1. INTRODUCTION

1.1 Overview

Welcome to Garena's Services, operated by Vietnam Esports and Entertainment Joint Stock Company and its affiliates (referred to individually and collectively as "Garena," "we," "our," or "us"). Garena takes its data privacy responsibilities seriously in compliance with Vietnam’s personal data protection laws (“Privacy Laws”) and is committed to respecting the privacy of all users of Garena’s games (“Games”), websites, and mobile applications (“Platforms”).

The Services covered under this Privacy Policy include Games, Platforms, and other related services as described in Garena’s Terms of Service. A "User" refers to any individual who registers an account, accesses, or uses our Services (collectively referred to as "Users," "you," or "your").

We recognize the importance of the personal data you entrust to us and take responsibility for its management, protection, and processing. This Privacy Policy aims to help you understand:

• How we collect, use, disclose, and process the personal data you provide to us;
• How we handle and safeguard personal data, both currently and in the future;
• How you can make informed decisions about sharing your personal data with us.

If you are accessing our Games from South Korea, please refer to the South Korea-specific Privacy Policy [HERE].

1.2 Definition of Personal Data

"Personal Data" refers to any information that identifies an individual, whether true or not, including data that can be used in combination with other available information. Common examples include name, identification numbers, and contact details.

1.3 Acceptance of Policy

By using our Services, registering an account, or accessing our Platforms, you confirm that you acknowledge and accept the practices, requirements, and policies described in this Privacy Policy.

IF YOU DO NOT AGREE TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED HERE, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR GAMES OR PLATFORMS.

If we update this Privacy Policy, we will notify you by posting the revised version on our Platforms. Continuing to use our Services after such changes will be considered your acknowledgment and acceptance of the modifications.

1.4 Scope and Application

This Privacy Policy applies in conjunction with other relevant notices, contractual terms, and consent agreements related to the collection, storage, use, disclosure, and processing of personal data. It does not override these agreements unless explicitly stated otherwise.

2. WHEN DOES GARENA COLLECT PERSONAL DATA?

We may collect personal data from you in the following situations:

• When you register, use our Services, Games, or Platforms, or create an account;
• When you submit forms, including applications or service requests, online or otherwise;
• When you enter into agreements, provide documents, or share information regarding your interactions with us;
• When you communicate with us via phone calls (which may be recorded), emails, social media, or in person;
• When you interact with our customer service representatives;
• When you use electronic services or interact with our Games or Platforms, including cookies that may track user activity;
• When you grant permissions on your device to share data with our Platforms;
• When you link your Garena account with your social media accounts or other external accounts;
• When you transact through our Games or Platforms (where applicable) or with authorized third-party payment providers;
• When you provide feedback or submit complaints to us;
• When you participate in competitions, tournaments, or specific gaming events;
• When you engage in gaming activities;
• When you submit personal data to us for any reason.

These examples are not exhaustive but represent common instances where personal data collection may occur.

3. WHAT PERSONAL DATA DOES GARENA COLLECT?

Unless otherwise specified, Garena may collect the following personal data:

• Name, username, and user ID;
• Contact information (email, phone number, address);
• Transaction details, including bank account or payment information (if applicable);
• Interactions and communications with other users and accounts;
• Gender, age, and date of birth;
• Device-related information used to access our Services;
• Images, audio, or videos you upload via our Services;
• Location data, including IP addresses;
• Government-issued identification or other official documents;
• Marketing preferences, communication choices, and interaction history with Garena;
• Survey responses, competition participation details, and other submitted information;
• Social media account details (if linked with your Garena account);
• Usage and transaction history, including in-game activities, requests, and advertisements interacted with.

You must not provide false or misleading information and must inform us of any updates or inaccuracies. Garena reserves the right to request further verification documents as needed.

If you register using a social media account, we may access public profile information shared with the social media provider in accordance with their policies.

4. DATA COLLECTION THROUGH COOKIES & TRACKING TECHNOLOGIES

Garena may use cookies and similar technologies to:

• Improve our Games, Platforms, and Services;
• Provide personalized content and relevant advertisements;
• Track user activity and engagement across our platforms.

Users can disable cookies via browser or device settings, but this may affect full functionality.

5. HOW DOES GARENA USE YOUR PERSONAL DATA?

Garena may collect, use, disclose, and process your personal data for purposes including but not limited to:

• Processing applications, transactions, and service requests;
• Managing your account and interactions with our Services;
• Providing customer support and responding to inquiries;
• Enhancing service functionality through updates and technical improvements;
• Conducting research, data analysis, and improving user experience;
• Personalizing marketing and promotional content;
• Ensuring compliance with legal obligations and regulatory requirements;
• Preventing fraud, illegal activities, and unauthorized account access.

6. HOW DOES GARENA PROTECT YOUR DATA?

Garena implements security measures to safeguard your personal data, including network protection, restricted access, and encryption techniques. However, no system is 100% secure, and absolute protection cannot be guaranteed.

7. DISCLOSURE OF PERSONAL DATA

Garena may share personal data with:

• Affiliates, subsidiaries, and related companies;
• Other users as part of interactive features within our Services;
• Contractors, agents, and third-party service providers, including payment processors, advertising partners, and IT service providers;
• Regulatory authorities or legal entities as required by law;
• Business partners in mergers, acquisitions, or restructuring events.

8. USER RIGHTS & DATA ACCESS

Users have the right to:

• Withdraw consent for data collection and processing;
• Request access, correction, or deletion of their personal data;
• Restrict or object to data processing where legally applicable.

Requests must be submitted in writing to Garena’s Data Protection Officer at dpo.vn@garena.com.

9. CONTACT INFORMATION

For inquiries, concerns, or data protection matters, contact:
📍 Vietnam Esports and Entertainment Joint Stock Company
 📍 Address: Floor 6, Capital Place Building, 29 Lieu Giai, Ngoc Khanh Ward, Ba Dinh District, Hanoi, Vietnam
📧 Email: dpo.vn@garena.com

Last updated: June 27, 2023. Effective seven days after publication.