PRIVACY POLICY
1. Introduction
1.1) Welcome to the services provided by , operated by ADIUSSOFT (CAMBODIA) CO., LTD., its subsidiaries, and affiliated companies (collectively referred to as Adiussoft,' 'we,' 'us,' or 'our'). Adiussoft is committed to complying with the applicable laws and regulations regarding personal data, and we take this commitment seriously. We also respect your privacy and are committed to being mindful of the personal data of Adiussoft users ('users') of the Adiussoft game ('game'), website, and mobile applications ('website') (collectively referred to as 'services'). 'Users' refer to individuals who have registered for or accessed our services (individually and collectively 'user,' 'you,' or 'your'). We recognize the importance of the personal data that you willingly provide to us, and it is our responsibility to manage, protect, and process your personal data correctly. This privacy policy ('Privacy Policy') is established to provide you with confidence in how we collect, use, disclose, transfer, and/or process your personal data that you have provided to us and any data we may possess in the present or future. It also defines the terms used in this Privacy Policy without setting any specific meanings other than those defined in Adiussoft's terms of service.
1.2) 'Personal data' means information, whether true or not, about individuals who can be identified, either directly from that data or indirectly from that data and other information to which it is likely to come into our possession. General examples of personal data may include names and contact information.
1.3) By using our services, creating an account with us, or visiting our website, you acknowledge and agree that you consent to us collecting, using, disclosing, and/or processing your personal data as described in this Privacy Policy. You also agree to abide by the rules, regulations, and policies summarized in this Privacy Policy.
1.4) If you do not consent to the processing of your personal data as described in this Privacy Policy, please refrain from using our games or visiting our website. If we make changes to our privacy policy, we will inform you, including through announcements or updates on our website. We reserve the right to amend this Privacy Policy at any time within the limits allowed by the applicable laws governing the use of our services or platforms. Your continued use of our services following any changes will be considered as your acknowledgment and acceptance of the modified policy.1.5) This policy is binding and supplements any consent, agreement, or acknowledgment regarding the collection, use, disclosure, and/or processing of your personal data by us. This policy does not override any express consents, agreements, and acknowledgments, but rather serves to provide additional clarity.
2. When will ADIUSSOFT collect your personal data?
2.1) We may collect personal data about you:
- We may collect personal data about you when you register and/or use our game services or website or open an account with us.
- When you complete any forms, including but not limited to application forms or any other forms related to our products or services, whether online or in physical form.
- When you agree to any terms or provide documents or other information related to your interactions with us or when you use our products or services.
- When you interact with us through means such as telephone calls (which may be recorded), letters, faxes, in-person meetings, social media, and emails, or when you contact our customer service agents.
- When you use our electronic systems or interact with us through our games or website, or use our services, including, but not limited to, through cookies that we may use when you interact with our games or website.
- When you permit your device to disclose any information via mobile applications or our website.
- When you link your Adiussoft account with your accounts on other online social networks (as defined herein) or accounts from other service providers or use social media features under the terms of the respective service providers' policies.
- When you engage in transactions through our games or website (if applicable) or with service providers authorized by us.
- When you provide feedback or make a complaint to us.
- When you register for contests or special events for our games.
- During the course of your gameplay.
- When you voluntarily provide your personal data to us for any reason, which may include some general personal data related to you that may be collected.
3. What personal data will Aduissoft collect?
3.1) Personal data that Aduissoft may collect include, but are not limited to:
- Usernames and user IDs.
-Contact information, including email.
-Phone numbers and addresses.
-Transaction data, including bank account and payment information (where applicable and permitted by law).
-Conversations and data related to individuals or accounts interacting with us.
-Gender, age, and birthdate.
-Data you have shared via any connected devices that interact with our services.
-Images or videos that you provide through our services.
-Location information, including IP addresses.
-Information disclosed by government agencies or any other information provided to us (where applicable)
-Marketing and market research data, such as your interests in receiving marketing information, your preferences, and data related to your interactions with our marketing activities.
