Privacy Policy

This Data Privacy Policy (the “Policy”) explains ZINGPLAY (“ZINGPLAY INTERNATIONAL PTE. LTD”, "us", "our" or "we") privacy practices with respect to your personal information throughout the entire ZINGPLAY’s services via the ZINGPLAY Portal. This Policy describes the ways we collect, store, use, and manage your personal information and data that you provide or we collect in connection with our websites or any ZINGPLAY games we provided and the rights and options available to you with respect to your personal data. This Privacy Policy is also designed to assist our users (“you”) who does not live in the European Union (the “EU”) to understand their applicable data privacy rights when they use our services. 

Who is ZINGPLAY?

Welcome to the ZINGPLAY Portal, a website run by ZINGPLAY INTERNATIONAL PTE. LTD. and its affiliates and related VNG Corporation, a leading homegrown digital ecosystem in Vietnam. ZINGPLAY is in VNG Corporation's core business: online games; we provide games on both the mobile platform and website. For more information about ZINGPLAY, you may visit our website.

ZINGPLAY takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all users of our ZINGPLAY games (“Games”) and website (the "Site") (we refer to the Games, Site and the services we provide collectively as the "Services").

By using the Services or visiting our Site, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein.

IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR GAMES OR SITE. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on the Site. We reserve the right to amend this Privacy Policy at any time.

 

Purpose of Data Processing.

Your data is collected, processed, used and shared by ZINGPLAY throughout our Services for the purpose of serving you targeted and personalized improvements based on your profile. When we share your data with third parties (Advertisers, Business Partners and/or Data Partners) we will contractually obligate them to use the data only for the Purpose detailed in Section 8 below, other than if they represent that they can use it other purposes subject to your consent or another lawful basis.

You can request us to stop or restrict processing your personal data for advertising and marketing purposes – one of your opt-out rights detailed in Section 11 below, by contacting our support at support@zingplay.com and we will do our best to accommodate your request.

Please note that, when our developer or publisher (directly or indirectly) provides advertising/ promotions to you may be optimized and/or customized for you to improve your experience with the app. Therefore, in case you wish to stop our data processing for advertising and marketing purposes, it may result in your service experience not being the best and upgrading over time.

 

ZINGPLAY Data Processing.

ZINGPLAY may be a controller or processor of your personal data, considering the way data is collected by or through each Data Source and its usage by us or each of our Advertisers, Business Partners or Data Partners.

You hereby agree to the use of: (a) electronic means to consent to and complete this Policy and to provide you with any notices given pursuant to this Policy; and (b) electronic records to store information related to this Policy.

 

Our Privacy Policy.

Section

Content

Information we collect directly or indirectly from you

We will collect, process, use and share (pursuant to this Policy) the following data if available to us: your name (as your ID or birth certificate, in case you are not old enough to be issued with an ID card), gender and age (if shared with us to identify your age is suitable for the Game you want to participate in), some contact information to support or send event gifts during use of our Services (as your billing address or place of residence, telephone number or your marital status) and aggregate data on content the user engages with.

 

You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify the information provided by you.

 

If you sign up to be a user of our Services using your social media account (“Social Media Account”) and link your account to your Social Media Account we may access information about you that you have voluntarily provided to your Social Media Account provider in accordance with such provider's policies, and we will manage and use such personal data in accordance with this Privacy Policy at all times.

 

Collection of other data

As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you use our Services. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our Games and Site.

 

Cookies

We may from time to time implement "cookies" or other features to allow us or third parties to collect or share information that will help us improve our Site, Games and the Services we offer, or help us offer new services and features. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your computer or device and tell us how and when the Services or website are used or visited, by how many people and to track activity within our Site and Games. We may link cookie information to personal data. Cookies also link to information regarding what items you have selected for purchase pages you have viewed, or games you have played. This information is used to keep track of your shopping cart, for example. Cookies are also used to deliver content specific to your interest and to monitor the usage of the Services.

 

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

 

Information we collect from your interaction with our advertising

When you interact with an advertising attribution, the measurement will be shared with us. We may receive post-click usage and/or activity within mobile apps or on the website provided by us.

 

The information such usage and/or activity may include purchases you make (including the amount), subscriptions you purchase and level progress (in games) will be used by us for optimizing future advertising campaigns as well for the Purpose detailed in Section 8 below.

 

Collection of Sensitive Information

ZINGPLAY DOES NOT REQUIRE NOR DOES IT KNOWINGLY OR INTENTIONALLY COLLECT OR SOLICIT ANY SENSITIVE INFORMATION FROM OR OF USERS.

 

Children’s Privacy

ZINGPLAY only collects personal information from children in compliance with applicable law.

 

If you know or have any reason to believe that a Child has shared any Personal Information with us without sufficient consent as required by applicable law, please contact us at support@zingplay.com and we will take steps to ensure that such personal information is only processed with all the consents required by law .

 

What kind of personal data processing do we perform?

