Privacy Policy

// Last Updated: September 1, 2025 //

1. Privacy Policy

PlayPop ("PlayPop", "we", "us", "our", or the "Platform") respects the privacy of its users ("user", "you", or "your"). This Privacy Policy explains how we collect, use, disclose, transfer, store, protect, and otherwise process your personal information when you access or use our mobile application and related services (the "Services").

Please read this Privacy Policy carefully to understand our practices regarding your personal information. If you do not agree with this Privacy Policy or our information handling practices, you may choose not to use our Services.

We process personal information in accordance with the purposes, scope, methods, and procedures described in this Privacy Policy when collecting, using, disclosing, sharing, transferring, storing, or deleting your personal information. We also implement industry-standard security measures to protect your personal information.

If you have any questions regarding your personal information, you may contact us through customer support or by email at cskh@playgate.vn.

This Privacy Policy does not apply to third-party platforms or marketplaces through which you may access, purchase, or pay for Services, including but not limited to the Apple App Store or Google Play Store. We are not responsible for the data collection practices of such third parties.

2. How We Collect and Use Your Personal Information

"Personal Information" means any information that identifies, relates to, describes, or can reasonably be associated with an identified or identifiable individual.

We collect and use your personal information only for the purposes described in this Privacy Policy.

The Services may allow you to create, upload, or share content such as text, photographs, audio recordings, profile information, and other content generated while using the Services. Depending on the features you use, we may collect and process the following information.

2.1 User Registration

When you register or log in using Facebook, Google, Apple, or other supported login methods, you acknowledge and agree that you authorize the Platform to collect certain information associated with those accounts, including your nickname and profile picture.

If you choose to upload photographs as your profile picture, you must grant the Platform permission to access your photo library. Refusing such permission will not affect other functions of the Services, but you may be unable to upload profile images.

2.2 Profile Information

To complete your user profile after registration or first login, the Platform may request that you provide information including:

• Name;
• Region settings;
• Telephone number;
• Email address; and
• Other information necessary to provide the Services.

2.3 Social Login Information

You may choose to log in using social login services such as Facebook, Apple, or Google.

When you do so, you authorize us to collect certain basic information from those services, which may include:

• Name;
• User ID;
• Username;
• Regional settings;
• Gender;
• Date of birth;
• Email address;
• Profile picture or profile picture URL; and
• Social network identifiers, where applicable.

2.4 Automatically Collected Information

When you interact with the Services, we automatically collect information relating to your device and usage of the Services, including:

• Device information;
• Browser type and language settings;
• IP address;
• Device identifiers;
• Hardware and software information;
• Usage records;
• Game-related information;
• User interaction data; and
• System operation data.

We and our partners may use technologies such as log files, software development kits (SDKs), and web beacons to collect this information.

2.5 Mobile Analytics and Device Permissions

Like many mobile applications, we use analytics tools to better understand how users interact with our Services and to improve functionality and performance.

Information collected may include:

• Frequency of use;
• Feature usage statistics;
• Aggregated usage data;
• Performance data; and
• Diagnostic information.

We generally do not use analytics information to directly identify individual users unless necessary for security, troubleshooting, fraud prevention, or as otherwise permitted by applicable law.

We generally do not associate analytics data with personally identifiable information that you provide, except where reasonably necessary for security, troubleshooting, fraud prevention, compliance with applicable law, or other legitimate operational purposes.

To ensure the secure operation of your account and the proper functioning of the Services, the Platform may request certain device permissions during installation, use, and uninstallation.

In particular, the Platform may request permission to read from and write to your device's external storage in order to:

• Generate cache files;
• Improve loading speeds for images, videos, and other content; and
• Maintain necessary system logs.

External storage generally refers to your device's SD card or equivalent storage medium.

Granting such permissions may be necessary for the full functionality of the Services. If you decline these permissions, certain features of the Services that rely on such permissions may be limited or unavailable.

Where we intend to use your personal information for purposes other than those described in this Privacy Policy, or use information collected for one purpose for another purpose, we will obtain your consent in advance as required by applicable law.

The Application may use third-party SDKs, including but not limited to:

• Firebase Analytics; and
• Firebase Crashlytics.

