Privacy Policy of ROCGAME PTE. LTD.

Dear Users

ROCGAME PTE. LTD. (hereinafter referred to as “the Company”) places great importance on the security and privacy of your personal data. To protect your rights, we have established this Privacy Policy (hereinafter referred to as “this Policy”) and, in accordance with the Personal Data Protection Act (hereinafter referred to as “PDPA”), inform you of the following matters before collecting your personal data:

(1) Name of the non-government agency.

(2) Purpose of data collection.

(3) Categories of personal data.

(4) Period, location, recipients, and methods of use.

(5) Rights exercisable under Article 3 of the PDPA and methods for exercising those rights.

(6) Possible effects on your rights if you choose not to provide your personal data.

Please carefully review and agree to the Company’s User Agreement and this Policy before registering and logging into any games or services provided by the Company. If you register and log into the services provided by the Company, it shall be deemed that you have read, understood, and agreed to this Policy in accordance with the User Agreement (also referred to as Terms of Use). The Company has the right to modify, amend, or supplement this Policy at any time. Once the revised contents are published on the website, they take immediate effect. Please regularly visit our website and review the relevant notices or announcements. If the revisions contain substantial changes, the Company will announce the updates 30 days in advance. After the 30-day period, the revised Policy will be formally implemented. If you continue to use the services provided by the Company, you will be deemed to have read, understood, and agreed to accept all modifications.

Please note: If you are under 18 years old, your legal guardian must agree to this Policy and the User Agreement on your behalf. If you are under 7 years old, your parent, guardian, caretaker, or legal representative must review and agree to this Policy and the User Agreement on your behalf and complete the registration process for you. Again, if you complete the registration and login process, it is deemed that you have fully understood and agreed to this Policy and the User Agreement.

Article 1: Scope of Application

This Policy applies to the collection, processing, and use of your personal data when using services provided by the Company. However, this Policy does not apply to websites or webpages operated by third parties linked through the Company’s website or services. The privacy policies of those third-party websites shall apply, and the Company assumes no joint liability.

Article 2: Categories of Data

Collected The personal data that may be collected by the Company includes (refer to the Ministry of Justice’s classification of specific purposes and personal data types):

  1. Identifiers (C001): Name, title, address, work address, previous address, home phone number, mobile phone number, instant messaging account, platform account, communication and household registration address, photo, fingerprint, email address, digital signature, certificate card serial number, certificate number, authentication records, and other identifiable information.
  2. Financial Identifiers (C002): Bank account number and name, credit or debit card number, insurance policy number, and other personal numbers or accounts.
  • Government Identifiers (C003): National ID number, resident certificate number, tax ID number, insurance certificate number, disability card number, retirement certificate number, license number, passport number, etc.
  1. Personal Descriptions (C011): Age, gender, date of birth, place of birth, nationality, voice, etc.
  2. Document Indexing (C131): Indexes or codes of documents not processed by automated machinery.
  3. Unclassified Data (C132): Letters, files, reports, or emails that cannot be categorized.

Article 3: Types of Information

Collected To provide services, the Company collects and uses the following types of information (limited to what is actually obtained):

  1. Game Information: For logging in and gameplay, the Company collects specific information you provide, including name, nickname, ID number, phone number, email, region, language settings, and other necessary information.
  2. Operational Data: To maintain game operations and service quality, the Company may collect data about your hardware, software, mobile device, connection environment, IP address, product model, operating system, ISP, browser type, login time, usage duration, visited URLs, game content, purchase history, reward records, and player interactions.
  • Online Transaction Information: To ensure payment and recharge processes, we collect order-related data and credit card information based on the transaction type. Credit card data is used solely for processing transactions and is not stored by the Company, as payments are handled by appropriate institutions.
  1. Customer Support Contact Information: If you contact the Company through any form, we may obtain and store the information you provide, including name, email, phone number, device type, and operating system. This information helps us improve customer support services.
  2. Promotional and Survey Information: If you participate in promotional events or surveys, the Company may collect any information you choose to provide, such as name, address, phone number, email, gender, and birthdate.
  3. Cookies: Cookies remember your preferences and usage habits to enhance your user experience. The Company may use cookies to collect data such as website management, activity logs, and usage behavior. You may disable cookies via your browser settings, though some website functions may be affected.
  • Browsing Information: To improve services, the Company’s servers automatically log IP addresses, access times, and browsing history when you access our website or affiliated sites. This is used only for statistical and service optimization purposes and is not linked to any individual.
  • Voluntary Information Provided by You.
  1. Information Provided by Other Users Regarding You.
  2. Others: In addition to data you provide directly, you may also provide personal data to the Company through partner companies. When connecting to third-party services, the Company may collect related data. Such information is processed within the scope of the agreed contractual purpose only.