ZINGPLAY’s Data Processing is one or more activities such as collection, recording, analysis, confirmation, storage, disclosure, access, retrieval, encrypt, decrypt, copy, share, transmit, delete, destroy personal data or other related actions.

 

Use of your information for Purposes

The information we collect will be used for the following purposes:

 

  1. to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;
  2. to manage, operate, provide and/or administer your use of and/or access to our Services, Site and Games (including, without limitation, your preferences), as well as your relationship and user account with us;
  3. to respond to, process, deal with or complete a transaction and/or to fulfill your requests for certain products and services and notify you of service issues and unusual account actions;
  4. to enforce our Terms of Service or any applicable end user license agreements;
  5. for identification and/or verification;
  6. to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
  7. to audit and track usage statistics and traffic flow, and detect fraud in connection with our Services;
  8. to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services; 
  9. to enforce this Policy and prevent unlawful activities and misuse of ZINGPLAY;
  10. to establish or exercise our rights to defend against legal claims;
  11. to allow other users to interact or connect with you, including to inform you when another user has sent you a private message or posted a comment for you on the Games or Site;
  12. to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyze how you use our Services, to improve our Services or products and/or to enhance your customer experience;
  13. to allow for advertising and other audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with ZINGPLAY’s Services;
  14. for marketing and, in this regard, to send you by various modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties with whom ZINGPLAY may collaborate or tie up with) that ZINGPLAY (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies;
  15. to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on ZINGPLAY or on its related corporations or affiliates;
  16. to protect the rights or property of ZINGPLAY or third parties;
  17. to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
  18. to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
  19. to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
  20. to store, host, back up (whether for disaster recovery or otherwise) your personal data, whether within or outside of your jurisdiction;
  21. to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves ZINGPLAY as a participant or involves only a related corporation or affiliate of ZINGPLAY as a participant or involves ZINGPLAY and/or any one or more of ZINGPLAY 's related corporations or affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
  22. to take any action in any case of dispute involving you with respect to ZINGPLAY; and
  23. any other purposes which we notify you of at the time of obtaining your consent. (collectively, the “Purposes”).

 

Sharing Data with third parties

We may share your data (or part of it) or process your data without your prior consent in accordance with the following:

 

  1. If you have breached the terms or this Policy, abused your rights to use the Services, or violated any applicable law, or in any other case of dispute, or legal proceeding of any kind involving you with respect to the Services, your information may be shared with competent authorities and with any third party, as may be required;
  2. In the event of an emergency, the relevant personal data should be immediately processed to protect the life and health of the data subject or others;
  3. We may share information that we collect or obtain through the Services with the relevant authorities, entities or persons if we are required by law to share or disclose your information in accordance with applicable law.
  4. Personal identifiable information may be shared with, or transferred to (i) our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly; “Affiliates”); (ii) our contractors, agents, service providers and other third parties that we hire or have a contractual relationship to support our business (such as postal companies, telecommunication companies, information technology companies and data centers etc.); (iii) a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of ZINGPLAY’s assets, if any; would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes, but their use of such information must comply with this Policy;

 

In any case other than the above mentioned in this Policy, your personally identifiable information will be shared with others only if you provide your consent.

 

Non-personal and/or anonymized data

We may collect, process and use non-personal and/or anonymized data, which does not identify you personally (which includes personal data which has been further anonymized). Such non-personal and/or anonymized data may be collected, processed and used by us in any way, including by posting, disseminating, transmitting, sharing or otherwise communicating or making it available to third parties.

 

For example: (i) we may use your data, after deleting your identification, for market research purposes; and (ii) we develop and apply the measurement software development kit for the purpose of verifying that ads were actually viewed. We do not share any personal data without your consent.

 

Data subject's rights 

You, as the data subject, have the right to have your data rectified, erased or transferred, or restrict or object to processing (“your Right(s)”).

 

Your Right

 

ZINGPLAY Action

11.1.

Consent withdraw

If the lawful basis for collection and processing of your personal information is your consent, you may withdraw your consent granted to us.

 

We will not process your data at all and (a) anonymize your data by deleting your identification; or (b) delete your personal data upon your request afterwards.

 

11.2.

Right to object

You may object to the processing of your personal data by us.

We may contact you if we have to verify your identity. We will exercise your Right within within 72 hours from receiving your Request or verifying your identity (as applicable). And we will (a) anonymize your data; or (b) stop sharing your data with any third party or advertisers or business partners, if any.

 

11.3.

Right to erasure

Right to request us to delete or remove the personal information collected by or shared with us. In the event that you believe that our data processing of your personal data is no longer necessary or appropriate for the purposes you previously agreed to, or you have a good faith belief that we collect and process your personal data. your data illegally.

 

We may contact you if we have to verify your identity. We will exercise your Right within within 72 hours from receiving your Request or verifying your identity (as applicable).

 

11.4.

Right to restrict data processing

You may restrict our processing of your personal data. 

We may contact you if we have to verify your identity. We will exercise your Right within within 72 hours from receiving your Request or verifying your identity (as applicable).

 

11.5.

