. We reserve the right to refuse to delete or destroy data in the event that your request does not comply with the prevailing laws, or due to the fact that we consider such request is for unsafe purpose, may or may be at risk of affecting our services, our associated partner or third parties.

8. DOES SOHAGAME DISCLOSE INFORMATION COLLECTED FROM VISITORS?

8.1. During business operations, we will/may need to use, process, disclose, and/or transfer your personal data to third-party service providers, agents and/or our associated or relevant companies, and/or other third parties that may be located in Vietnam or outside Vietnam, for one or more of the above Purposes, and this disclosure will be carried out in accordance with the procedure and prevailing laws. Third-party service providers, agents, and/or associated or relevant companies and/or other such third parties will process your personal data either on our behalf or on our behalf or vice versa, for one or more of the above-mentioned Purposes. We strive to ensure that our third parties and associated companies keep your personal data safe from unauthorized access, collection, use, disclosure, processing, or the same risks and only keep your personal data as long as your personal data is still necessary for the above Purposes. Such third parties include:

our parent company, subsidiary company, associated company, and relevant company;
other users of our Services for one or more of the Purposes set forth above;
contractors, agents, service providers, and other third parties we hire to support or supplement our business operations. These parties include, but are not limited to providers of administrative services or other services to us including but not limited to telecommunications companies, business partners, advertising and media companies, information technology companies, and data centers, payment intermediaries, etc.;
the management agency having jurisdiction over SohaGame or as otherwise permitted under Section 6.2;
the purchaser or other successor in the event of a merger, divestment, restructuring, reorganization, dissolution or sale, or transfer of part or all of the assets of SohaGame, whether the matter is ongoing or in bankruptcy, liquidation, or similar proceedings, where the personal data SohaGame stores about our users is included in the transferred assets; or to a partner in a business asset transaction in which SohaGame or any of its associated company and relevant company is involved in the transaction; and
third parties to whom we disclose information for one of the Purposes and who in turn will collect and process your personal data for one or more of the Purposes.

8.2. We may share information including statistical and demographic information about our users as well as information about their use of the Services with service provider partners and other associated units.

8.3. For the avoidance of doubt, where laws on protecting the confidentiality of personal information or other prevailing laws permit an organization such as us to collect, use, or disclose your personal data without your consent, such permission by law will continue to apply. In accordance with the foregoing regulations and in accordance with the prevailing laws, we may use your personal data for recognized legal grounds, including to comply with our legal obligations, to perform our contract with you, to achieve our legitimate interests and our reasons for using that data outweigh any prejudice to your data protection rights or where necessary in connection with a legal requirement.

8.4. Third parties may block or gain unauthorized access to personal data sent to or available on the website/mobile application, technologies may not function correctly or not as intended, or someone may access, abuse, or misuse information that is not our fault. Having said that, we will implement reasonable security measures to protect your personal data in accordance with the law on protecting the confidentiality of personal information; having said that, we cannot guarantee absolute security, such as in the case of unauthorized disclosure arising from malicious hacking or attacks by third parties that is not our fault.

9. CHILD INFORMATION

To parents or guardians of children, please monitor and ensure personal information, and be responsible for the children’s personal information provided to SohaGame by parents and guardians.

When a parent or guardian provides his/her information and information of a child, it means that he/she has confirmed consent to the processing of such children's information, and agrees to be governed by this Policy on behalf of the ward.

10. INFORMATION COLLECTED BY THIRD PARTIES

10.1. Our website/mobile application uses Google Analytics, a website analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files on your device, to help the Website/mobile application analyze how users use our Website/mobile application. The information generated by the cookie about your use of the Website/mobile application (including your IP address) will be sent to and stored by Google on servers in the United States. Google will use this information to evaluate your use of our Website/mobile application, compile reports on website/mobile application activity for website/mobile application operators, and provide other services related to website/mobile application activity and Internet usage. Google may also send this information to third parties where required by law, or where such third parties process the information on behalf of Google. Google will not associate your IP address with any other data kept by Google.

10.2. Our Services may use measurement tools (such as AppsFlyer, Firebase, …) (“Mobile Measurement Partner”, referred to as “MMP”). MMPs using a Software Development Kit (“SDK”) are placed on Your device to help Us monitor and optimize the provision of Services to You. Information generated by the SDK about Your use of our application (including Your IP address) will be sent to and saved by the MMP provider. MMP Provider will use this information to evaluate Your use of our Services, compile reports on application activity for developers to operate the application, and provide other services related to application operation and Internet usage.

