NCV

NCV PRIVACY POLICY

1. Introduction and Overview

This Privacy Policy is specifically designed to help users residing in Indonesia, Malaysia, Singapore, Thailand, and the Philippines understand their data privacy rights when using our Services.

·         For users residing in Vietnam, your personal data is collected, processed, and stored by VNG CORPORATION; and please refer to VNG’s Privacy Policy regarding your personal data.

We at NCV GAMES PTE. LTD., along with its subsidiaries, affiliates, and related entities (collectively referred to as "NCV," “we,” “us,” or "our"), manage your personal data in compliance with applicable laws and regulations. We take our responsibilities regarding information security and personal data protection very seriously and are committed to respecting the privacy rights of all users of our Services.

We understand the importance of the personal data you have entrusted to us and are dedicated to managing, protecting, and processing it appropriately. This Policy is intended to help you understand how NCV handles the personal data you provide and to assist you in making informed decisions when sharing it.

This Privacy Policy also serves as a notice regarding our data processing practices, provided to you before we collect or process any personal data.

We collect, use, disclose, transfer, store, and process your personal data in accordance with this Policy. This Policy applies to personal data in our possession or control, including data handled by organizations we have engaged for the purposes outlined below.

IF YOU DO NOT CONSENT TO NCV 'S COLLECTION AND PROCESSING OF CERTAIN PERSONAL DATA WHICH ARE REASONABLY REQUIRED TO PROVIDE YOU WITH OUR SERVICES (INCLUDING ACCESS TO OUR GAMES), PLEASE DO NOT ATTEMPT TO ACCESS OR OBTAIN SERVICES FROM NCV.

2. What Personal Data We Collect

We collect information about you when you use the Services, whether you’re using the Platform, playing our Games, using Streaming Service, registering an account, updating your profile, accessing content, signing up for a rewards program, making a purchase, participating in a promotion, or contacting customer support. The information we gather varies based on your interactions with us and may include, but is not limited to:

Information you Provided to Us

We collect information directly from you during the opt-in process, such as when you register for an account, sign up for communications, make a purchase, or contact us via phone, email, or other methods.

·         Contact Data: Includes your first and last name, e-mail address, phone number, and postal address.

·         Account Credentials: Includes your username, password, and authentication details.

·         Demographic Data: Includes your date of birth, gender and country.

·         Commercial or transactions information: Includes records of product or services purchased, obtained, or considered.

·         Content: Includes any content you send to us (such as feedback, questions to customer support inquiries, or bug reports), content publicly post on the service (like product reviews or blog comments), and messages exchanged with other users through our chat functionality.

·         Promotion Participation: If you Participate in a promotion and are declared a winner, we may collect your name, phone number or email, account information, and possibly identification documents (such as National Identity Card, or passport) depending on the prize.

·         Third-Party Services: When you access our Services through third-party or social media accounts, we may collect information such as your account information, nickname, and profile details.  

·         Payment Information: Includes bank account details and credit or debit card information.

·         Service Usage Information: Includes any other information about you when you sign in to use our Services, and during your use of the Services, and details related to how you interact with our Services.

·         Engagement Data: Includes aggregate data on the content, such as our Games, that You engages with.

Information Collected Automatically

We collect information automatically through cookies, server logs, and similar technologies when you play our Games, interact with our Websites, Apps, or other Services, as well as when you engage with our advertisements and communications.

·         Service Use Data: Includes data on the features you use, pages you visit, emails and advertisements you view, gameplay interactions, error records, products and Services you browse and purchase, browsing times, and your entry and exit pages.

·         Device Data: Includes information about your device type, browser, telecommunications provider, operating system, internet service provider, regional and language settings, and device identifiers such as IP address, Global Unique Identifier, and Ad ID.

·         Location Data: Includes imprecise location data (e.g., data derived from an IP address or indicating a city or postal code level) and, with your consent, precise location data (e.g., latitude/longitude). 

·         Log Files: Files that record events occurring in connection with your use of the Service.

·         Cookies: Small data files stored on your device to identify your browser. We use session cookies, which expire when you close your browser, and persistent cookies, which personalize your experience, remember your preferences, and support security features. Persistent cookies also enable advertising on and off the Service and may remain on your device for extended periods. You can control cookies through your browser settings, but disabling them may limit the functionality of our Website, Games, or Services.

