1. INTRODUCTION
1.1 Studio Vega Private Limited and its affiliates and related
corporations (individually and collectively, "Studio Vega Private Limited", "we",
"us" or "our"). Studio Vega Private Limited 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 Studio Vega Private Limited
website (the "Site") (we refer to the Site and the services we
provide as described in our Site collectively as the "Services"). We
recognize the importance of the personal data you have entrusted to us and
believe that it is our responsibility to properly manage, protect and process
your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in
understanding how we collect, use, disclose and/or process the personal data
you have provided to us and/or possess about you, whether now or in the future,
as well as to assist you in making an informed decision before providing us
with any of your personal data. Please read this Privacy Policy carefully. If
you have any questions regarding this information or our privacy practices,
please see the section entitled "Questions, Concerns or Complaints?
Contact Us" at the end of this Privacy Policy.
1.2 "Personal Data"
or "personal data" means data, whether true or not, about an
individual who can be identified from that data, or from that data and other
information to which an organization has or is likely to have access. Common
examples of personal data could include name, identification number and contact
information.
1.3 By using the Services,
registering for an account with us 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.
1.4 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.
2. WHEN WILL STUDIO Vega PRIVATE LIMITED COLLECT PERSONAL DATA?
2.1 We will/may collect
personal data about you:
• when you register and/or use
our Services, Games or Site, or open an account with us;
• when you submit any form,
including, but not limited to, application forms or other forms relating to any
of our products and services, whether online or by way of a physical form;
• when you enter into any
agreement or provide other documentation or information in respect of your
interactions with us, or when you use our products and services;
• when you interact with us,
such as via telephone calls (which may be recorded), letters, fax, face-to-face
meetings, social media platforms and emails;
• when you use our electronic
services, or interact with us via our Games or Site or use our Services. This
includes, without limitation, through cookies which we may deploy when you
interact with our Games or Site;
• when you carry out
transactions through our Games or Site;
• when you provide us with
feedback or complaints;
• when you register for a
contest, for games or game specific events;
• during your gameplay; and
• when you submit your personal
data to us for any reason.
The above does not purport to
be exhaustive and sets out some common instances of when personal data about
you may be collected.
3. WHAT PERSONAL DATA WILL
STUDIO Vega PRIVATE LIMITED COLLECT?
3.1 The personal data that
Studio Vega Private Limited may collect
includes but is not limited to:
• name;
• email address;
• date of birth;
• billing address;
• bank account and payment
information;
• telephone number;
• gender;
• information sent by or
associated with the device(s) used to access our Services;
• any other information about
the user when the user signs up to use our Services, and when the user uses the
Services, as well as information related to how the user uses our Services; and
• aggregate data on content the
user engages with.
3.2 You agree not to submit
any information to us which is inaccurate or misleading, and you agree to
inform us of any inacuracies or changes to such information. We reserve the
right at our sole discretion to require further documentation to verify the
information provided by you.
3.3 If you sign up to be a
user of our Services using your social media account (“Social
Media Account”), link your account to your Social Media
Account or use any Studio Vega Private
Limited social media features, we may access information about you which 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 Policy at all times.
3.4 If you do not want us to
collect the aforementioned information/personal data, you may opt out at any
time by notifying our Data Protection Officer in writing. Further information
on opting out can be found in the section below entitled "How can you
withdraw consent, remove, request access to or modify information you have
provided to us?". Note, however, that opting out or withdrawing your
consent for us to collect, use or process your personal data may affect your
use of the Services. For example, opting out of the collection of location
information will cause its location-based features to be disabled.
4. COLLECTION OF OTHER DATA
4.1 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.
4.2 Our mobile applications
may collect precise information about the location of your mobile device using
technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process
this information for one or more purposes including, without limitation,
location-based services that you request or to deliver relevant content to you
based on your location or to allow you to share your location to other Users as
part of the services under our mobile applications. For most mobile devices,
you are able to withdraw your permission for us to acquire this information on
your location through your device settings. If you have questions about how to
disable your mobile device's location services, please contact your mobile
device service provider or the device manufacturer.
5. COOKIES
5.1 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 usage of the Services.
5.2 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.
6. HOW DO WE USE THE
INFORMATION YOU PROVIDE US?
