1.1. Welcome to the products and services of FunGames - the official game portal operated by Funfinity Studio Media Company Limited ("We" or "FunGames").

For the purposes of this Policy, a "User" is any individual who creates an account, provides information, or uses the products, services, games, applications, websites, or other online platforms developed and operated by us.

We value the personal data you share and regard its management, protection, and processing as a long-term responsibility. This Privacy Policy clearly explains how FunGames collects, uses, stores, shares, and protects your data, helping you make informed decisions before providing any information.

1.2. "Personal Data/Information" refers to any information, whether accurate or not, that can directly or indirectly identify an individual, or that can be combined with other data to determine identity. This may include: full name, age, date of birth, identification documents (ID card/passport), phone number, address, email, payment details, image and audio data, and other information you provide when using our services.

1.3. By using our services, registering an account, or providing information, you acknowledge that:

• You have read and understood this Policy and the related Terms of Use;
• You consent to FunGames collecting, processing, storing, and sharing your personal data as described herein;
• If you do not agree, you should stop using our services;
• This Policy may be updated, and continued use of the services constitutes your acceptance of such changes.

1.4. This Policy applies concurrently with any notices, terms, and agreements related to the collection and processing of personal data, unless otherwise specified, and does not replace or nullify them.

2.1. FunGames may collect your personal data in various circumstances, including but not limited to:

• When you register an account, activate, or use our services, games, applications, or platforms.
• When you complete and submit forms, applications, surveys, or documents (online or paper).
• When you enter into contracts, agreements, or provide documents/information for transactions or cooperation.
• When you contact us via phone (calls may be recorded), email, messages, letters, in-person meetings, social media, or other applications.
• When you access our websites/applications, including data collected through cookies or similar technologies.
• When you grant device permissions (location, contacts, images, audio, etc.).
• When you link your FunGames account with social networks or external accounts.
• When you make in-game purchases, top-ups, or request service support.
• When you submit feedback, comments, or complaints.
• When you register for or participate in events, programs, contests, or promotional campaigns.
• When you voluntarily provide information for any reason.
• When you engage in other activities on our platforms, products, services, or communication channels.

The above list is illustrative and does not cover all possible circumstances of data collection.

2.2. In addition to information you provide directly, we may also collect data from:

• Affiliates, strategic partners, payment providers, technical, infrastructure, technology, or media service providers.
• Credit rating agencies, marketing agencies, referral programs, or loyalty programs.
• Other users (e.g., when they invite you to an event or share information about you).
• Public sources or government authorities as permitted by law.

2.3. In some cases, you may provide us with another person's personal data (e.g., relatives, friends, or contacts). By doing so, you confirm that you have obtained their lawful consent and agree that FunGames may process such information in accordance with this Privacy Policy.

3.1. Unless otherwise specified, FunGames may collect both basic and sensitive personal data, including some or all of the following:

• Full name
• Email address
• Date of birth
• Permanent or temporary address
• Contact phone number
• Gender
• National ID/Passport number
• Bank account details, payment methods, and transaction history
• Device data used to access the services (IP address, device type, operating system, hardware/software information)
• User account information: contacts (if permission is granted), interaction lists
• Text, images, audio, and video content you create or provide while using the services
• Data, resources, or information generated from your activities on our platform
• Identification information issued by authorities or used for identity verification, KYC, and fraud prevention
• Communication data: marketing preferences, preferred contact methods, history of exchanges with FunGames/third parties
• Service usage history, transaction records, and digital content accessed or interacted with
• Social media account names and profile pictures
• Social media friends lists (e.g., Facebook), including display names and profile photos

This list covers common cases and does not include all data that may be collected depending on specific circumstances.

3.2. The information you provide may be accurate or inaccurate. FunGames is not obliged to verify it unless formally requested; you are responsible for the accuracy and legality of the data.

3.3. When logging in or linking your FunGames account with social networks, we may access the information you permit to share and will process it in accordance with this Policy.

3.4. You may request to stop using services, withdraw consent, delete, restrict, object to, or correct your data. However, this may affect your benefits or limit service functionality.

4.1. When accessing the services, your device automatically sends technical information (IP address, operating system, browser, device type/specifications, identifiers, referring URL, pages/features used, access time, cookies, etc.). If logged in, such data may be linked to your user profile and aggregated anonymously for analysis and service improvement.

4.2. Certain services may request access to precise location data (GPS, Wi-Fi, etc.) in order to:

• Provide location-based services
• Personalize content and recommendations
• Enable sharing of your location with other users
• Support service management and optimization

You may adjust or disable this permission in your device settings.

4.3. In addition to information you provide, the system automatically records data such as IP address, device type, operating system, and hardware/software details for the purposes of operation, security, analysis, and service enhancement.

5.1. FunGames and its partners may use cookies or similar tracking technologies to collect and share information about how you access and use the services.

Cookies help to:

• Improve website/application performance and user experience
• Recommend relevant features and services
• Personalize content and advertising
• Analyze user behavior to optimize services

A cookie is a small data file stored on your device containing identifiers and usage information. In some cases, cookie data may be linked with personal information to display relevant content and support statistical analysis.

5.2. You may manage or refuse cookies through your browser or device settings. However, disabling cookies may cause certain features or services to function incompletely.