·         Pixels (also known as web beacons): Code embedded in a website, video, email, or advertisement that sends information about your usage to a server. Pixels work with cookies to track browser activity and may include image pixels or JavaScript pixels. These allow us or other entities to track conversions, deliver advertising, and connect our Service with your social media accounts.

·         Device Fingerprinting: The process of analyzing and combining data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a unique “fingerprint” for identifying your browser and device.

·         App technologies: Technologies embedded in our Apps that are not browser-based and cannot be controlled via browser settings. There may include SDKs (e.g., Facebook SDK) that track usage, deliver advertising, and connect our Service with your social media accounts.  

·         Location-Identifying Technologies: Technologies used to collect your location, such as GPS, WiFi, and Bluetooth. With your consent these technologies can collect precise location data, which may be used to verify your device’s location and deliver or restrict content and advertising based on that location.

Information From Other Sources

We may receive your contact information from your friends if they invite you to play our Games or engage with our Services. We do not purchase personal information from other sources without your consent.

We may also collect information from other sources, such as affiliates, business partners, service providers, online social media services, third-parties, or publicly available sources. For example, if you log into your account through social media sign-in services (such as Facebook Connect). Where required by law, these collections will be based on your consent.

3. Use of Information

We collect and use information for business and commercial purposes as outlined in this Privacy Policy. Our purpose may include, but is not limited to:

·         Operating and Managing Services: Managing and administering your use of our Services, including account verification, software updates, and customer support.

·         Responding to Requests: Providing services you request, such as responding to comments, questions, requests, processing transactions, facilitating refunds, and offering customer support.

·         Communications: Sending technical notices, updates, security alerts, policy changes, and support messages. Contacting you via various methods (e.g., voice call, email, postal mail) to manage your relationship with us and inform you about our Services.

·         Security and Compliance: Preventing and addressing fraud, policy violations, security threats, and legal compliance. This includes responding to legal proceedings, conducting background checks, and ensuring compliance with risk management policies.

·         Monitoring and Analysis: Monitoring, analyzing, and researching trends, usage, and activities to improve our Services, products, and customer experience. This includes conducting surveys, focus groups, and data analytics.

·         Advertising and Marketing: Developing and delivering advertising, direct marketing, and communications about our and other entities’ products, offers, promotions, rewards, events, and services. This includes allowing for audits and surveys to understand our target audience. You can opt out of these marketing activities at any time, and we will respect your choice unless there are valid legal reasons to retain your data.

·         Promotions and Prizes: Conducting promotions, verifying eligibility, awarding prizes, and managing entries for competitions, events, and game tournaments.

·         Business Transactions: Facilitating and handling business asset transactions involving NCV, its subsidiaries, affiliates, or third-party organizations.

·         Data Management: Storing, hosting, and backing up your personal data, including disaster recovery. Some of your data maybe transferred overseas in compliance with relevant data protection laws, with appropriate safeguards in place.

·         Legal and Safety: Protecting personal safety and the rights, property, or safety of others, including individuals under your guardianship. You retain the right to seek legal recourse if your data protection rights are violated.

·         Non-identifiable Data Usage: We may use and share non-identifiable information (including aggregated or de-identified data) for any lawful purpose and will not attempt to re-identify such data unless required to meet legal standards.

·         Custom Purposes: Fulfilling any other purposes with your notice and consent. If you do not agree to specific purposes, please inform us, though this may impact your use of our services.

4. Disclosure and Sharing of Information

We may need to disclose your personal data to third parties, such as game developers, services providers, agents, subsidiaries, affiliates, other entities, or NCSOFT for one or more purposes outlined in this Privacy Policy. These third parties may process personal data on our behalf, including but not limited to:

·         Service Providers: We share information with service providers who assist us with payment processing, data analytics, marketing, advertising, website hosting, technical support, and other services. Service providers are contractually prohibited from using or disclosing your information for purposes other than providing services to us. However, they may use non-identifiable information (including aggregated or de-identified data) for any lawful purpose. We regularly assess and ensure that our service providers comply with our privacy policy.

·         Vendors and Other Parties: We share information with vendors and other parties for analytics and advertising purposes. These parties may act as service providers or independently decide how to process your information. Third parties may request information such as your gameplay history or records of IP addresses that have accessed the games. We may also share statistical information about your use of the Services. However, this information will not include any data that can personally identify you.

·         Affiliates: We share information with our affiliates and related entities, either as service providers or for their internal purposes.

·         Partners: We share information with partners to offer co-branded services, sell or distribute products, or engage in joint marketing activities.