-Survey responses, data related to tournaments, events, and any other information you provide.
-Data related to any registrations or use of our services, including information you share through social media accounts and information on transactions and usage of our services, as well as data related to your activities, transactions, and usage of our services, and data related to your browsing of advertisements and content.
3.2) You agree not to provide us with inaccurate or misleading information and agree to inform us of any inaccuracies and changes in your data. You further agree to provide us with additional documents, at our request and as required by law, to verify the details in your data. We reserve the right to verify your information at any time.
3.3) If you register as a user of our services using your online social media account or link your account with an online social media account, or use our social media features, we may access the information related to your current social media account according to your consent and in accordance with the policies of your service provider.
3.4) If you do not want us to collect certain data/personal data, you may opt out at any time by providing a written request to our Data Control Officer at the address provided below in the 'How Can You Access or Change Your Data?' section. Please note that opting out of data collection or our withdrawal of your consent to allow us to collect and use your data may affect your use of our services. For example, opting out of location data collection may result in the deactivation of location-based features.
4. Collection of Other Data
4.1) Like websites, mobile applications on your phone or other devices may collect data, which could include information related to you. This data could be collected by our web servers when you use our services, typically including details about your device, such as the device's internet protocol (IP) address, the operating system of your computer/phone, and the type of browser you use. This may also include characteristics specific to your mobile device, such as the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device. These are used to understand how users interact with our games and websites. If you log in, this information may be linked to your personal account.
4.2) Our mobile applications may collect data that is directly related to your device's usage, such as GPS (Global Positioning System), Wi-Fi, and Location-Based Services (LBS). This information is used for various purposes, including location-based services and content delivery. You can choose to disable the location-based services in your device settings.
4.3) Just like when you view pages or content on our website or mobile applications, almost all data is sent to us, including (but not limited to) your IP address and information related to your operating system. Your device also sends data about the content and advertisements you view, as well as the software you have installed, and the time of your access.
5. Cookie
5.1) We or other parties providing services on our behalf, as well as our advertising partners, may use 'cookies' or other features at times to allow us or third parties to collect or share data related to your usage of our services. These features help us improve our websites, games, and services or allow us to offer new services and features. They also assist us and our advertising partners in delivering content that matches your interests, including legal obligations to provide advertisements. 'Cookies' are identifiers sent by us to your computer or device, storing information about your computer or device. This includes information about your computer or device, such as how and when you use our services, the number of users, and activities within our websites and games. We may link cookie data to personally identifiable information. Additionally, cookies may be linked to information about your selected preferences for web-based shopping or the games you have viewed, and this information may be used to deliver suitable content according to your interests, enabling our advertising partners to offer advertisements through our services or on various internet websites. It is also used to verify your usage of our services related to purchases and to assist in related services.
5.2) You can refuse the use of cookies or web beacons by configuring your browser or your device in a manner suitable to your preferences and interests. However, please note that if you do this, you may not be able to use some features of our websites, games, or services to their full extent.
5.3) You may be able to opt out of interest-based advertising on certain mobile applications by following the guidelines for Android and iOS operating systems.
6. How will we use the information you provide to us?
6.1) We may collect, use, disclose, and/or process your personal information for the following purposes:
1. To evaluate and/or process your requests/transactions with us, or transactions or communications with third parties through our services.
2. To manage, operate, deliver, and/or provide access to our services, websites, and games (including customization based on your preferences), as well as to manage your interactions and accounts with us.
3. To respond, process, and manage or complete any requests from you for products or services, and address issues with our services or abnormal account activities.
4. To enforce agreements for our services, or terms and conditions for any requested rights or services.
5. To safeguard the security and safety of individuals, property, and assets, and to investigate any fraud, misconduct, or breaches of our agreements or applicable laws.