Right to access and requests for information

You have right to access and revise all your data information or you may ask us to rectify it. 

And also, you have right to receive a copy of the data collected by or shared with us throughout ZINGPLAY system.

 

We may contact you if we have to verify your identity. We will exercise your Right within within 72 hours from receiving your Request or verifying your identity (as applicable).

 

11.6. 

Other right under applicable law

We will do our best to exercise your other rights under applicable law provided that you will also demonstrate that you have a lawful basis for the request.

 

Please note that, exercise of the above Rights will not affect the lawfulness of processing based on consent before they were exercised.

 

Exercising the data subject's rights 

You can exercise your Right(s) by sending us an email to support@zingplay.com which elaborates the Right(s) you would like to exercise (such as: “Consent Withdraw”). We may have to communicate with you in order to process your Request, including to verify your identity. By sending us a Request you hereby agree that we will communicate with you for that purpose. We are always happy to assist you.

 

Information collected by payment services provided

Our Site and Games use the payment services provided by competent third parties (“Payment Services Provider”). The Payment Services Provider will collect and use the specific payment information for the purpose of payment procedures when you use of our Services and in our Site. The Payment Services Provider may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. Third party products or services provided through these applications are not owned or controlled by ZINGPLAY. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.

 

Data Security

We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. Your Personal Data is protected from unauthorized access, use or disclosure. ZINGPLAY committed to implement all physical, technical and administrative security measures for the Services to protect your data and comply with applicable laws and industry standards. 

 

Your privacy is very important to ZINGPLAY. However, there can inevitably be no guarantee of absolute security, in any circumstance, violation of regulations on the protection of personal data is detected by us, we will immediately apply remedial measures and minimize the harm of the breach to your data.

 

Data Retention

We retain personal data we collected, in accordance and compliance with applicable laws, but in any event, we will not use your personal information for the Purpose during more than 36 months since your last logout action in the Services.

 

In any of the events detailed in Section 11 (your Right under subsection 11.1, 11.2, 11.3, 11.4) upon your request, we will (i) anonymize your data in our database; and/or (ii) delete the personal data actually collected about you whose collection and process required your consent.

 

You should note that, regulations in some countries (such as Vietnam) and territories require that service providers such as VNG are required to keep Personal Data of the user for a certain period (may be up to 02 (two) years from the last time that user uses the Service). You agree that, in this case, the provisions of the above-mentioned countries and territories shall prevail; therefore, a request to delete your Personal Data will only be possible after the end of the aforementioned retention term.

 

Transfer of data outside your territory

Data transfers outside of your territory can only be conducted in strict compliance with applicable laws. If you are a resident of a jurisdiction where transfer of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

 

Changes to The Policy

This Policy may be updated by us from time to time. Major changes will take effect 30 (thirty) days from update. Other changes will take effect 5 (five) days from update. If the Policy is amended to comply with legal requirements, the amendments will become effective immediately. The most up-to-date Policy as well as any updated to this Policy will be published and will be available on ZINGPLAY website link

 

  1. Additional information protection for users in EU countries

This addition term will apply to the extent the Services include access to personal information subject to EU Data Protection Laws. These terms shall prevail only in the event of any discrepancy in other terms of this Privacy Policy

  1. “EU Data Protection Laws” means EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995, as transposed into domestic legislation of each Member State and as amended, replaced or superseded from time to time, including by the GDPR (the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016) and any other relevant and applicable data protection laws or regulations. “EU Personal Information” means Personal Information subject to EU Data Protection Laws.
  2. ZINGPLAY complies with applicable legislation related to children’s privacy protection. Thus we do not knowingly collect information, including personal data, from children or other individuals who are not legally able to use our sites and services. If we obtain actual knowledge that we have collected personal data from a child under the age of 16 (if they are located in the EU), we will take immediate steps and promptly delete it, unless we are legally obligated to retain such data. Contact us at support@zingplay.com if you believe that we have mistakenly or unintentionally collected information from a child under the age of 16.
  3. You have full rights under Section 11 above, which means you are entitle to (i) receive from us all or a part of personal data provided to us previously, (ii) to request erasing your Information collected by us, (iii) may restrict our processing of your personal data, (iv) object to any our processing activities for your personal data and all other rights under applicable law and EU Data Protection Laws.
  4. We will protect your information as described in this Privacy Policy if your personal data is transferred to other countries. By using our Services, you consent to your personal data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Services are appropriate or available in any particular jurisdiction.
  5. You will maintain reasonable administrative, technical, and physical safeguards and comply with this EU Data Protection Laws. We will continuously monitor the risk to the protected Data and ensure that the safeguards are properly designed and maintained to prevent unauthorized access to the Protected Information Data. We will periodically ensure third-party penetration tests and other appropriate vulnerability tests are conducted, and document the effectiveness of our safeguards.

 

If you have questions, concerns or complaints? 

Contact Us

If you have any questions or comments about this Policy, please contact us via email at: support@zingplay.com 

Please be sure to include your name, address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.

 

                           

Last update: 30 June 2023