TGMedia
1. Introduction
TGMedia (collectively, “TGMedia”, “us”, “our” or “we”) develops and publishes games for mobile devices. This
Privacy
Policy (this “Policy”) describes the ways we collect, store, use, and disclose the information, including
personal
information, and data that our users (“users” or “you”) provide or we collect in connection with the TGMedia
website
available at https://www.tgmedia.vn/ and any TGMedia game provided on a mobile platform (each a “Service,”
collectively, the “Services”). Additionally, this Policy describes your rights and choices concerning your
information.
Please note that the scope of this Policy is limited to information and data collected or received by TGMedia
through your use of the Services. TGMedia is not responsible for the actions of individuals with no relationship
to
TGMedia or third-party companies, the content of their sites, the use of information or data you provide to
them, or
any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or
affiliation with, those individuals or companies.
If you do not want TGMedia to collect, store, use, or share your information in the ways described in this
Policy,
you should not use our Services.
2. Information and Data We Collect from You and How We Collect It
When you use our Services, you may give us your contact information directly on our website, generally your name
and
email address.
Registration Information:
We may also offer you the option to complete a user profile that is visible to other TGMedia users (“Account”).
If
you create an Account, you may provide us you name, a username, e-mail address, a password and other information
that helps us confirm that it is you accessing your Account. We may do this through in-game dialog boxes, which
you
may choose to skip. If you sign into the Services with Facebook Connect we will collect information that is
visible
via your Facebook account such as: (1) your first and last name, (2) Facebook ID, (3) Profile Picture/URL, and
(4)
list of Facebook friends. Your Account may be used to publicly identify you as part of social features of the
Services, which may include user-to-user interaction, chat or messaging functionality, public leaderboards,
head-to-head competition, and other similar features. The TGMedia username will be public and will be shown to
other
users, but will only permit access to information that is considered public or that you have designated as
public in
your user profile settings.
We may also offer you the ability to import your contacts or manually enter email addresses so that you can
locate
your contacts on TGMedia and invite your contacts to join you in the Services. We will store those contacts for
purposes of helping you and your contacts make connections through our Services.
Payment Information:
When you order any goods or service through the Services, including any virtual currency or virtual goods, our
payment processing service provider will collect your name, phone number, e-mail address, mailing address,
billing
address, and complete credit card information that enables them to receive your payment. Our payment processing
service provider may also retain this information to enable you to purchase additional items through our
Services
without having to re-enter it each time. Please note that purchases from third parties may also be subject to
additional policies
Information Collected by Customer Support:
When you ask for assistance from our Customer Support team, we will collect and store the contact information
you
provide (generally your name and email address), information about your gameplay or activity on the Services,
and
your user-name or ID number. We will also store the correspondence and any information contained within.
Technical and Usage Information:
When you access our Services, we may collect (i) certain technical information about your mobile device or
computer
system, including IP Address, mobile device ID (IDFA, Google Advertising ID or other identifiers), and the
version
of your operating system; and (ii) usage statistics about your interactions with the Services. In certain
Services
we will create and assign to your device an identifier that is similar to an account number. We may collect the
name
you have associated with your device, device type, telephone number, country, and any other information you
choose
to provide, such as username, character name, or e-mail address. We may also access your contacts to enable you
to
invite friends to join you in the Services. This information is typically collected through the use of
third-party
mobile device software development kits. We may occasionally send you push notifications through our Services to
send you game updates, high scores and other service-related notifications that may be of importance to you. You
may
at any time opt-out from receiving these types of communications by turning them off at the device level through
your settings.
3. How We Use Your Information
TGMedia's primary goals in using your information are to create your account, provide Services to you,
troubleshoot,
improve and optimize our Services, contact you, conduct research and create reports for internal use. We use
information collected through our Service for purposes described in this Policy or disclosed to you in
connection
with our Service. For example, we may use your information to:
Create accounts and allow users to use our Services.
Identify and suggest connections with other TGMedia users.
Operate and improve our Services.
Understand you and your preferences to enhance your experience and enjoyment using our Services.
Respond to your comments and questions and provide customer service.
Provide and deliver products and services you request.
Deliver advertising and marketing and promotional information to you.
Send you related information, including confirmations, invoices, technical notices, updates, security alerts,
and
support and administrative messages.
Communicate with you about promotions, contests, rewards, upcoming events, and other news about products and
services offered by TGMedia and our selected partners.