6. For identity verification and/or authentication purposes.
7. To maintain, manage, and improve the software and/or hardware updates, and to address issues, reports, or management of any incidents that may be necessary for ensuring the reliability of our games and/or services.
8. To manage or facilitate the convenience of the user's relationship with us, as well as to respond to inquiries received (or received on your behalf) from you or relating to you.
9. To communicate with you, or send communications to you through various methods (including email or SMS), and to manage and/or operate any notices or content that may relate to you or posts or comments by you within our games or websites.
10. To market and advertise activities that may be conducted safely in compliance with applicable laws and to communicate, by any means or methods, marketing and sales information related to products and/or services (including products or services that may be operated jointly or cooperatively by Adiussoft or its related companies) that may exist now or in the future. You may cancel the receipt of marketing materials at any time by opting out (unsubscribe function) that is available in electronic marketing materials. We may use your information to contact you for the purposes of mailing or marketing communications by us and by companies related to us.
11. To analyze, evaluate, and develop activities (including, but not limited to, analysis of data, surveys, development of products and services, or analysis of information based on your interests or behaviors) for the purposes of analyzing and using our services, making recommendations based on your interests, improving services or products, and enhancing the user experience.
12. To conduct surveys, research, and review, and to conduct surveys online and offline on platforms of third parties, including third-party social media platforms such as Google Forms, for the purposes of examining the size and composition of our target audience, and for the purposes of understanding the user experience of our service.
13. To conduct marketing and advertising for activities that may be conducted safely in compliance with applicable laws, and for the purposes of marketing products or services based on your interests, providing marketing and sales information (which may include products or services operated by Adiussoft or a related company), and communicating by any means or methods, including by electronic mail or SMS, marketing communications and product offerings, for example, product offerings (including products or services that may be operated jointly or cooperatively by Adiussoft or related companies). You may cancel the receipt of marketing materials at any time by opting out (unsubscribe function) that is available in electronic marketing materials. We may use your information for the purposes of contacting you for the purposes of mailing or marketing communications by us and by companies related to us.
14. To respond to legal processes or to comply with or follow any obligations imposed by any applicable law, government regulations, orders, or requirements, including, but not limited to, complying with any legal obligations imposed by applicable laws binding on Adiussoft, or by a related company or company within the group.
15. To create statistics and conduct research for internal and legal reporting, and/or as required by record-keeping regulations.
16. To conduct business or other screening activities (including, but not limited to, background checks) related to legal obligations or any processes that are legally mandated or may be required by us.
17. To audit our service accounts or the business of Adiussoft.
18. To prevent or investigate any violations or suspicions of actions that may be deemed to be a violation of our terms of service, illegal activities, negligence, or misconduct, whether related to your use of our services or other matters arising from your relationship with us.
19. To securely store personal information, whether it is within or outside the jurisdiction that is subject to your legal obligations.
20. To manage and/or facilitate transactions of business assets or business interests, involving transactions related to Adiussoft, either as a joint venture or solely related to Adiussoft, and/or one of the companies related or a group company of Adiussoft, in a joint venture or an association with Adiussoft, and/or one of the companies related or a group company of Adiussoft. This may involve any third party which is a joint venture party in a transaction like 'business asset transactions,' which refers to a purchase, sale, lease, company merger, business combination, or acquisition, transfer, or management of the financial operation of an organization or a part thereof, or any business, activity, or business interest therein, or any transaction of financial assets or financial businesses, by an organization or one part of an organization
For purposes that may be legally conducted under the applicable law, for which we will inform you when obtaining your consent (which collectively is referred to as 'Specific Purposes')
21. For purposes that may be legally conducted under the applicable law, for which we will inform you when obtaining your consent (which collectively is referred to as 'Specific Purposes')
6.2) I acknowledge and agree that Adiussoft may collect, retain, and disclose my account information, including 'content,' in cases where it is required to comply with any applicable laws, court orders, or lawful requests from any governmental agency that has jurisdiction over Adiussoft, or as required under the terms of service and privacy policy. This may include, but is not limited to:
1. Compliance with any legal obligations.
2. Compliance with orders from any governmental agency with jurisdiction over Adiussoft.
3. Enforcement of the terms of service and policies.
4. Complying with any requests, whether legitimate or factual, from you or any other third party alleging that the 'content' in question violates the rights of any other person.