·         Promotions and Prizes: Promotions and prizes may be jointly sponsored or offered by other parties. By entering a promotion or collecting a prize, you agree to the applicable terms and conditions, which may allow the sponsor or other entities to use your name, voice, or likeness for marketing purposes unless prohibited by law.

·         Public Forums: Information you make public through our services, such as profile details or posts on public boards, may be shared. You are responsible for any information you make public, and you may not be able to edit or delete it.

·         Mergers or Acquisitions: If our company, business, or assets are acquired or planned to be acquired by another company, we may share your personal information with that company during the negotiation stage.

·         Security and Legal Requirements: We may disclose information in response to legal processes, to comply with relevant laws, to defend against legal claims, or to prevent illegal activities, ensure safety, or enforce our policies.

·         Facilitating Requests: We share information at your request or direction.

·         Consent: We share information in other situations with your notice and consent.

To achieve the purposes mentioned above, some of your personal data may be transferred, stored, or processed overseas. We will only do so in compliance with applicable data protection regulations and will implement appropriate safeguards to protect your personal data. NCV will take reasonable measures to ensure that recipients are bound by legally enforceable obligations (such as laws, contracts, or binding corporate rules) to provide a level of protection comparable to that under the relevant laws.

We may disclose your Personal Data without your consent where permitted by data protection laws or other applicable laws. However, we do not rent, sell, or provide your personal information to third parties for purposes other than those described above, including completing transactions and providing the Services.

5. Other Parties

We offer parts of our Service through websites, platforms, and services operated or controlled by third parties. Additionally, we integrate technologies operated or controlled by third parties into parts of our Service.

·         Links: Our Service includes links that lead to websites, platforms, and other services not operated or controlled by us.

·         Logging In: We may allow you to log in or create an account through social media or other platforms, such as Google, Facebook, or Apple. If you choose to use such integration, we may receive information from the platform that you have authorized to share with us, such as your public profile name, email address, and internal identification information. Please note that the platform may independently collect information about you through the integration.

·         Brand Pages: We may offer our content through social media. Any information we collect from your engagement with our content (e.g., through our brand page) is treated according to this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with NCV or the Service in a tweet or post), we may use your reference in connection with our Service. Please note that the social media provider will use your information according to their privacy policy.

Please note that when you interact with other parties, including when you leave our Service, those parties may independently collect information about you and request information from you. The information collected and stored by those parties is subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

6. Analytics and Advertising

We use analytics services to help us understand how users access and use the Service. Additionally, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and platforms. For example, we place ads through Google and Facebook that you may see on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our Service (including our websites, apps, and emails) as well as into our ads displayed on other websites and platforms. Some of these tracking technologies may monitor your activities across time and services to associate the different devices you use and deliver relevant ads and/or other content to you (“Interest-based Advertising”).

We also use audience matching services (a type of Interest-based Advertising) to reach people (or similar people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our Service, allowing the ad partner to match common factors between our data and theirs. For example, we use the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

As mentioned above, vendors and other parties may act as our service providers or, in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please refer to the “Information Collected Automatically” and “Your Rights and Choices” sections.

7. Your Rights and Choices

Account Information

You can access, update, or remove certain information provided through your NCV account by visiting your account settings or contacting us via email. We may require additional information to verify your identity. We retain and use your information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

Withdrawing Consent

You may withdraw your consent for the collection, use, or disclosure of your personal data by following the methods specified on our account setup page. Withdrawal of consent will not affect the lawfulness of data processing conducted before the withdrawal. However, withdrawing consent may result in our inability to continue providing services, and it may lead to the termination of your relationship or contract with us without compensation for any losses.

Correcting or Deleting Personal Data

You can view, edit, or request deletion of your personal data via your account settings or by contacting our customer support. If you do not have an account, or for certain types of data that require separate procedures, you may request corrections or deletions through customer support. We will process such requests in accordance with our privacy policy, customer support procedures, and legal obligations.

Requests to delete your personal data may be made under specific conditions, such as if the data is no longer needed for its original purpose or if you withdraw consent. Please note that requesting deletion of your data may result in us being unable to provide further services, leading to the termination of your relationship or contract with us without compensation.

In all cases, sufficient information is required to verify your identity and the nature of your request. We may charge a reasonable fee to process your request, and we will inform you of any fees in advance.

Tracking Technology Choices

·         Cookies and Pixels: Manage cookies through your browser settings. Note that cookie management is browser-specific.

·         Do not Track: We do not respond to "Do Not Track" signals due to the lack of industry consensus.

