Privacy Policy

Effective Date: 4 September 2024

A. Overview

This Privacy Policy is issued on behalf ofGIANG TRU SOFTWARE COMPANY LIMITED. When we refer to "Company," "we," "us," or "our," it means the entity withinGIANG TRU SOFTWARE COMPANY LIMITED responsible for processing your data. Our commitment is to protect your privacy and ensure your trust. This document explains what personal information we collect, why we collect it, and how we secure it. We comply with all applicable data privacy laws, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act (VCDPA), the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) and any provincial substantially similar law as applicable.

B. Information We Collect

a. Personal Information, includes any data that identifies or could identify you. If anonymous data is linked with personal information, it is treated as Personal Information.

b. We gather two primary types of information—Personal Information and anonymous information—and may combine them to create aggregate data.

c. The information we collect includes:

- Contact Details: Name, email, address, and phone numbers.

- Personal Information: Gender, age, images, account login details (username, password, profile pictures).

- Communications: Information sent via email, post, or other means.

- Third-Party Data: Information from platforms or sites about your use of our services.

- Location Data: GPS or IP-based location information from your devices.

- Usage Data: Technical and activity details, such as content viewed, session duration, interaction history, device details, browser type, and IP address.

- Sensitive Information: Biometric data, geolocation, ID details, and financial information required for legal purposes.

C. Information Collected via Technology

a. Use of Industry Standard Identifiers

When you interact with our Game, we aim to provide a seamless and user-friendly experience. To achieve this, we and our partners use industry-standard identifiers, including cookies and similar technologies, to collect and process data.

b. Technologies Used to Enhance User Experience

Our Game employs various technologies, such as small files placed on your devices (computers, tablets, mobile phones), when you visit our website. These technologies enable us to gather specific information each time you visit or engage with the Game. The data collected may include your browser type, operating system, device type, approximate geographic location linked to your IP address, location of your mobile device, the specific pages you visit, time spent on those pages, referring URLs, and other information typically transmitted in HTTP requests. This data helps us understand how you use our services, such as your overall engagement, the types of content you interact with, and your duration on different pages. While this information is generally non-identifiable, if we link it to you as an identifiable individual, we will treat it as Personal Information.

c. Examples of Technologies We Use

APIs: APIs (Application Programming Interfaces) facilitate communication between different software systems, enhancing user experience by simplifying interactions between applications.

Cookies: Cookies are small text files stored in your device's browser to remember your preferences. While most browsers allow you to block or delete cookies, doing so may impact the functionality of the service.

Event Tagging: Event tagging allows us to monitor specific actions on the Game, such as app installations and purchase events. Tracking these events helps us analyze user behavior, measure ad performance, and build targeted advertising audiences.

Mobile Device Identifiers: We may share advertising identifiers linked to your mobile device or tablet (such as Apple IDFA and Google Advertising ID) with advertisers. These identifiers help deliver internet-based ads tailored to your device. For information on using advertising choice mechanisms for major mobile operating systems, visit the NAI’s Mobile Choices page.

Pixel Tags/Web Beacons: Pixel tags, also known as web beacons, are small pieces of code embedded on our Game that collect data about your interactions on a specific web page. For instance, pixels can track if a user has visited a page or clicked on an ad. We may also include web beacons in emails to understand if messages have been opened, clicked on, or forwarded.

D. How We Collect Your Information

a. Direct Collection: We collect data when you interact with our services, such as registering on our site, participating in surveys, or engaging in other activities.

b. Indirect Collection: We gather information from phone and video calls, emails, live chats, social media, and other communications. Calls may be recorded for training, quality control, and compliance.

c. Automated Collection: We use cookies, flash cookies, pixels, tags, and APIs to collect data automatically when you visit our site or use our applications. Analytics tools also help us collect information about your interactions with our services.

d. Third-Party Sources: We may also obtain information from trusted sources to validate or update the data you provide.

e. Finally, we also use trusted sources to update or supplement the information you provided, or we have collected, including in order to verify or validate information (for example, postal address, documentation and names).

E. Use of Collected Information

a. General Use

We use the information collected to operate our Game, provide our products and services, respond to your inquiries, and meet all applicable regulatory requirements.

b. Specific Purposes for Using Your Information

In line with applicable laws and your preferences, we may use your information for the following purposes:

1.Service Provision and Management: We use your information to deliver the services you request, such as processing registrations, setting up and managing your account, and conducting fraud checks.

2.Improving Customer Service and Products: Your information helps us respond more effectively to your customer service inquiries and improve our products and services based on your feedback.

3.Personalizing User Experience: We analyze aggregated information to understand how users interact with our Game and tailor the services and resources we offer.

4.Communications and Marketing: We may contact you about our services via email, live chat, phone, text, mail, or social media to keep you informed and engaged with our offerings.