5. Complying with your requests within the scope of the service.
6. Protecting the security and privacy rights of Adiussoft users and/or the public.
6.3) Objectives We may combine, use, disclose, or process your personal information based on the situation at hand. The objectives may not be fixed in any particular way. We will inform you of the specific objectives when obtaining your consent, and, unless required by your consent, will process your data as allowed by law and as outlined in the privacy policy.
7. How does Adiussoft control and retain personal data?
7.1) We implement various security measures and control practices to ensure that personal data of our users is secure and accessible only to authorized personnel with special access rights in our secured environment. However, we cannot guarantee the complete security of your personal data.
7.2) We will retain personal data in compliance with applicable data protection and privacy laws. We may destroy or delete the personal data when it is no longer needed for the purposes for which it was collected, such as when (i) the purposes for which the personal data was collected are no longer being served by retaining the personal data and (ii) retention is no longer necessary for legal or business purposes, and (iii) there is no longer any benefit to continuing the retention of the personal data. In the event you cease to use our services, and your access to the game website and/or your services is terminated or withdrawn, we may still continue to use and/or disclose your personal data in accordance with this privacy policy and our legal obligations.
8. Does Adiussoft disclose data collected from external individuals or not?
8.1) In the course of our business operations, we may need to disclose your personal data to provide services from external individuals, agents, and/or companies within our group, or companies related to us, and/or other third parties, whether located in Singapore or elsewhere, for one or more of the purposes listed above:
- Affiliated Companies: Adiussoft may share your data with other companies within its corporate group or affiliated companies.
- Service Providers: Your data may be shared with service providers, including but not limited to logistics companies, game developers, financial service providers, advertising and marketing agencies, telecommunications companies, and data center providers.
- Government Agencies and Regulatory Bodies: Adiussoft may disclose your data to government agencies and regulatory bodies that have jurisdiction over the company.
- Business Transfers: Your personal data may be disclosed to individuals or entities in the event of business reorganization, mergers, acquisitions, or other transactions, including asset transfers or sales.
- Third Parties for Business Purposes: Adiussoft may share data with third parties to support its business operations.
- Data Sharing by Third Parties: Personal data disclosed by Adiussoft for any purpose may be further collected and processed by third parties, including affiliated companies, for their respective purposes.
8.2) We may disclose information about your gaming history and/or share records that show your game accesses, as well as your IP addresses. Additionally, we may share statistical and demographic information about user activities and service usage with third parties, including advertising companies and other individuals for advertising purposes and for tracking, as well as under applicable laws.
8.3) Furthermore, you may choose to submit your user activities as an RSS feed that can be subscribed to by other users, including information related to your gaming activities, game installations, connections with other users, and other account activities. These activities will be published as feeds on our website or games as permitted by relevant laws, and we may process your personal data under the legal processing basis mentioned in Section 6.1, which includes legal bases for the fulfillment of contracts with you, legal compliance, and our legitimate interests for processing data, taking into account the impact on your rights concerning personal data control, as well as for any necessary or legally required legal complaints.
8.4) To avoid doubt, in cases where personal data is governed by data protection laws or other applicable laws, we shall process your personal data without your consent if we, for example, collect, use, or disclose such data as required by the law. The permission provided by law shall continue to apply.
8.5) Third parties may capture or access personal data that is improperly collected or stored on websites, and technology may fail to operate as expected or may have errors, or individuals may gain unauthorized access to, misuse, or use data improperly. No matter what, we will employ appropriate security measures to protect your personal data in accordance with applicable laws governing personal data control. However, security breaches cannot be guaranteed to be entirely safe, like those limited by law, especially when data is disclosed without authorization due to hacking, and unintended disclosures may occur.