10.3. We, and third parties, may from time to time provide downloads of software application for your use by the Website/mobile application or through the Services. These applications may privately access, and allow a third party to view, your identification information, such as your name, your User ID, your device's IP Address, or other information such as the game you are playing in any particular access session, and any cookies you may have previously installed or that have been installed for you by a software application or website/mobile application of third party. In addition, these applications may ask you to provide additional information directly to third parties. Third-party products or services provided through these applications are not owned or controlled by SohaGame. You should read the terms and other policies published by such third parties on their websites/mobile applications or elsewhere.

11. EXCLUSIONS OF LIABILITY FOR CONFIDENTIALITY OBLIGATIONS OF THIRD PARTY

11.1. We do not guarantee the security of the personal data and/or other information you provide on websites/mobile applications of third party. We implement various security measures to maintain the safety of your personal data that we keep or control. Your personal data is stored behind secure networks and can only be accessed by a limited number of individuals who have special access rights to our systems, and they have been requested to keep such personal data confidential. When you use or access your personal data, we guarantee a secure server.

11.2. To provide you with an increase in value, we may also choose other third-party websites/applications to link to. These linked sites have their own independent privacy policies and security measures. Even if such a third party is associated with us, we do not control those linked sites or other linked software, each of which has its own privacy and data collection which is separate and independent from us.

11.3. We therefore will not take responsibility or liability for the content, security measures (or lack of security measures), and the operations of other websites/mobile applications or other linked software. These linked websites/mobile applications or other software are for your convenience only and you therefore are solely responsible when accessing them. However, we are responsible for the protection within the scope of our Services.

12. WILL SOHAGAME TRANSFER YOUR INFORMATION ABROAD?

Your personal information and/or data may be transferred abroad, stored, or processed outside of your country for one or more Purposes. SohaGame will only transfer your personal data abroad in accordance with the law on the protection of personal data.

13. HOW CAN YOU WITHDRAW CONSENT, REQUEST THE RESTRICTION OF PROCESSING, PROTEST AGAINST PROCESSING, REQUEST PROVIDING PERSONAL DATA, ACCESS OR ADJUST INFORMATION YOU HAVE PROVIDED TO US?

13.1. Withdraw Consent, request restriction, protest against data processing, delete data

You may withdraw your consent, request restriction, protest, delete data in the collection, processing, use, and/or disclosure of your personal data that we are keeping or controlling by sending document or email attached with the request to us at the email address: hotro@sohagame.vn, and we will handle these requests in accordance with the Privacy Policy as well as relevant laws.

However, your withdrawal of consent, request for restriction, protest at the processing of personal data, deletion of data may mean that we will not be able to continue to provide the Services to you and we may need to end the existing relationship with you and/or the contract you entered with Us.

13.2. Request to provide Personal Data

13.2.1. You have the right to request us to provide you with your Personal Data by sending us a document or email attached with a written request to our email address: hotro@sohagame.vn. You also have the right to request us to provide your Personal Data to other organizations or individuals or of other organizations or individuals to you provided that you provide valid authorization or other documents proving the data subject’s consent as prescribed by law.

13.2.2. Your request will only be considered valid and accepted for processing when it has all the necessary information and uses the correct form as prescribed. When you request, we will send you a form for you to conduct.

13.2.3. Depending on our review from time to time, we may charge you a reasonable fee to solve and handle your request for personal data. If we charge a fee, we will notify you of the fee on a case-by-case basis, you have the right to continue to request providing data or cancel this request.

13.2.4. In case your request is valid according to the law and we are allowed to provide the data, we will notify you through appropriate communication methods regarding time and location, form of personal data provision, cost (if any), payment method and term (if any) and we will provide personal data in accordance with this notice and other procedures as prescribed under the law.

13.2.5. We reserve the right to refuse to provide your personal data in accordance with the laws on the protection of personal information confidentiality, in case such laws require and/or allow an organization to refuse to provide personal data in such cases.

13.3. Request Access or Correction of Personal Data

13.3.1. If you have registered an account with us, you may personally access and/or correct your personal data that we are keeping or controlling through the Account Settings page on the Service. If you have not registered an account with us, you may personally request access and/or correction of your personal data that we are keeping or controlling by sending a document or email attached with a written request to our email address: hotro@sohagame.vn

13.3.2. Depending on our review from time to time, we may charge you a reasonable fee to solve and handle your request for personal data. If we charge a fee, we will notify you of the fee on a case-by-case basis, you have the right to continue to request providing data or cancel this request.

13.3.3. We reserve the right to refuse to adjust your personal data in accordance with the laws on the protection of personal information confidentiality, in case such laws require and/or allow an organization to refuse to adjust personal data in such cases.

14. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US

If you have any questions, requests, or complaints about our privacy protection methods, please contact us as follows:

SOHA COMPANY LIMITED

Address: 19th Floor, Center Building Hapulico, No. 1 Nguyen Huy Tuong, Thanh Xuan Trung Ward, Thanh Xuan District, Hanoi

Email: hotro@sohagame.vn

Phone number: 1900 6639