INTRODUCTION
1.1. Đua Heo is a gaming product, which may be referred to as “we” in the following document.
Đua Heo is committed to fulfilling its responsibilities regarding information security in accordance with Vietnam’s laws on personal data protection and respecting the privacy and concerns of all users of our Services.
Users refer to individuals who register an account or provide information to us to use the Services we provide.
We acknowledge the importance of the personal data you entrust to us and believe that we have a responsibility to manage, protect, and process your personal data appropriately. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to help you understand how we collect, use, disclose, and/or process the personal data you have provided to us and/or we hold about you, whether presently or in the future, and to help you make informed decisions before providing us with any of your personal data.
1.2. “Personal data” or “Personal information” means data, whether true or not, about an individual that can be identified from that data or from that data and other information that an organization has or may have access to. The data collected as per Section 3 of this Policy includes, but is not limited to, information such as name, age, date of birth, ID or Citizen Identification Card, phone number, address, email, payment information, and other data you provide.
1.3. By using the Services, registering an account, or providing your information to us, you confirm and agree that you accept the practices, requirements, and/or policies described in this Privacy Policy and/or our Terms of Service, and hereby acknowledge and agree to allow us to collect, use, disclose, and/or process your personal data as described herein. If you do not agree to the processing of your personal data as described in this Policy, please do not use our Services. If we change our Privacy Policy, we will notify you by posting such changes or the revised Policy on our website/application or through other channels accessible to you. To the extent permitted by law, your continued access to or use of the Services is considered as acknowledgment and acceptance of the changes in this Privacy Policy.
1.4. This Policy applies in conjunction with any other notices, terms of service, contractual terms, or consent terms applicable to the collection, storage, use, disclosure, and/or processing of your personal data by us, and is not intended to override, replace, or nullify such notices or terms unless explicitly stated otherwise.
WHEN DO WE COLLECT PERSONAL DATA?
2.1. We may collect personal data about you:
When you register for and/or use our Services, or open an account with us;
When you submit any forms, including application forms or other forms relating to any of our products and services, whether online or otherwise;
When you enter into any agreements or provide documents or information in connection with your interactions with us, or when you use our products and services;
When you interact with us, such as through telephone calls (which may be recorded), correspondence, faxes, face-to-face meetings, social media platforms, emails, or any other method;
When you use our Services, or interact with us via our website/application or other channels. This includes the use of cookies that we may implement when you interact with our Services;
When you grant permission on your device to share information with our Services/website/application or other channels;
When you link your Đua Heo account with your social media account or other external accounts or use other social media features, subject to the policies of those providers;
When you perform transactions through our Services, such as making payments or providing information to us for using the Services or requesting support;
When you provide feedback or submit complaints to us;
When you register to participate in a contest, program, or event;
When you provide your personal data to us for any reason; and/or
When you engage in other activities on our website/application or other channels.
The above instances are not intended to be exhaustive but highlight some common scenarios where your personal data may be collected.
2.2. We may collect your information from you, affiliated companies, third parties, and other sources, including but not limited to business partners (e.g., payment service providers, technology and media solution providers, infrastructure partners), credit rating agencies, marketing service providers, referral programs, loyalty programs, other users utilizing our Services, publicly available data, or government data sources.
2.3. In some cases, you may provide us with the personal data of other individuals (e.g., family members, friends, or contacts). By providing their personal data to us, you represent and warrant that you have obtained their consent to process their personal data under this Policy.
WHAT DATA DO WE COLLECT?
3.1. Unless otherwise specified in this Policy, the personal data we may collect includes basic and sensitive personal data, which may consist of part or all of the following information:
Full name;
Email address;
Date of birth;
Address;
Bank account and payment information;
Phone number;
Gender;
ID card or Citizen Identification Card (CCCD);
Information transmitted by or related to the device(s) used to access our Services;
Your account information, including your contact list (with your consent on your device) and the individuals or accounts you interact with;
Written, visual, or audio content, or video content;
Data, resources generated, executed, or appearing during your use of our Services;
Government-issued identity documents or other information for legal assessment, customer identification, verification, and/or fraud prevention;
Communication or correspondence data, such as your preferences for receiving advertising information from us or third parties, preferred means of communication, and communication history with us, our service providers, or other third parties;
Account usage information and transaction details, performance history, content, or other electronic formats you interact with while using our Services.