·         App and Location Technologies: Stop data collection by uninstalling the app or resetting your device’s Ad ID. Location data collection can also be stopped by adjusting your device settings.

Disabling tracking technologies may affect service functionality.

Analytics and Interest-Based Advertising

·         Opting Out of Google Analytics: Use Google-provided tools to opt out of data collection for analytics and display advertising.

·         Opting Out of Targeted Ads: Opt out of targeted ads provided by companies in the Digital Advertising Alliance (DAA) or Network Advertising Initiative (NAI) through their respective websites.

·         Matched Ads: To opt out of using your hashed email for matched ads, contact us as specified.

Opting out applies only to the specific browser or device used for the opt-out.

Communications

·         Emails: Opt out of promotional emails by following the unsubscribe link or emailing us with "UNSUBSCRIBE" in the subject line. Non-promotional emails cannot be opted out of.

·         Push Notifications: Opt out by adjusting your device settings or uninstalling the app.

·         Text Messages and calls: Opt out by replying "STOP" to text messages or contacting us. For calls, request opt-out during the call or contact us.

Opt-outs apply only to the specific email, device, or phone number used and do not affect future subscriptions.

Special Cases for Denying Requests

Your request to delete or access personal data may be denied in special cases, such as when deletion is prohibited by law, when data is being processed by government authorities, or in emergencies related to national security, defense, or public safety. Requests may also be denied if the data is required for legal, scientific, or research purposes, or if processing is necessary to prevent or respond to criminal activities or terrorism.

8. Children

Our Services are designed for a general audience. It is important to note that it is nearly impossible for us to accurately verify whether an account registration or creation was made by a minor who misrepresented their age.

If you are a parent or guardian and believe that your child has uploaded personal information in connection with our services, or if you wish to review, modify, or delete your child’s personal information, you may contact us as outlined in the “Contact Us” section below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete the collected information unless we are legally required to retain it.

9. Data Security

We maintain reasonable security measures to protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Your personal data is stored in secure networks, accessible only by authorized personnel, and all personal data is encrypted.

While we make every effort to ensure the reliability and security of our systems, you are also responsible for using this platform and third-party websites or applications securely. We may link to third-party websites to offer additional value, but we have no control over their privacy policies or security measures, and we are not responsible for their content or security.

To help us maintain the integrity of our site and games, please contact us outlined in the “Contact Us” section below if you encounter any issues with linked sites.

10. International Transfer

As stipulated in Article 1 of this Privacy Policy, personal data of users residing in Vietnam is collected, processed, and stored by VNG CORPORATION. Therefore, Vietnamese residents should refer to VNG's Privacy Policy.

For residents of Indonesia, Malaysia, Singapore, Thailand, and the Philippines, if personal data is transferred outside of their respective countries, Article 4 generally applies. However, please refer to the specific country sections below for additional requirements that may apply.

11. Changes to this Privacy Policy

We reserve the right to revise and update this Privacy Policy at any time. Any changes will take effect immediately upon posting the updated Privacy Policy. Your continued use of our Service signifies your acceptance of the current Privacy Policy. If the changes are significant, we may send you additional notice to your email address.

12. Contact Us

If you have any concerns or questions about this Privacy Policy, or if you wish to request access to, correct, or withdraw your consent for the processing of your Personal Data, please do not hesitate to contact us and our Data Protection Officer.

·         By email: ncv_support@ncvgames.com

13. Additional Disclosures for Thailand Resident

This section applies exclusively to users residing in Thailand and take precedence over any conflicting provisions in the rest of this Privacy Policy.

Data Protection Rights

In addition to the rights outlined in Section 7 of this Privacy Policy, you have specific rights regarding your personal data under the Thai Personal Data Protection Act (PDPA). These rights are described below:

·         Right to Access: You have the right to access and request a copy of your personal data. Additionally, you have the right to request information about how your personal data was obtained, especially if it was collected without your consent.

·         Right to Data Portability: If we process your personal data in a structured, commonly used, and machine-readable format, you have the right to transfer that data to another data controller using automated means. You are also entitled to receive your personal data in such a format, unless technological limitations prevent this.

·         Right to Object: You have the right to object to the processing of your personal data if it is being processed based on our legitimate interests or for direct marketing purposes.

·         Right to Restrict Processing: You have the right to request the restriction of processing your personal data under the following circumstances:

·         Right to Lodge a Complaint: If you believe we have not complied with the PDPA in relation to your personal data, you have the right to lodge a complaint with the Personal Data Protection Commission Office (PDPC) in Thailand.