These SDKs collect and process information according to their respective providers' privacy policies.

Firebase Analytics is used to understand user behavior, device information, and Service operation status to improve user experience and Service quality.

Firebase Crashlytics is used to monitor application stability and collect crash reports and error information.

These SDKs may support login functions, analytics, performance monitoring, and other operational purposes.

Additional information regarding third-party SDK providers and their privacy practices may be made available through the Application or upon request.

2.6 Sharing

We only share your personal information under the following circumstances:

1. With your explicit consent;
2. Where required by applicable law;
3. With authorized service providers and business partners who are subject to strict confidentiality obligations and may only use the information for agreed purposes.

2.7 Transfer

We do not transfer your personal information to third parties except in the following situations:

1. With your explicit consent; or
2. In connection with mergers, acquisitions, reorganizations, divisions, dissolutions, or similar transactions.

In such cases, the receiving entity must continue to comply with this Privacy Policy or obtain your consent where legally required.

2.8 Public Disclosure

The Platform may display certain information that you choose to make available to other users through the Services, including:

• Nickname;
• Profile picture; and
• Other profile information displayed within the Platform.

Other users may also view information generated through your use of the Services, including:

• Nickname;
• Profile picture;
• User ID;
• Visit statistics;
• User level; and
• Related profile information.

Except as otherwise provided below, we will not publicly disclose your registration information or non-public content.

Exceptions include:

1. With your prior authorization;
2. Compliance with legal obligations;
3. Requests from competent governmental or judicial authorities;
4. Protection of public interests;
5. Protection of the lawful rights and interests of the Platform;
6. Resolution of disputes arising from the Services; and
7. Situations necessary to provide and maintain the Services.

3. International Data Transfers and Data Retention

Your personal information may be stored and processed in North America and other jurisdictions where we or our service providers operate. Where required by applicable law, we implement appropriate safeguards for cross-border data transfers.

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

Retention periods generally begin on the date the relevant information is collected and continue until such information is deleted or anonymized in accordance with this Privacy Policy and applicable law.

However, personal information may continue to be retained where necessary to:

• Resolve disputes;
• Protect lawful rights and interests;
• Comply with investigations or requests from competent authorities; or
• Fulfill legal or regulatory obligations.

4. How We Protect Personal Information

4.1 Security Measures

We implement industry-standard safeguards designed to protect personal information against unauthorized access, disclosure, use, modification, destruction, or loss.

Examples include:

• SSL encryption for data transmission;
• Encryption technologies to protect stored data;
• Security mechanisms against malicious attacks;
• Access control measures;
• Authorization management procedures; and
• Employee privacy and security training programs.

The Platform has completed the necessary Internet information service registrations in accordance with applicable laws and regulations.

4.2 Information Security Management

We maintain cybersecurity safeguards, information security management systems, and user information management procedures.

Dedicated personnel oversee the collection, use, storage, and deletion of personal information.

Technical measures include:

• Identity verification procedures;
• Access authorization controls;
• Minimum username and password requirements;
• Encrypted VPN connections for remote access; and
• Other reasonable technical safeguards.

We only retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law.

4.3 Internet Risks

Although we employ reasonable security measures, no method of transmission or storage over the Internet can guarantee absolute security.

Accordingly, we cannot guarantee that personal information will never be accessed, disclosed, altered, or destroyed without authorization.

If a personal information incident occurs due to objective circumstances beyond our reasonable control, including cyberattacks or technical failures, we will take remedial measures.

Where such incidents are caused by our failure to comply with applicable legal obligations, we will assume responsibility to the extent required by applicable law.

However, we shall not be liable for losses arising from force majeure events, including but not limited to:

• Network failures;
• Power outages;
• Server failures;
• Computer viruses;
• Hacker attacks;
• Government policies or administrative orders;
• Natural disasters;
• Social unrest; and
• Similar events beyond our reasonable control.

We will nevertheless make reasonable efforts to notify affected users and minimize adverse impacts.

4.4 Personal Information Security Incidents

In the event of a personal information security incident, we will notify affected users as required by applicable law regarding:

• The nature of the incident;
• Potential consequences;
• Measures already taken or planned;
• Recommendations to mitigate risks; and
• Available remedies.

