Privacy Policy

Effective date: April 26, 2022.

CITIGO VIETNAM JSC ("CITIGO VIETNAM", "us", "we", or "our") is dedicated to protecting the privacy rights of our online users ("users" or "you"). This Online Privacy Policy ("Privacy Policy") has been crafted to inform you as to the ways we collect, store, use, and manage the information you provide in connection with any CITIGO VIETNAM game or application (hereinafter referred to as the "Service"). Please note that the scope of this Privacy Policy is limited to only information collected from CITIGO VIETNAM through use of the Service.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Definitions

Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies: Cookies are small files stored on your device (computer or mobile device).

Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User): Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

CITIGO VIETNAM is GDPR compliant

CITIGO VIETNAM's primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service.

When you install any of the CITIGO VIETNAM games or applications, we may collect and record the information you provide us voluntarily through services such as www.vk.com ("V Kontakte, VK") in accordance with the policies and terms of VK.

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

  • Your name

  • Email address

  • Cookies and Usage Data

When you access one of our VK Games. VK also provides us:

  • Your profile info

  • Your photos

  • Your friend list

  • Your communities

  • The language selected

  • The country you are playing from

In all cases of data access and collection, the information you provide will not be disclosed, rented, leased, loaned, sold, or otherwise voluntarily distributed to unaffiliated third parties and will be used solely for the purpose of providing you with and improving the Service.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Service, to improve and customise our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies: We use Session Cookies to operate our Service.

  • Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

  • Security Cookies: We use Security Cookies for security purposes.

  • Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

CITIGO VIETNAM uses the collected data for various purposes:

  • To provide and maintain our Service

  • To notify you about changes to our Service

  • To allow you to participate in interactive features of our Service when you choose to do so

  • To provide customer support

  • To gather analysis or valuable information so that we can improve our Service

  • To monitor the usage of our Service

  • To detect, prevent and address technical issues

  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), CITIGO VIETNAM legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

CITIGO VIETNAM may process your Personal Data because:

  • We need to perform a contract with you

  • You have given us permission to do so

  • The processing is in our legitimate interests and it is not overridden by your rights

  • For payment processing purposes

  • To comply with the law

Retention of Data

CITIGO VIETNAM will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

CITIGO VIETNAM will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Singapore and choose to provide information to us, please note that we transfer the data, including Personal Data, to Singapore and United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

CITIGO VIETNAM will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction

If CITIGO VIETNAM is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, CITIGO VIETNAM may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

CITIGO VIETNAM may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation

  • To protect and defend the rights or property of CITIGO VIETNAM.

  • To prevent or investigate possible wrongdoing in connection with the Service

  • To protect the personal safety of users of the Service or the public

  • To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. CITIGO VIETNAM aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us (support@citigovietnam.com) to assist you.

  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

  • The right to object. You have the right to object to our processing of your Personal Data.

  • The right of restriction. You have the right to request that we restrict the processing of your personal information.

  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

  • The right to withdraw consent. You also have the right to withdraw your consent at any time where CITIGO VIETNAM relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

  • Yandex.Metrica. Yandex.Metrica is a web analytics tool that you can use to collect data about visitors to your website and their sessions. For more information on what type of information Yandex.Metrica collects, please visit the Yandex.Metrica Privacy & Terms web page: LINK.

  • Google Analytics. Google Analytics is an analytics service provided by Google Inc. For more information on what type of information Google Analytics collects, please visit the Google Privacy & Terms web page: LINK.

  • Firebase. Firebase is an analytics service provided by Google Inc. For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: LINK.

  • GameAnalytics. GameAnalytics is provided by Game Analytics Ltd. For more information on what type of information GameAnalytics collects, please visit their Privacy Policy page: LINK.

  • Sentry. Sentry is provided by Functional Software Inc. For more information on what type of information Sentry collects, please visit their Privacy Policy page: LINK.

Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

  • VKontakte Advertising. VKontakte Advertising is provided by VK (VKontakte). If you'd like to learn more about VKontakte Advertising, please visit the Privacy Policy page of VKontakte Advertising: LINK

  • Facebook Audience Network. Facebook Audience Network is provided by Meta Platforms, Inc. If you'd like to opt-out from the Facebook Audience Network service, please visit the Facebook Audience Network Opt-out page: LINK. If you'd like to learn more about Facebook Audience Network, please visit the Privacy Policy page of Facebook Audience Network: LINK.

Behavioral Remarketing

CITIGO VIETNAM uses remarketing services to advertise on third-party websites to you after you visited our Service.

  • VKontakte Advertising. VKontakte Advertising remarketing service is provided by VKontakte Advertising.You can learn more about interest-based advertising from VKontakte Advertising by visiting this page: LINK.

For more information on the privacy practices of VK, please visit VK's Data Policy: LINK

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.

The payment processors we work with are:

  • In-App Purchases for VK Games. Their Privacy Policy can be viewed at LINK

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

The Service is not geared toward children under the age of 13 and we do not knowingly collect personal information from children under the age of 13. If we learn that a child under 13 has provided us with personal information we will delete such information from our files as quickly as possible.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, would you like to learn more about why, how, and what Personal Data we use, or to request deleting it, please contact us at support@citigovietnam.com.