-          When you have requested the correction of your personal data and the request is pending.

-          When your personal data should be deleted, but you prefer to restrict its processing instead.

-          When the processing period has expired, but you have requested restriction due to legal reasons.

-          During the verification process when you have objected to the processing of your personal data.

Transfer of Personal Data Outside Thailand

Your personal data may be transferred outside Thailand under the following conditions, in accordance with the PDPA:

·         You have given your consent for the transfer of your personal data to a country with inadequate data protection standards.

·         The destination country has an adequate level of data protection as prescribed by the PDPC.

·         The transfer is necessary for compliance with Thai law.

·         The transfer is necessary to fulfill our contractual obligations to you.

·         The transfer is necessary to execute a contractual agreement between two entities for your

Collection of Personal Data from Minors in Thailand

We do not knowingly collect or maintain any personal data from individuals under the age of 20 residing in Thailand, nor is any part of our Site, Games, or other Services directed towards minors under the age of 20 living in Thailand. If we become aware that a minor under the age of 20 residing in Thailand has provided us, we will close any accounts associated with that minor and delete the personal data provided.

14. Additional Disclosures for Philippine Resident

This section applies exclusively to users residing in Philippine and take precedence over any conflicting provisions in the rest of this Privacy Policy.

Right to be informed

You have the right to be informed if your personal data is being processed, has been processed, or will be processed, including any involvement in automated decision-making and profiling. You shall be notified and provided with the following information before your personal data is entered into our processing system or at the earliest practical opportunity:

·         A description of the personal data to be processed.

·         The purposes for which the data is being or will be processed, including direct marketing, profiling, or for historical, statistical, or scientific purposes.

·         The legal basis for the processing if it is not based on your consent.

·         The scope and method of the processing.

·         The recipients or categories of recipients to whom the personal data may be disclosed.

·         Methods used for automated access, if allowed by you, including the extent of authorization, meaningful information about the logic involved, and the significance and expected consequences of such processing for you.

·         The identity and contact details of the personal data controller or its representative.

·         The period for which your information will be stored.

·         Your rights as a data subject, including the rights to access, correct, and object to the processing, as well as the right to lodge a complaint with the National Privacy Commission of the Philippines.

Right to Object

You have the right to object to the processing of your personal data, including processing for direct marketing, automated processing, or profiling. You shall be informed and given the opportunity to withhold consent if there are any changes or amendments to the information provided to you as a data subject in the preceding section.

Right to Access

You have the right to reasonable access to the following, upon request:

·         The content of your personal data that has been processed.

·         The sources from which your personal data was obtained.

·         The names and addresses of recipients of your personal data.

·         The manner in which your data was processed.

·         The reasons for disclosing your personal data to recipients, if applicable.

·         Information about automated processes where your data will be, or is likely to be, used as the sole basis for any decision that significantly affects you.

·         The date when your personal data was last accessed and modified.

·         The designation, name or identity, and address of the personal information controller.

Right to Erasure or Blocking

You have the right to suspend, withdraw, or request the blocking, removal, or destruction of your personal data from the personal information controller’s records. The personal information controller may notify third parties who have previously received such processed personal information. This right can be exercised upon discovery and substantial proof of any of the following:

·         The personal data is incomplete, outdated, false, or unlawfully obtained.

·         The personal data is being used for purposes not authorized by you.

·         The personal data is no longer necessary for the purposes for which it was collected.

·         You withdraw your consent or object to the processing, and there is no other legal basis or overriding legitimate interest for the processing.

·         The personal data concerns private information that is prejudicial to you unless justified by freedom of speech, expression, or the press, or is otherwise authorized.

·         The processing is unlawful.

·         The personal information controller or processor has violated your rights.

Right to Damages

You have the right to lodge a complaint with the National Privacy Commission and, where appropriate, seek compensation for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data, taking into account any violation of your rights and freedoms as a data subject.

Right to Data Portability

Where your personal data is processed by electronic means and in a structured and commonly used format, you have the right to obtain a copy of such data in an electronic or structured format that is commonly used, enabling further use by you. The exercise of this right is primarily focused on ensuring your control over your personal data when it is processed based on consent or contract, for commercial purposes, or through automated means. The National Privacy Commission of the Philippines may specify the electronic format mentioned above, as well as the technical standards, modalities, procedures, and other rules for their transfer.