Conduct and administer contests promoted by TGMedia.
Enable you to communicate with other users.
Link or combine it with other information we get from third parties, to help understand your preferences and
provide
you with better services.
Use of Your Information by Others:
Third Party Services. We may provide your information to third party companies to perform certain services,
including but not limited to hosting services, payment processing, analytics, customer service and to assist us
in
our marketing efforts. Where we share your information with third-party service providers and business partners,
we
ensure that we have appropriate agreements in place to protect your information as required by applicable data
protection laws.
Advertising. To the extent we display advertising in our Services, we may allow advertising networks of our
affiliates and partner networks to collect information about your mobile device to enable them to serve targeted
ads
to you. Such mobile device data includes the following:
Device make, model and operating system.
Device properties related to screen size & orientation, audio volume and battery.
Carrier.
Operating system.
Name and properties of mobile application through which a consumer interacts with the Services.
Country, time zone and locale settings (country and preferred language).
Network connection type and speed.
IP Address.
Internet browser user-agent used to access the Services.
Advertising ID (IDFA on iOS devices and GAID on Android devices).
The privacy policies of our partners may include additional terms and disclosures regarding their data
collection
and use practices. We encourage you to check those privacy policies to learn more about their practices.
You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more
about
interest-based advertising and how to opt-out of this form of advertising on your web browser by companies
participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. If you wish to opt-out of
interest based advertising in mobile apps on your device by companies that participate in the DAA’s AppChoices
app,
you may download that app onto your device and exercise your choice. AppChoices is available at the links below:
DAA AppChoices iOS
DAA AppChoices Android
DAA AppChoices Amazon
You may also limit data collection by third parties by using your mobile device settings. Please note that
electing
to opt-out will not stop advertising from appearing in your browser or applications. It may make the ads you see
less relevant to your interests. Additionally, please note that if you use a different browser or erase cookies
from
your browser, or use a different mobile device, you may need to renew your opt-out choices.
4. How We May Disclose Your Information to Third Parties
TGMedia does not share your personal information except as approved by you or as described in this Policy.
We may share information we collect or derive with third parties for the following purposes:
With service providers that perform services on our behalf, including the ones referenced above under “Third
Party
Services”.
With our affiliates.
For analytics and research purposes.
When we have a good faith belief that we have to disclose the information in response to lawful requests by
public
authorities, including law enforcement or legal process purposes.
To satisfy any applicable laws or regulations.
When we believe in our sole discretion that our Services are being used in committing a crime, including to
report
such criminal activity or to share information with other companies and organizations for the purposes of fraud
protection, credit risk reduction, and other security precautions.
To protect our or a third party’s legal rights, investigate fraud, or to defend against a legal claim.
As part of a business transfer such as a merger, acquisition, or at bankruptcy;
We may share aggregate or anonymous information about you with advertisers, publishers, business partners,
sponsors,
and other third parties.
We may use analytics services provided by third parties, including Google Analytics. These service providers may
use
cookies to collect information about your online activities across this and other sites over time for
non-advertising purposes. To learn more about how Google analytics collects and processes data and the choices
Google may offer to control these activities, you may visit
http://www.google.com/intl/en/policies/privacy/partners/.
5. Specific Provisions for EU Individuals
Accessing and Correcting Your Personal Information. At any time, you may contact TGMedia at the address provided
in
the “Contact TGMedia” section herein and request to access the personal data that TGMedia holds about you.
TGMedia
may need to ask you to provide certain information to make sure you are who you claim to be. If you find the
information on your account is not accurate, complete or updated, then please provide TGMedia with the necessary
information to correct it.
Withdrawing Your Consent. Contact us if you would like to withdraw your consent to the processing of your
personal
data. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.
Erasing or Restricting Access to Your Information. You may request to delete or restrict access to your personal
data. We may postpone or deny your request if your personal data is in current use for providing Services or for
other legitimate purposes, in which case we will let you know if we are unable to do so and why.
Transferring your Personal Data (Otherwise known as Your Right to Data Portability). You have the right to
receive
your personal data that you have provided us in a structured, commonly used and machine-readable format and the
right to transmit that data to another party of your choice, where technically feasible. However, this right
shall
not apply where it would adversely affect the rights and freedoms of others.
Right to Make Complaint: if you consider that our processing of your personal data infringes data protection
laws,
you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You
may do
so in the EU member state of your habitual residence, your place of work or the place of the alleged
infringement.