6.1. FunGames may collect, use, share, and process personal data for the following purposes:

• Providing, operating, maintaining, and upgrading services, applications, and websites
• Processing transactions, payments, and orders; notifying changes or account incidents
• Identity verification, KYC, risk management, fraud prevention, and violation investigations
• Customer support, handling complaints, and account management via communication channels
• Enabling users to connect and interact within the system
• Data analysis, surveys, research, product development, and optimization
• Marketing, promotions, loyalty programs, events, and communications
• Complying with laws, preparing internal reports, and responding to government requests
• Storing, backing up, and securing data; restoring data in case of incidents
• Supporting corporate transactions (mergers, acquisitions, restructuring)
• Any other legitimate purposes notified at the time consent is obtained

6.2. By providing information and using the services, you consent to FunGames accessing, retaining, processing, and disclosing your data in cases such as:

• Requests from law, courts, or competent authorities
• Compliance with legal obligations and mandatory procedures
• Enforcing service terms or this Privacy Policy
• Handling complaints, disputes, or risks of rights violations concerning the company, users, or third parties
• Responding to customer support requests
• Protecting the rights, property, and safety of the company, users, and the community

7.1. FunGames implements multiple technical and administrative measures (firewalls, multi-layered security systems) to protect personal data. Only authorized personnel may access such data when required for their work.

7.2. Personal data is stored in accordance with legal requirements. We will delete, destroy, or anonymize data when:

• You submit a valid request
• The data is no longer needed for its original purpose
• It no longer serves legitimate business purposes
• There are no other lawful grounds for retention

Even if you stop using the services or your account is terminated, we may still retain, use, or share your data under this Policy and applicable laws. In certain cases, deletion may be carried out without prior notice.

7.3. We reserve the right to refuse deletion if:

• The request violates applicable laws
• Deletion may cause risks to systems, services, partners, or other users
• The request is deemed fraudulent, harmful, or inconsistent with legitimate interests

8.1. In the course of providing services, FunGames may share personal data with:

• Parent company, subsidiaries, affiliates, and strategic partners
• Other users (where features allow)
• Contractors, agents, and service providers (e.g., telecommunications, data centers, payment, IT, advertising, media)
• Competent government authorities
• Partners or transferees in mergers, acquisitions, restructurings, or liquidations
• Other lawful third parties for the purposes previously disclosed

All recipients must apply appropriate security measures and retain the data only as long as necessary.

8.2. We may share aggregated, non-identifiable statistical, demographic, or usage data with partners or research entities.

8.3. Where permitted by law, FunGames may collect, use, or disclose personal data without your consent in order to:

• Fulfill legal obligations
• Perform a contract
• Safeguard FunGames' legitimate interests (without infringing your data protection rights)
• Respond to legal requirements or mandatory regulations

8.4. While we implement reasonable security measures, no system is completely secure; risks such as unauthorized access, cyberattacks, or technical incidents may still occur beyond our control.

FunGames respects and protects children's privacy. We do not collect personal data from individuals under 16 years of age without the lawful consent of a parent or legal guardian.

Parents/guardians must supervise their child's use of the services and are responsible for the information provided, which constitutes:

• Consent for FunGames to collect, process, and use the child's data in accordance with this Policy
• Acceptance of the terms and privacy provisions on behalf of the child

If we discover that children's data has been provided without valid consent, FunGames reserves the right to delete or anonymize such data in compliance with applicable laws.

10.1. Certain services, features, or content on FunGames may be deployed, operated, or integrated by partners or third-party providers (e.g., advertising, analytics, social media login, payment methods). When using these services, your personal data may be directly collected, stored, or processed by third parties according to their own policies.

10.2. FunGames will endeavor to select reputable partners and providers; however, we are not responsible for the collection, processing, or security of personal data by third parties. You should review the privacy policies of the relevant parties before using their services or providing information.

10.3. In case of any doubts, complaints, or discovered violations related to the use of personal data by third parties, you should contact them directly or notify FunGames for appropriate assistance.

11.1. FunGames stores data within multi-layered security systems, with access restricted to authorized personnel. Data is transmitted through secure servers; however, absolute security cannot be guaranteed on third-party platforms.

11.2. Our platforms may contain links to third-party websites or applications with their own privacy policies. Even in cases of cooperation, FunGames does not control or take responsibility for how these parties collect or process data.

11.3. FunGames bears no legal responsibility for the content or security practices of third parties. Such links are provided solely for user convenience, and you assume responsibility when accessing them. We only ensure data protection within the scope of services directly operated and controlled by FunGames.

Your personal data may be transferred, stored, or processed abroad for the purposes stated in this Policy, for example:

• Using servers or storage services located outside Vietnam
• Cooperating with overseas partners, providers, or affiliates
• When necessary to provide services, technical support, or process transactions

FunGames will only transfer personal data overseas in compliance with Vietnamese law and with appropriate security measures to prevent unauthorized access, use, disclosure, or processing.

13.1. Users have the right to make requests related to their personal data in accordance with applicable laws, including:

• Request access, view, or receive a copy of personal data
• Request correction, updating, or supplementation when data is incomplete or inaccurate
• Request deletion, anonymization, or restriction of personal data processing in cases permitted by law
• Request withdrawal of consent for personal data processing
• Object to or restrict processing that may affect legitimate rights and interests
• Request explanation of personal data processing activities
• Request information about third parties who have received or will receive personal data

13.2. Users may submit requests to exercise rights related to personal data through FunGames support channels or according to specific service guidelines.

13.3. FunGames will receive, verify, and fulfill requests in accordance with applicable laws. Some requests may be refused if they violate regulations or affect the legitimate interests of FunGames or third parties.

13.4. Exercising these rights may affect service experience or related benefits.

If you have any questions, privacy protection requests, or complaints related to how we collect, use, and secure personal information, please contact:

FUNFINITY STUDIO MEDIA COMPANY LIMITED
Address: 271 Nguyen Sinh Sac, Hoa Khanh Ward, Da Nang City, Vietnam
Email: lienhe@funfinity.vn
Phone: 1900 9022

We will receive and process your request in accordance with applicable laws and this Privacy Policy.