6.1 We may collect, use,
disclose and/or process your personal data for one or more of the following
purposes:
(a) to consider and/or
process your application/transaction with us or your transactions or
communications with third parties via the Services;
(b) 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;
(c) to respond to, process,
deal with or complete a transaction and/or to fulfil your requests for certain
products and services and notify you of service issues and unusual account
actions;
(d) to enforce our Terms of
Service or any applicable end user license agreements;
(e) to protect personal
safety and the rights, property or safety of others;
(f) for identification and/or
verification;
(g) 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;
(h) to deal with or
facilitate customer service, carry out your instructions, deal with or respond
to any enquiries given by (or purported to be given by) you or on your behalf;
(i) 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. You acknowledge and agree that such communication by us could be by
way of the mailing of correspondence, documents or notices to you, which could
involve disclosure of certain personal data about you to bring about delivery
of the same as well as on the external cover of envelopes/mail packages;
(j) to inform you when
another user has sent you a private message or posted a comment for you on the
Games or Site;
(k) 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;
(l) 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 Studio
Vega Private Limited’s Services;
(m) 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 whom Studio Vega Private Limited may collaborate or tie up
with) that Studio Vega Private Limited
(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;
(n) 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 Studio Vega Private
Limited or on its related corporations or affiliates;
(o) to produce statistics and
research for internal and statutory reporting and/or record-keeping
requirements;
(p) 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;
(q) to audit our Services or
Studio Vega Private Limited’s business;
(r) to prevent or investigate
any fraud, unlawful activity, omission or misconduct, whether relating to your
use of our Services or any other matter arising from your relationship with us,
and whether or not there is any suspicion of the aforementioned;
(s) to store, host, back up
(whether for disaster recovery or otherwise) of your personal data, whether
within or outside of your jurisdiction;
(t) to deal with and/or
facilitate a business asset transaction or a potential business asset
transaction, where such transaction involves Studio Vega Private Limited as a participant or involves
only a related corporation or affiliate of Studio Vega Private Limited as a participant or involves
Studio Vega Private Limited and/or any one or
more of Studio Vega Private Limited's related
corporations or affiliates as participant(s), and there may be other third
party organizations 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
organization or a portion of an organization or of any of the business or
assets of an organization; and/or
(u) any other purposes which
we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”).
6.2 As the purposes for which
we will/may collect, use, disclose or process your personal data depend on the
circumstances at hand, such purpose may not appear above. However, we will
notify you of such other purpose at the time of obtaining your consent, unless
processing of the applicable data without your consent is permitted by the
Privacy Laws.
7. HOW DOES STUDIO Vega PRIVATE LIMITED PROTECT CUSTOMER INFORMATION?
7.1 We implement a variety of
security measures to ensure the security of your personal data on our systems.
User personal data is contained behind secured networks and is only accessible
by a limited number of employees who have special access rights to such
systems. We will retain personal data in accordance with the Privacy Laws
and/or other applicable laws. That is, we will destroy or anonymize your
personal data when we have reasonably determined that (i) the purpose for which
that personal data was collected is no longer being served by the retention of
such personal data; (ii) retention is no longer necessary for any legal or
business purposes; and (iii) no other legitimate interest warrant further
retention of such personal data. If you cease using our Services, or your
permission to use the Site, Games and/or the Services is terminated, we may
continue storing, using and/or disclosing your personal data in accordance with
this Privacy Policy and our obligations under the Privacy Laws. Subject to
applicable law, we may securely dispose of your personal data without prior
notice to you.
8. DOES STUDIO Vega PRIVATE LIMITED DISCLOSE THE INFORMATION IT
COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES?
8.1 In conducting our
business, we will/may need to disclose your personal data to our third party
service providers, agents and/or our affiliates or related corporations, and/or
other third parties, whether sited in Singapore or outside of Singapore, for
one or more of the above-stated Purposes. Such third party service providers,
agents and/or affiliates or related corporations and/or other third parties
would be processing your personal data either on our behalf or otherwise, for
one or more of the above-stated Purposes. Such third parties include, without
limitation:
• our subsidiaries, affiliates
and related corporations;
• contractors, agents, service
providers and other third parties we use to support our business. These include
but are not limited to those which provide administrative or other services to
us such as mailing houses, telecommunication companies, information technology
companies and data centres;
• 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 Studio Vega Private Limited’s
assets, whether as a going concern or as part of bankruptcy, liquidation or
similar proceeding, in which personal data held by Studio Vega Private Limited about our users is among the
assets transferred; or to a counterparty in a business asset transaction that
Studio Vega Private Limited or any of its
affiliates or related corporations is involved in; and
• third parties to whom
disclosure by us is for one or more of the Purposes and such third parties
would in turn be collecting and processing your personal data for one or more
of the Purposes.
8.2 This may require, among
other things, disclosing your gaming history and/or disclosing records showing
which games were viewed by which IP addresses. We will also share statistical
and demographic information about our users and their use of the Services with
suppliers of advertisements and programming. This would not include anything
that could be used to identify you specifically or to discover individual
information about you.
8.3 Additionally, you may
elect to export your user activity feeds as RSS feeds which may be subscribed
to by other users, which may include information regarding your game play,
installation of games, connections with other users and other information about
your account activity which is published as a feed on the Site or Games.
8.4 For the avoidance of
doubt, in the event that Privacy Laws or other applicable laws permit an
organization such as us to collect, use or disclose your personal data without
your consent, such permission granted by the laws shall continue to apply.
