Privacy Policy

By using a NOGAME’ App you permit the collection and use of your personal information as described in this Privacy and Security Policy and you agree with this Privacy and Security Policy (last updated in July 2018). If you do not agree with the terms of this Privacy and Security Policy, you should not use NOGAME’ Apps.

ABOUT OUR PRIVACY POLICY
1. Our products, including all our computer programs for your mobile telephone, tablet, computer or other supported device (“Device”) (each a “NOGAME’ App”), are managed and controlled by NOGAME STUDIO, of 12 Hoa Phuong, Ward 2, Phu Nhuan District, HCM, VN (“NOGAME”, “we”, “us” and “our”).
2. Our Privacy and Security Policy sets out the basis on which we process and use any personal data we collect from you or that is provided to us as a result of you downloading or using the NOGAME’ App
3. Please read the Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it.
4. We strive to comply with the United States’ Children’s’ Online Privacy Protection Act (COPPA). Please see section 6 below. To learn more about COPPA please consult this simple one-page information guide from the kidSAFE seal program: http://www.kidsafeseal.com/knowaboutcoppa.html.
5. We comply with the General Data Protection Regulation (GDPR). Please see section 7 below.
INFORMATION ABOUT YOU RECEIVED THROUGH VARIOUS APP DISTRIBUTION CHANNELS
1. We make the NOGAME’ Apps available for download via a number of channels, including websites, app stores, shops and markets (e.g. the Apple Inc. App Store and Google Inc.’s Google Play) which we decide upon from time to time (each an “App Channel”) operated by third parties (each an “App Channel Operator”).
2. While you are using NOGAME’ Apps downloaded from an App Channel, and while those NOGAME’ Apps are installed on your Device, we and/or the App Channel Operator may use cookies, unique device identifier codes (all personally identifiable information is anonymised by NOGAME) or other technology to collect and process the following information about you, and we may have access to it:
  1. information on your patterns of use of a NOGAME App, such as how long you use it for, how often you use it, and what you do or click when you are using it;
  2. the amount of content used – pages, game play or video watched – within the app each time you use it;
  3. the language through which you are using a NOGAME’ App;
  4. information about your Device, including (where available) your operating system, the anonymised unique device identifier code, information regarding the volume and status of data transmission, click-through statistics and the date and time you access portions of the NOGAME’ App; and
  5. what other NOGAME’ Apps you have installed on your Device.
3. We have no control over an App Channel Operator’s collection or use of information and cannot change what information is made available to us by an App Channel Operator by virtue of your or our use of the App Channels.
4. Your personal data is gathered from the following sources:
  1. when you provide it to us or the App Channel Operator;
  2. use of cookies, unique device identifier codes or other technology by an App Channel Operator; please refer to the terms and conditions and Privacy and Security Policy of the App Channel Operator in respect of such use; and
  3. use of cookies, unique device identifier codes or other technology by us.
5. We currently use Apple’s Vendor ID to identify your device, in accordance with Apple requirements. This ID is generated by iOS, identifies your device in the context of our NOGAME’ Apps only and allows us to gather information about you described in this Privacy Policy.
USES MADE OF THE INFORMATION
1. We use information that we have access to about you or that you give to us in the following ways:
  1. to refine and improve NOGAME’ Apps and to deliver to you and maintain high quality products;
  2. to gain insight into how customers (including you) use the NOGAME’ Apps so that we can make improvements to its usability and diagnose or fix technology problems;
  3. to balance traffic to ensure our customers receive a consistent and reliable service;
  4. to conduct research on and analysis of on our business practices and our interactions with you, with a view to improving our service and products;
  5. to comply with our legal obligations;
  6. to deliver and maintain a high quality service;
  7. to allow you to access the NOGAME’ Apps and to participate in interactive features of our services when you choose to do so; and
  8. to notify you, if we choose to do so, about changes to our services, including the NOGAME’ App.
2. Except as set out in this Privacy Policy, we do not sell, rent, share, trade or give away any of your personal information.
DISCLOSURE OF YOUR INFORMATION TO OTHER PEOPLE
1. We do not disclose personal information about you to any third party unless we have your permission (including as given in this Privacy Policy), it is a condition of our agreement with an App Channel Operator, or we believe applicable laws and regulations permit or require it.
2. You understand and agree that we may disclose your personal information to the following third parties:
  1. any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries;
  2. our professional advisors (e.g. lawyers, tax advisors);