10. Data Collected by Third Parties
10.1) Our websites and games use Google Analytics, a web analytics service provided by Google. Google Analytics uses cookies, which are small files that are stored on your device, to help us analyze how users use our services. Data generated by these cookies concerning your use of the service or your 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, and providing other services related to website activity and internet usage. Google may also transfer this information to third parties where required 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) At times, we and third parties may enable the download of software applications (apps) that can access your data either within or through the app service. These apps may access data separately and provide it to third parties. Third parties may access information that identifies you, such as your name, your user ID, your IP address, or other information. For example, games you play at different times and services may have their apps and may ask you to provide additional information directly to third parties through their software apps or websites. In addition to this, these apps may ask for your consent, and their policies and other information are explained by the third parties in their apps or on their websites.
11. Disclaimer of Responsibility for Security and Third-Party Websites
11.1) We do not guarantee the security of personal data and/or other information you provide to third-party websites. We implement various security measures to maintain the security of your personal data within our control. Personal data is securely stored and can only be accessed by individuals with proper authorization.
11.2) In our efforts to offer you greater value, we may choose to link and partner with third-party websites to connect and integrate within our websites or games. These linked websites may have separate privacy policies and practices. Although these third parties are within our network, we have no control over their websites.
11.3) We are not responsible for or liable for the content, security arrangements (or lack thereof), and activities of linked websites. Linked websites are provided for your convenience, and you access these linked websites at your own risk. We make no representation concerning the content or services of linked websites and encourage you to provide feedback about linked websites (including any specific link) for quality control purposes.
12. Does Adiussoft Transfer Your Data Abroad?
12.1) Personal data and/or your information may be transferred, stored, or processed outside your country. Adiussoft will transfer your data to various countries under data protection laws. By agreeing to this privacy policy, you consent to the transfer of your data to any country where our affiliate companies maintain servers and/or data centers. In this regard, personal data will be processed within Singapore, which serves as the central data hub, and our servers.
12.2) If you are an individual residing in India, your personal data will be processed and stored in our servers located in India or Singapore. Adiussoft will transfer your data to other countries in compliance with data protection laws, and you agree to such data transfers and processing.
12.3) You can find more information about the transfer of personal data outside the European Union (EU) and data related to EU residents in the 'Additional Terms for Service Users in EU Member States' section.
13. How Can You Choose to Withdraw Consent, Request Access, or Correct Your Provided Data?
13.1) Withdrawal of Consent
You may withdraw your consent for the collection, use, and/or disclosure or request the deletion of your personal data under our custody or control by informing us through the Data Protection Officer at info@adiussoft.com. We will process your request according to this privacy policy and applicable data protection laws.
However, the withdrawal of consent may render us unable to continue providing you with services or fulfilling the agreements you have with us.
13.2) Requesting Access or Correction of Accurate Data
If you have an account with us, you can access and/or correct accurate data regarding your personal information within our custody or control at any time through your account settings on our website or games. If you do not have an account with us, you can request access and/or correction of accurate data regarding your personal information within our custody or control at any time by submitting a written request to our Data Protection Officer at info@adiussoft.com.
Under applicable law, we may charge a reasonable fee for managing and processing your requests. If we choose to charge a fee, we will inform you of the estimated fees. Please note that we are not obligated to respond to or manage your access requests until you agree to the estimated fees.
We reserve the right to refuse to correct your personal data in the circumstances defined by data protection laws and/or in order to protect our rights
Data Controller
ADIUSSOFT (CAMBODIA) CO., LTD.
Physical Registered Office Address: Building No.685 Floor 11, Street Preah Monivong, Boeng Keng Kang Ti Bei, Boeng Keng Kang, Phnom Penh, Cambodia.