The above examples are not exhaustive but are provided as common examples of the types of personal data we may collect.
3.2. The information you provide to us may be true or untrue. We have no obligation to verify or modify your information (unless requested by you). You are solely responsible for the accuracy, honesty, and legality of the information you provide.
3.3. If you do not wish for us to collect the aforementioned personal data/information, you may opt out at any time by providing written notice to us, which will result in ceasing your use of our Services.
You may also withdraw consent, request deletion, restrict processing, object to processing, request data provision, access, or amend the information you have provided to us through written means. However, please note that refusing, restricting, or revoking our ability to collect, use, or process your personal data may affect your rights when using our Services.
COLLECTING OTHER DATA
4.1. Like most websites and mobile applications, your device sends information, which may include data about you, to a server when you use our Services. This information typically includes, but is not limited to, your IP address, the operating system of your computer/mobile device, browser type, mobile device type, mobile device characteristics, Unified Device Identifier (UDID) or Mobile Equipment Identifier (MEID) of your mobile device, the referring address of the website/mobile application (if any), the pages you visited on our website/application, the time of access, and sometimes “cookies” (which can be disabled using your browser options) to help the website/application remember your last visit. If you log in, this information is linked to your personal account. This information is also included in anonymous statistics to help us understand how visitors use our website/application.
4.2. Applications may collect precise location data from your mobile device using technologies like GPS, Wi-Fi, etc. We collect, use, disclose, and/or process this information for one or more purposes, including but not limited to providing location-based services you request, delivering content relevant to your location, or allowing you to share your location with other users as part of the services offered by our mobile applications. For most mobile devices, you can withdraw permission for us to collect such location-based information through your device settings. If you have questions about how to disable location services on your mobile device, please contact your mobile service provider or device manufacturer.
4.3. As you browse or use our Services/websites/mobile applications, information may be sent to us (including, but not limited to, IP address, operating system, etc.).
COOKIES
5.1. From time to time, we or our authorized service providers and advertising partners may use “cookies” or other features to allow us or third parties to collect or share information about your use of our Services or website/mobile application. These features help us improve the website/mobile application and the services we provide, suggest new services and features, and/or allow us and our advertising partners to deliver content that is more relevant to you. “Cookies” are identifiers stored on your computer or mobile device that record data about your computer or device, how and when Services or the website/mobile application are used or accessed, by how many people, and track activities on our website/mobile application. We may link cookie information to personal data. Cookies may also be linked to information about the pages or features you have selected or used. This information is used to monitor your use of services, deliver content tailored to your preferences, enable advertising partners to provide advertising services on pages across the Internet, and perform data analytics or track the usage of Services.
5.2. You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do so, you may not be able to use the full functionality of our website/mobile application or our Services.
HOW DO WE USE THE INFORMATION YOU PROVIDE TO US?