  3. a prospective seller or buyer of any business or assets of NOGAME’ or NOGAME’ itself;
  4. a third party in order to enforce or comply with any agreement, including an agreement with an App Channel Operator; and
  5. to protect the rights, property, or safety of NOGAME’, our group of companies, or others; this includes exchanging information with third parties for the purposes of fraud protection insurance and credit risk reduction.
3. We will tell you when personal data about you may be provided to third parties by us in ways other than those explained in this Privacy Policy; you will have the option to prevent such information sharing at the time that we tell you.
4. We do not disclose personal information about you to third parties (including advertisers or marketing companies) unless you have consented to that disclosure, but we may provide them with aggregate anonymized information about users of a NOGAME’ App. You agree to these practices.
5. It may be necessary to transfer your personal information to other group companies, to App Channel Operators or to our other service providers located in countries outside of the United States of America (US). This may happen where our servers, an App Channel Operator’s servers, or suppliers and service providers are based outside of the US, or where you use our services and products while visiting countries outside of the US. You agree that we may transfer your personal data on that basis.
TIPS AND WARNINGS
1. The use by you of any App Channel is at your sole risk.
2. From time to time game publishers are the target of third parties acting illegally and masquerading as legitimate game companies. The NOGAME’ Apps will never be made available to download from sources other than from an App Channel Operator approved by us. If you are in doubt about the authenticity of any source of a NOGAME’ App, please let us know.
3. NOGAME’ Apps and the NOGAME account pages in the App Channels may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates as well as to third party websites to which we have no affiliation or connection. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or for the activities on those websites or for the actions of an App Channel Operator.
4. Care should be taken when using the third party apps or websites which you can access using the NOGAME’ App and the NOGAME account pages in the App Channel Operators. If you find any suspicious activity connected to the use of an App Channel then we suggest you contact the App Channel Operator immediately. If you find anything suspicious or encounter suspicious activity in relation to your use of a NOGAME’ App or our account then please contact us immediately at [email protected]
CHILDREN'S PRIVACY
1. Our products respect the privacy of children. We don't collect personal Information from children with our mobile applications. Our apps for children's do not show Interest-based Advertising.
2. We comply with the Children's Online Privacy Protection Act (COPPA).
3. In the event that a user identifies himself/herself as a child under the age of 13 through a support request or feedback, we will not collect, store or use and will delete in a secure manner any personal information of such a user.
4. We take care of filtering categories of sensitive and unsuitable ads for children. But rarely can an advertiser misclassify your ads, and this situation is beyond our reach.
SECURITY AND CONTROL OF YOUR PERSONAL DATA
1. Although we rely on an App Channel Operators to take care of your data, much of which we only access by viewing the data through their tools, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy and Security Policy.
2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to NOGAME; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. You acknowledge that we are not responsible for the actions of an App Channel Operator, or for any intercepted information sent via the internet, and you release us from liability in connection with any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.
ACCESS TO INFORMATION AND UPDATING, VERIFYING AND DELETING PERSONAL DATA
1. At any time, you can make a written request to have access to all the personal data information that we hold about you. We will provide this information to you and may request a small administrative charge.
2. You can modify, update or delete your inaccurate personal information at any time by contacting us at   [email protected]   or by using the contact information at the bottom of this Privacy Policy.
CHANGES TO OUR PRIVACY POLICY
1. Any changes we may make to our Privacy and Security Policy in the future will be posted on this page, with an updated effective date at the top of this Policy. You should visit this page periodically to review any changes to the Privacy and Security Policy. If we were to make any material changes to this Policy, we would notify you more prominently and obtain your prior consent or the prior consent of a parent or legal guardian.
USER FEEDBACK
1. We welcome questions, comments and requests regarding this Privacy and Security Policy. These should be addressed to   [email protected]  or by post to NOGAME STUDIO, 12 Hoa Phuong, Ward 2, Phu Nhuan District, HCM, VN.

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