5.Legal and Regulatory Compliance: Your information may be used to fulfill regulatory obligations, including detecting, investigating, and preventing activities that violate our terms or applicable laws.

6.Alternative Dispute Resolution: If internal processes do not resolve a dispute, we may share your information with a service provider partner to facilitate alternative dispute resolution.

7.Market Research and Analysis: We conduct research and analysis to understand how you interact with our products and services, monitor usage trends, and gather insights for improving user engagement and our overall offerings.

c. Automated Decision Making

We do not employ automated decision-making processes that fall under the definitions outlined in global data protection laws.

d. Advertising and Third-Party Services

We may collaborate with third-party service providers to display advertisements on our Game or manage ads on other websites. These providers may use technologies like cookies to collect information about your activities on our Game and other sites to serve ads based on your browsing history and interests.

F. Your Rights

a. Right to Object to Direct Advertising

If we process your personal information for direct advertising purposes, you have the right to object to this processing at any time. This right also applies to any profiling associated with direct advertising.

b. Opt-Out of Marketing Communications

You can opt-out of receiving marketing messages from us by following the instructions in those messages or by contacting Customer Support. If you object to the processing of your information for direct advertising purposes, we will cease processing your personal information for these purposes.

c. Additional Rights Under Data Protection Laws

You have various rights regarding the personal information we hold about you, including:

1.Right of Access: You can request access to the personal information we hold about you.

2. Right to Object: You can object to the processing of your data under certain conditions.

3. Right to Update and Correct: You have the right to update or correct any inaccurate or incomplete personal information.

4. Right to Withdraw Consent: You can withdraw any consent you have provided for data processing.

5. Right to Deletion: In certain circumstances, you can request that we delete your personal information.

d. Non-Discrimination

We will not discriminate against you for exercising any of your rights. This means we will not deny you products or services, charge different prices, or provide a different level or quality of goods or services based on your exercise of these rights.

e. Exercising Rights Through an Authorized Agent

If you wish to exercise your rights through an authorized agent, we may request proof that the agent has valid authority to act on your behalf, such as a power of attorney or other legal documentation.

G. Data Protection Measures

a. We implement physical, electronic, and procedural safeguards to protect your personal information from unauthorized access, misuse, or disclosure.

b. Our security measures are regularly reviewed and updated to keep pace with technological advances.

c. If a significant data breach occurs, we will notify you as required by applicable laws.

H. Data Retention

a. Retention Period

We will retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is mandated by applicable laws or regulations.

b. Deletion or De-identification of Information

We will take appropriate steps to securely destroy or permanently de-identify any personal information when:

1.The information is no longer needed for the purposes for which it was collected, or for any related purposes; and

2.We are not legally required, whether by law, regulatory obligation, or court/tribunal order, to retain the personal information.

I. Sharing Your Information

a. General Sharing Practices

We do not sell, trade, or rent your personal information. However, there are specific circumstances where we may share your personal data with the following categories of third parties:

1.Affiliates: Other companies within our corporate group.

2.Service Providers: Companies that perform services on our behalf, such as payment processing, customer support, or data analysis.

3.Third Parties: Entities that interact with us in connection with the services we provide.

Whenever we share your data with third parties, we ensure that they maintain the same level of protection over your information as we do. They are strictly prohibited from using your personal information for any purposes other than those requested by us or as required by law.

b. Specific Circumstances for Sharing Information

We share your information with third parties only under limited and specific circumstances, including:

1.With Your Consent: When you explicitly allow us to share your information with third parties.

2.Service Provision: To provide you with products and services or to inform you about important updates or changes to these services.

3.Legal and Regulatory Compliance: In response to lawful requests from public authorities, including national security or law enforcement requirements, or when mandated by a regulatory body or legal provisions of a particular jurisdiction.

4.Financial Institution Requests: When authorizing the financial institution managing your account to disclose information requested by a regulator concerning your account.

5.Enforcing Our Terms and Conditions: To protect our rights and property, as well as the rights and property of our customers and third parties, to detect fraud or other illegal activities, and to comply with legal or regulatory processes.

6.Customer Due Diligence: To perform necessary customer due diligence activities, including identity verification and compliance checks.

J. Updates to This Privacy Policy

a. Updates to the Policy

This Privacy Policy may be updated periodically to reflect changes in our operations or adjustments to legal and regulatory requirements. We will notify you of any significant changes, and, where legally required, we will seek your consent. Notifications of changes may be made by posting updates on our Game or through other means as required by applicable laws.

b. Effective Date of Changes

Any changes to this Privacy Policy will become effective once the updated policy is posted on our Game.

c. Staying Informed

We encourage you to review this page regularly to stay informed about how we protect the personal information we collect and to be aware of any updates or changes.

d. Supersession of Previous Policies

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

K. Contact Us

If you have questions or concerns about your personal data or this Privacy Policy, please contact our Data Protection Officer [email protected].