Article 4: Specific Purposes

  1. Our company will use your information for the following purposes (as detailed in the Ministry of Justice’s “Specific Purposes and Categories of Personal Data” under the Personal Data Protection Act):
    1. 040: Marketing (including joint marketing activities with our business partners).
    2. 063: Collection, processing, and use of personal data by non-governmental agencies as required by law.
  • 069: Contract, quasi-contract, or other legal relationship matters.
  1. 090: Consumer and customer management and services.
  2. 091: Consumer protection.
  3. 098: Commercial and technical information.
  • 129: Accounting and related services.
  • 135: Information and communication services.
  1. 136: Information and database management.
  2. 137: Information and communication security and management.
  3. 148: Online shopping and other e-commerce services.
  • 150: Auxiliary and logistical support management.
  • 157: Research, statistics, and analysis.
  • 173: Supervision and management by other government agencies related to specific business purposes.
  1. 181: Other operations in accordance with our registered business scope or organizational charter.
  • 182: Other consulting and advisory services.
  1. To fulfill the services provided by our company:
    We may use the collected information to provide, maintain, and improve our company’s applications, relevant websites, and other services we develop, operate, or manage. This includes preventing illegal activities or violations of the user agreement. If you choose to use our online transaction services, we may collect the order-related information and credit card details you provide to complete payment, top-ups, logistics, and other consumer services.
  • To resolve user issues or consumer disputes:
    If you contact us regarding issues experienced while using our applications or websites, we may use the provided information to resolve the problem. In the case of a dispute between you and our company, we may use your personal data to explain or communicate the relevant circumstances.
  1. To provide, maintain, and improve our services, and to develop new services:
    1. We may use the collected information to operate, maintain, enhance, and develop our platform and related services, including automatically updating the application on your device and remembering your login details to avoid repeated input during current or future visits.
    2. We may use the collected information to help us develop new services.
  2. To communicate with users:
    We may use the collected information (such as your name, phone number, and email address) to communicate and interact directly with you. This includes, but is not limited to, sending notifications about changes or improvements to our network services, or contacting you about content you have uploaded to or downloaded from our services. If you contact us, we will also keep a record of your request to help address any issues you may have.
  3. To provide personalized services, including tailored content, promotions, recommendations, marketing, event notifications, and the delivery of business-related messages to build commercial relationships with you:
    We may use the collected information and provide it to our affiliated companies or partners to personalize your network service experience, including recommending content and promotions related to our company, our affiliates, or our partners. This also includes sending you relevant content (including but not limited to advertisements, marketing materials, event notices, and other commercial messages). Additionally, we may periodically send you promotional materials or notices related to our services.
  • Statistics and analysis:
    1. While you use our gaming services, we may automatically collect data regarding your device usage to analyze your personal gaming habits and purchasing behavior. This helps us improve our services, design membership activities, optimize game content, create marketing campaigns, and develop new products and services. We may also analyze and generate statistics based on the information you provided during account registration and server logs from your browsing activities. However, such analysis will not target individual behavior.
    2. To improve service quality, we may use, share, or disclose the collected information to our company, affiliates, or partners for market analysis, statistical evaluation, or research purposes, such as in connection with sales or incentives, or to provide you with broader and more comprehensive services.
  • To comply with applicable laws and fulfill legal obligations.
  1. We do not actively collect or process sensitive personal data (such as medical records, genetic data, sexual life, health examination results, or criminal history). If it becomes necessary to process such data for legal reasons, we will follow applicable legal provisions (e.g., Article 6 proviso of the Personal Data Protection Act). Please ensure that you are legally authorized to disclose any such sensitive personal data to us before doing so.
  2. Corporate changes and data transfers:
    As the company evolves and grows, we may buy or sell companies, subsidiaries, products, or assets. In such transactions, customer information is typically part of the business assets transferred. In the event of a business transfer (e.g., merger, acquisition, or sale of all or part of our products or assets), your personal data may be transferred accordingly, but only insofar as it relates to services under the change of ownership.