8.5 Third parties may
unlawfully intercept or access personal data transmitted to or contained on the
site, technologies may malfunction or not work as anticipated, or someone might
access, abuse or misuse information through no fault of ours. We will
nevertheless deploy reasonable security arrangements to protect your personal
data as required by the Privacy Laws; however, there can inevitably be no
guarantee of absolute security such as but not limited to when unauthorized
disclosure arises from malicious and sophisticated hacking by malcontents
through no fault of ours.
9. INFORMATION ON CHILDREN
9.1 The Services are not
intended for children under the age of 10. We do not knowingly collect or
maintain any personal data or non-personally-identifiable information from
anyone under the age of 10 nor is any part of our Site, Games or other Services
directed to children under the age of 10. We will close any accounts used
exclusively by such children and will remove and/or delete any personal data we
believe was submitted by any child under the age of 10.
10. INFORMATION COLLECTED BY
THIRD PARTIES
10.1 Our Site and Games use
Google Analytics, a web analytics service provided by Google, Inc.
("Google"). Google Analytics uses cookies, which are text files
placed on your device, to help the website analyze how users use our Services.
The information generated by the cookie about your use of the Services or
device (including your IP address) will be transmitted to and stored by Google
on servers in the United States. Google will use this information for the
purpose of evaluating your use of our Services, compiling reports on website
activity for website operators and providing other services relating to website
activity and Internet usage. Google 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. Google will not associate your IP address with
any other data held by Google.
10.2 We, and third parties,
may from time to time make software applications downloads available for your
use on or through the Services. These applications may separately access, and
allow a third party to view, your identifiable information, such as your name,
your User ID, your device’s IP Address or other information such as what
game you are playing during any given session, and any cookies that you may
previously have installed or that were installed for you by a third party
software application or website. Additionally, these applications may ask you
to provide additional information directly to third parties. Third party
products or services provided through these applications are not owned or
controlled by Studio Vega Private Limited.
You are encouraged to read the terms and other policies published by such third
parties on their websites or otherwise.
11. DISCLAIMER REGARDING
SECURITY AND THIRD PARTY SITES
11.1 WE DO NOT GUARANTEE THE
SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD
PARTY SITES. We do implement a variety of security measures to maintain the
safety of your personal data that is in our possession or under our control.
Your personal data is contained behind secured networks and is only accessible
by a limited number of persons who have special access rights to such systems,
and are required to keep the personal data confidential. When you place orders
or access your personal data, we offer the use of a secure server. All personal
data or sensitive information you supply is encrypted into our databases to be
only accessed as stated above.
11.2 In an attempt to provide
you with increased value, we may choose various third party websites to link
to, and frame within, the Site or Games. We may also participate in co-branding
and other relationships to offer e-commerce and other services and features to
our visitors. These linked sites have separate and independent privacy policies
as well as security arrangements. Even if the third party is affiliated with
us, we have no control over these linked sites, each of which has separate
privacy and data collection practices independent of us. Data collected by our
co-brand partners or third party web sites (even if offered on or through our
Site or Games) may not be received by us.
11.3 We therefore have no
responsibility or liability for the content, security arrangements (or lack
thereof) and activities of these linked sites. These linked sites are only for
your convenience and you therefore access them at your own risk. Nonetheless,
we seek to protect the integrity of our Site and Games and the links placed
upon each of them and therefore welcome any feedback about these linked sites
(including, without limitation, if a specific link does not work).
12. HOW CAN YOU WITHDRAW
CONSENT, REQUEST ACCESS TO OR CORRECT INFORMATION YOU HAVE PROVIDED TO US?
Withdrawing Consent
12.1 You may withdraw your
consent for the collection, use and/or disclosure of your personal data in our
possession or under our control by sending an email to our Personal Data
Protection Officer at studio 123456@gmail.com.
12.2 However, your withdrawal
of consent may mean that we will not be able to continue providing the Services
to you, and we may need to terminate your existing relationship and/or the
contract you have with us.
Requesting Access to, or
Correction of Personal Data
12.3 If you have an account
with us, you may personally access and/or correct your personal data currently
in our possession or control through the Account Settings page or tab on the
Site or Games. If you do not have an account with us, you may request to access
and/or correct your personal data currently in our possession or control by
submitting a written request to us. We will need enough information from you in
order to ascertain your identity as well as the nature of your request so as to
be able to deal with your request. Hence, please submit your written request by
sending an email to our Personal Data Protection Officer at studio 123456@gmail.com.
12.4 We may charge you a
reasonable fee for the handling and processing of your requests to access your
personal data. If we so choose to charge, we will provide you with a written
estimate of the fee we will be charging. Please note that we are not required
to respond to or deal with your access request unless you have agreed to pay
the fee.
12.5 We reserve the right to
refuse to correct your personal data in accordance with the provisions as set
out in Privacy Laws, where they require and/or entitle an organization to
refuse to correct personal data in stated circumstances.
13. QUESTIONS, CONCERNS OR
COMPLAINTS? CONTACT US
13.1 If you have any
questions, concerns or complaints about our privacy practices, please contact
us at tfofficial@totalfootballkickoff.com .