Notifications may be made through email, letters, telephone calls, push notifications, or other appropriate means.

Where individual notification is impracticable, we will issue public announcements through reasonable and effective methods and report the incident to competent authorities where required by law.

5. Your Rights Regarding Personal Information

Subject to applicable laws and regulations, you may have the following rights regarding your personal information.

5.1 Right of Access

While your account remains active, you may access your personal information through your account settings.

You may also:

• View and update profile information;
• Change passwords;
• Supplement security information; and
• Close your account.

If you cannot access your information through available functions, you may contact customer support.

We will generally respond within fifteen (15) business days.

5.2 Right to Correction and Deletion

You may request correction of inaccurate information or request deletion of personal information where:

• Our processing violates applicable law;
• We collect or use information without proper authorization;
• Processing violates agreements between you and the Platform;
• You no longer use the Services and request account closure; or
• We cease providing Services to you.

Where required by law, we will notify relevant recipients of your deleted information.

You acknowledge that backup systems may not be updated immediately.

Personal information is primarily stored in North America or other jurisdictions providing equivalent levels of protection.

Retention periods begin from the date of collection until deletion.

However, information may continue to be retained where necessary to:

• Resolve disputes;
• Protect lawful rights and interests;
• Comply with investigations by competent authorities; or
• Fulfill legal obligations.

Where malicious use, false information, misleading content, or invalid information is identified, we reserve the right to remove such information.

You may appeal through customer support by providing supporting evidence.

6. Changes to Your Authorization

You may withdraw previously granted authorizations by contacting customer support.

We will review and respond within ten (10) business days.

Withdrawal of authorization does not affect processing previously conducted lawfully based on your consent.

You acknowledge that withdrawal may result in the inability to use some or all related Services or functions.

Such inability shall not constitute a breach by the Platform.

If you later wish to reauthorize processing, you may contact customer support, and we will reactivate applicable functions within ten (10) business days.

7. Account Termination and Data Processing

You may request account cancellation at any time through the Platform or customer support.

Following account cancellation, we will cease providing Services and delete your personal information in accordance with applicable law.

However, deletion may be delayed where:

• Disputes remain unresolved;
• Deletion could harm lawful rights and interests;
• Government investigations require retention; or
• Retention is otherwise required by law.

8. Children's Privacy

The Services are not directed to children under thirteen (13) years of age.

Certain features may require users to be at least eighteen (18) years old or the applicable age of majority in their jurisdiction.

We do not knowingly collect personal information from children under thirteen (13).

If we become aware that we have collected such information without appropriate parental or guardian consent, we will promptly delete it.

If you believe we may possess information relating to a child under thirteen (13), please contact us immediately.

9. Updates to This Privacy Policy

We may update this Privacy Policy from time to time.

Without your explicit consent, we will not reduce or restrict the rights granted to you under this Privacy Policy.

Where material changes occur, including material revisions to this Privacy Policy, we will notify users through pop-up notices, in-app notifications, or other appropriate methods and request users to review and accept the updated terms.

Material changes include, but are not limited to:

• Significant changes to our processing purposes or methods;
• Significant organizational or ownership changes;
• Significant changes regarding recipients of personal information;
• Significant changes to your rights and methods of exercising them;
• Changes to responsible departments or complaint channels; or
• Situations where privacy impact assessments indicate heightened risks.

We will retain prior versions of this Privacy Policy for your reference.

10. Contact Us

If you have any questions, comments, suggestions, complaints, or requests regarding this Privacy Policy or our processing of personal information, please contact us through our online customer service channels.

The Platform maintains a dedicated team responsible for personal information protection.

Customer support will forward relevant requests to this team for handling and response.

We generally respond within fifteen (15) business days after receiving your request.

If you are dissatisfied with our response, particularly where you believe our handling of personal information has affected your lawful rights and interests, you may also contact us at:

Email: cskh@playgate.vn

By clicking "Agree" to this Privacy Policy, you acknowledge that you have carefully read, understood, and accepted this Privacy Policy and any related authorizations described herein.