Article 5: Period, Location, Recipients, and Methods of Use

  1. Period:
    1. User data will be used during the operational period of the Company’s services until you request to cease usage or the service is terminated.
    2. Data will also be retained for the duration required by relevant laws or individual contractual agreements (whichever is longer).
  2. Recipients:
    1. The Company, its affiliates, partners, and their personnel (including shareholders, directors, consultants, officers, employees, or other professionals such as legal, accounting, or financial advisors).
    2. Government or non-government agencies authorized by law.
  • Any third parties you consent to.
  1. Social media or software service providers used by the Company (e.g., Facebook, LINE,Instagram, YouTube, Discord, Google, etc.).
  • Location:

The service regions or locations of the Company, its affiliates, partners, and software/social media providers, as well as the Company’s websites and affiliated sites.

  1. Method:

Collection, processing, international transfer, and use by automated or non-automated means in accordance with applicable data protection laws.

Article 6: Rights and Methods of Exercising Your Rights

  1. According to Article 3 of the PDPA, you may exercise the following rights regarding your personal data held by the Company:
    1. Request to inquire, review, or obtain a copy of your personal data (a fee may be charged for necessary costs).
    2. Request correction or supplementation (you must provide appropriate explanation according to Article 19 of the PDPA Enforcement Rules).
  • Request to stop the collection, processing, or use and request deletion.
  1. If there is a dispute regarding the accuracy of your personal data, you may request to stop its processing or use according to Article 11(2) of the PDPA. However, if required for business or with your written consent noting the dispute, this restriction does not apply.
  2. When the specific purpose for which the data was collected no longer exists or the retention period expires, you may request deletion or cessation of use under Article 11(3) of the PDPA. The exception applies if continued use is necessary for business or with your written consent.
  3. If the Company violates the PDPA by collecting, processing, or using your personal data, you may request the Company to stop collecting your data under Article 11(4).
  1. Your rights may be limited if procedures are not followed or if otherwise stipulated by law.
  • To exercise the rights stated in Item I above, the following procedures must be completed:
    1. Fill out the required application form.
    2. Present identification documents that can confirm your identity.
  • The Company may charge necessary fees for processing your request.
  1. If authorized by another person, a power of attorney and identification documents of both parties are required.

Article 7: Consequences of Not Providing Personal Data

 If you fail to provide complete and accurate personal data, it may affect the Company’s ability to:

  • Provide services
  • Contact you
  • Complete transactions
  • Authenticate your identity
  • Process customer complaints or other services

You are advised to provide complete and updated information. If damages occur to you or third parties due to incomplete or inaccurate data, you shall bear all legal responsibilities. If the Company incurs losses as a result, you shall be liable for compensation.

Article 8: Maintenance of Personal Data

  1. The Company shall take appropriate and reasonable technical and organizational measures to protect your personal data and prevent unauthorized access, alteration, loss, or disclosure in accordance with relevant laws.
  2. The Company will not modify or delete any personal data or files without your consent, except as stated in this Policy or applicable laws.
  • Unless otherwise specified in this Policy or applicable updates, your personal data will not be lent, sold, or shared with third parties except in the following cases:
    1. When permitted by law.
    2. To protect the rights of the Company and its affiliates.
  • In cooperation with lawful investigations by judicial authorities.
  1. In response to legally required investigations by competent authorities.
  2. When disclosure is reasonably necessary to comply with the law or improve services.
  3. To prevent danger to your life, body, freedom, or property.
  • To protect the safety of other users or third parties in emergencies.
  1. Although the Company strives to secure your data, the security of online transmissions cannot be guaranteed. Please do not share your account or password with others or allow others to use your data. If your account or password is compromised, change your password immediately and notify the Company. The Company may verify your identity before taking any action. Avoid publicly disclosing sensitive information online.

Article 9: Amendments to This Policy

The Company may revise this Policy at its sole discretion. Updates will be posted on the Company’s website. Please regularly check the site for updates. Continued use of the services after changes means you have read, understood, and agreed to the revised Policy. If you do not agree, you must immediately cease use of the Company’s services.

Article 10: Feedback and Suggestions

If you have any questions, comments, or requests regarding this Privacy Policy or personal data, please contact us at: rocgame2021@gmail.com