6.1. We may collect, use, disclose, and/or process your personal data for part or all of the following purposes:
To consider and/or process your service requests or payment transactions when you use our Services;
To manage, operate, provide, and/or administer your use of the Services;
To respond to, process, resolve, or complete a transaction and/or meet your requests for certain products and services and notify you of service issues and unusual account activities;
To enforce our Terms of Service;
To protect personal safety and the rights, property, or safety of others;
For identification, verification, legal evaluation, or customer identification purposes;
To maintain and manage software updates and/or other updates and support as needed to ensure the smooth operation of our Services;
To facilitate customer service, fulfill your requests, or address any queries or concerns submitted by you or on your behalf;
To contact you via methods such as phone calls, text messages, fax, social media, email, or other means for administrative and/or relationship management purposes related to your use of our Services;
To allow other users to interact or communicate with you or view some of your activities;
To conduct research, analysis, and development activities, including but not limited to data analytics, surveys, and product/service development, to analyze how you use our Services, introduce products and/or services tailored to your interests, and enhance the Services or improve customer experiences;
To conduct audits or surveys, including validating the size and composition of our target audience and understanding their experiences with our Services;
For marketing and advertising purposes, to send you information and promotional materials regarding products and/or services (including third-party products/services we may collaborate with) through various methods of communication;
To provide loyalty programs, partnerships, promotional events, and marketing campaigns from us or our affiliates;
To comply with legal proceedings or legal requirements from competent government authorities or when we believe that disclosure is necessary, including meeting our disclosure obligations under the law or with business affiliates;
To compile statistics and research to meet regulatory and/or internal management reporting requirements;
To perform due diligence and verification or other screening activities (including background checks) to comply with legal obligations or risk management procedures;
To audit our Services or operations;
To prevent or investigate any actual or suspected fraud, misconduct, or other illegal activities;
To address actual or potential threats or legal claims against us or violations of third-party rights;
For storage, server hosting, and backup (whether for disaster recovery purposes or otherwise) of your personal data;
To process and/or facilitate a business asset transaction involving us as a party or with our affiliates. A “business asset transaction” includes mergers, acquisitions, or other organizational transactions or reorganizations;
For any other purpose we notify you of when requesting your consent.
(Collectively referred to as the “Purposes”)
6.2. By providing your personal data and using our Services, you acknowledge, authorize, and agree that we may access, store, process, and disclose your account information and content as required by law or under orders from courts or government authorities. This may include circumstances where such actions are necessary and justified to comply with legal processes, protect public safety, and respond to claims or threats.
HOW DO WE PROTECT AND STORE CUSTOMER INFORMATION?
7.1. We implement various security measures and strive to ensure the safety of your personal data on our systems. Personal data is stored behind secure networks and is accessible only by a limited number of individuals with special access rights who are required to keep the information confidential.
7.2. We will retain personal data in compliance with the laws on personal data protection and/or other applicable laws. We will delete or anonymize personal data upon request, in accordance with legal requirements, or if retention is no longer necessary for legal, business, or legitimate purposes.
7.3. We reserve the right to refuse deletion requests if they conflict with applicable laws or compromise the safety and integrity of our Services, affiliated parties, or third parties.
INFORMATION ABOUT CHILDREN
Parents or guardians are responsible for supervising and ensuring the personal data of children they provide to us is accurate. By providing such data, they consent to the processing of the child’s information under this Policy.
THIRD-PARTY DATA COLLECTION
9.1. Our website/mobile application uses Google Analytics, a service provided by Google, Inc. Google Analytics collects cookies to analyze user behavior on our website/mobile application.
9.2. Our Services may use Mobile Measurement Partners (MMPs) such as AppsFlyer or Firebase to track and optimize service delivery. These tools collect device data to assess application performance and improve services.
9.3. We or third parties may provide downloadable software applications linked to third-party websites/applications. These third parties may access your data, including your device’s IP address or usage information.
THIRD-PARTY DATA SECURITY LIABILITY
10.1. We cannot guarantee the security of data shared on third-party websites/applications.
10.2. Linked third-party sites may have separate privacy policies and security measures. While we aim to protect your data within our Services, we are not responsible for third-party actions.
INTERNATIONAL DATA TRANSFER
Your data may be transferred, stored, or processed overseas for the specified Purposes, in compliance with applicable data protection laws.
HOW TO WITHDRAW CONSENT OR REQUEST DATA AMENDMENT?
12.1. You may withdraw consent, restrict processing, or request data deletion by providing written notice to us via email or through our official channels. However, doing so may affect the Services we provide.
12.2. Requests for data access, amendments, or provision to third parties must follow legal requirements and may incur reasonable fees.