If you have any concerns about the way we process your personal data, you are welcome to contact our data
protection
officer at hello@tgmedia.vn which you can see in the “Contact TGMedia” section. We will look into your request
and
make good faith efforts to resolve any concern you may have.
6. Security Safeguards.
TGMedia takes reasonable measures to protect your information from unauthorized access or against loss, misuse
or
alteration by third parties. Although we make good faith efforts to store the information collected on the
Services
in a secure operating environment that is not available to the public, we cannot guarantee the absolute security
of
that information during its transmission or its storage on our systems. Further, while we attempt to ensure the
integrity and security of our network and systems, we cannot guarantee that our security measures will prevent
third-party “hackers” from illegally obtaining access to this information. We do not warrant or represent that
your
information will be protected against, loss, misuse, or alteration by third parties. No method of transmission
over
the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its
absolute
security.
7. Data Retention.
TGMedia retains your personal data for as long as needed to provide you Services, unless we are required by law
to
delete or if TGMedia accepts your request to delete the information. We will also retain and use your personal
data
as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. Our Policy Regarding Children.
We do not knowingly collect or solicit personal data from anyone under the age of 16 or knowingly allow such
persons
to use our Services. If you are under 16, please do not send any information about yourself to us, including
your
name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. In
the
event that we learn that we have collected personal data from a child under age 16, we will delete that
information
as quickly as possible. If you believe that we might have any information from or about a child under the age of
16,
please contact us.
9. Transfer of Personal Data Outside Your Country.
We may transfer information that we collect about you to affiliated entities, or to other third parties across
borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note
that
these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we
take
steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use and
disclosure of information about you, including personal data, as described in this Policy.
10. Lawful Basis for Processing.
On certain occasions, we process your personal data when it is necessary for the performance of a contract to
which
you are a party, such as to provide the Services to you. We may also process your personal data to respond to
your
inquiries concerning our products and services.
On other occasions, we process your personal data where required by law. We may also process your personal data
if
necessary to protect your interests or the interests of a third party.
Additionally, we process your personal data when necessary to do so for fraud prevention, improving our network
and
services, and marketing our services to advertisers and publishers; where these interests are not overridden by
your
data protection rights.
If the processing of personal data is necessary and there is no other lawful basis for such processing, we will
generally ensure that consent has been obtained from you. You have the right to withdraw your consent to
processing
of personal data at any time.
For questions about data processing, please contact our Data Protection Officer. Visit the “Contact TGMedia”
section
below for contact information.
11. Privacy Shield Framework
TGMedia transfers certain personal data to the U.S. and participates in and has certified its compliance with
the
EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. TGMedia is committed to subjecting
all
personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on
each
Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield
Framework
visit the U.S. Department of Commerce’s Privacy Shield List, available at: https://www.privacyshield.gov/list.
TGMedia is responsible for the processing of personal data it receives under the Privacy Shield Framework and
subsequently transfers to a third party acting as an agent on its behalf. TGMedia complies with the Privacy
Shield
Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer
liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, TGMedia is
subject
to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, TGMedia may be
required to disclose personal data in response to lawful requests by public authorities, including to meet
national
security or law enforcement requirements.
In compliance with the Privacy Shield Principles, TGMedia commits to resolve complaints about our collection or
use
of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield
policy should first contact us at: hello@tgmedia.vn. We will attempt to answer your questions and satisfy your
concerns in a timely and complete manner. If you do not receive timely acknowledgment of your complaint from us,
or
if we have not addressed your complaint to your satisfaction, please contact or visit
https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS
are
provided at no cost to you.
If your complaint is still not resolved through these channels, under certain conditions, more fully described
on
the Privacy Shield website here: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may
invoke
binding arbitration when other dispute resolution procedures have been exhausted.
12. Provisions for Consumers
Please access here for more information: Provisions for Consumers
13. Changes to This Policy.
We may update this Policy to reflect changes to our data and information privacy practices. If we make any
material
changes we will notify you by means of a notice on the Services prior to the change becoming effective. We
encourage
you to periodically review this Policy for the latest information on our privacy practices. Please note that if
TGMedia needs to adapt the policy to legal requirements, the new policy will become effective immediately or as
required
14. Contact Us
You may contact TGMedia’s Data Protection Officer at hello@tgmedia.vn
Background images in all games used under license from Shutterstock