Privacy Policy

23-12-24

Article 1: INTRODUCTION

Welcome to the products and services operated by International IT Solutions JSC (referred to individually and collectively as “Inter ITS,” “We,” or “Our”). Inter ITS is committed to fulfilling its responsibilities regarding information security under personal data protection laws and respecting the privacy and concerns of all users of our services. Inter ITS understands the importance of your personal data, entrusted to us, and believes it has a duty to manage, protect, and process your personal data appropriately.

This Privacy Policy ("Privacy Policy" or "Policy") is designed to help you understand how Inter ITS handles the personal data you provide, whether now or in the future, and to help you make informed decisions before sharing any of your personal data with us. Additionally, this Privacy Policy serves as a data processing notification provided to you prior to our processing of your personal data. This Policy also assists Inter ITS customers residing in the European Union (EU) in understanding their rights regarding their personal data under the EU General Data Protection Regulation (GDPR) when using our services.

“Services” or “the Services” refers to Inter ITS’s online video games ("Games") and/or website ("Website"), and/or any products or services offered by Inter ITS.

“Personal Data” means information in the form of symbols, writings, numbers, images, sounds, or other formats in electronic environments associated with you or that helps identify you. Personal Data is provided by you, and you are responsible for its accuracy.

“Processing of Personal Data” refers to one or more activities involving your Personal Data, such as: collecting, recording, analyzing, validating, storing, modifying, publishing, combining, accessing, retrieving, encrypting, decrypting, copying, sharing, transmitting, supplying, transferring, deleting, destroying Personal Data, or other related actions.

By ticking the box to agree to this Privacy Policy before using the Services, registering an account with Inter ITS ("Account"), or accessing the Website, you confirm and agree that you voluntarily allow the Processing of your Personal Data and accept all methods, requirements, and/or policies described in this Privacy Policy. You thereby grant Inter ITS permission to process your Personal Data as described herein ("Consent").

IF YOU DO NOT AGREE TO ALLOW INTER ITS TO PROCESS YOUR PERSONAL DATA AS DESCRIBED IN THIS POLICY, PLEASE DO NOT REGISTER AN ACCOUNT, USE INTER ITS'S SERVICES, OR ACCESS INTER ITS'S GAMES OR WEBSITE. If we make changes to this Privacy Policy, we will post the updates or revised policy on the Website, within the Games, and/or through our Services. We reserve the right to modify or supplement this Privacy Policy at any time without prior notice to you.

Article 2: WHEN DOES INTER ITS COLLECT PERSONAL DATA?

Inter ITS may collect Personal Data about you in the following situations:

When you register and/or use the Services, Games, or Website of Inter ITS, or register an Account with us;
When you submit any forms, including but not limited to application forms or other forms related to any of Inter ITS’s products and services, whether online or otherwise;
When you sign agreements or provide documents or information related to your interactions with Inter ITS or when you use our products and services;
When you interact with us via phone calls (which may be recorded), correspondence, fax, face-to-face meetings, social media platforms, or email;
When you use Inter ITS’s electronic services, interact with us through the Games, Website, or Services. This includes but is not limited to interactions involving Cookies, which we may deploy when you interact with our Games, Website, or Services;
When you conduct transactions through Inter ITS’s Games or Website;
When you provide feedback or lodge complaints with Inter ITS;
When you register to participate in contests, games, events, and/or promotions related to the Games or Services of Inter ITS;
During your gameplay, use of the Website, and interaction with Inter ITS’s Services; and
When you provide your Personal Data to Inter ITS for any reason.

The above represents common scenarios in which Inter ITS collects Personal Data. It does not reflect all instances where your Personal Data may be collected.

Article 3. WHAT PERSONAL DATA DOES INTER ITS COLLECT?

Inter ITS may collect the following Personal Data, but not limited to, the basic personal information listed below:

Full name;
Email address;
Date of birth;
Identification document information (e.g., ID card, citizen identification card, passport), including date and place of issue;
Address (permanent address, contact address);
Phone number;
Gender;
Marital status;
Occupation;
Your facial image captured through devices;
Payment-related information;
Any other information about you:

When you log in to use Inter ITS Services;
When you use the Services; and
Information on how you use Inter ITS Services; and

Aggregate data about the content users consume.

To avoid any doubt, under no circumstances will we process any of your Personal Data classified as sensitive personal data as per applicable data protection laws.

You agree not to provide us with sensitive personal data, inaccurate data, or misleading data. Additionally, you agree to notify Inter ITS of any inaccuracies or changes regarding this data. Inter ITS reserves the right (at its sole discretion) to request that you provide additional necessary documents to verify the information you have provided.

If you use your social media accounts (e.g., Facebook, Google) or app accounts (e.g., Apple account) (“Social Media Accounts”) and/or your phone number to log in, use Inter ITS Services, or link to an Account you have registered with Inter ITS, you acknowledge and agree that Inter ITS may access your Personal Data when and only if you and the Social Media Account provider consent to and authorize such access.

You have the right to edit, request corrections, request access to, or delete the Personal Data you have provided to us. You may also withdraw your Consent at any time if you no longer wish for us to continue collecting your Personal Data. However, please note that declining or withdrawing your Consent for us to process your Personal Data, or requesting its deletion, may affect your ability to use our Services. Further details can be found in Section 12 below.

Article 4. COLLECTION OF OTHER DATA

As with most websites and mobile applications, the data your device sends to us may include:

Your data logged by a server when you use Inter ITS Services, including but not limited to:

IP address;
Operating system of your computer/mobile device;
Browser type;
Mobile device type, device characteristics, unique device identifier (UDID), or mobile device identifier (MEID);
Referring web address (if applicable);
Websites you visited prior to accessing Inter ITS websites or mobile apps, and the time of access;
Cookies (which can be disabled via your browser settings) that help the website remember your last visit.

Inter ITS Services may utilize technologies such as ARKit (Augmented Reality or AR), Camera API, TrueDepth API, or similar technologies provided by mobile operating systems. These technologies record facial expressions for in-app features. For such data, we do not use it for any purpose other than those explicitly provided within the application. You have the right to deny camera access for these features at any time. However, please note that disabling camera access may render some app features non-functional. We do not store or share this data with any third party.

Article 5. COOKIES

We may occasionally use “Cookies” or other features to enable us or third parties to collect or share information that helps us improve our Website, Games, and the Services we provide, or to introduce new services and features.

“Cookies” are identifiers we send to your computer or mobile device that allow us to recognize your device and know when our Services or Website are accessed, by how many users, and to track activities on our Website or Games. We may link Cookie information to Personal Data. Cookies may also be associated with information about your preferences, such as the products you viewed or the games you played. They are also used to provide content tailored to your interests and track how you use our Services.

You can decline the use of Cookies by selecting the appropriate settings in your browser. However, please note that doing so may limit your ability to use the full functionality of our Website, Games, or Services.

Article 6: HOW DOES INTER ITS USE THE PERSONAL DATA YOU PROVIDE TO INTER ITS?

Inter ITS may process your Personal Data for one or more of the following purposes:

To comply with legal procedures, adhere to applicable laws and regulations, and meet the requirements of competent government authorities;
To review and/or process your application, transaction with us, or correspondence with third parties through our Services;
To manage, operate, provide, and/or administer your use of and/or access to our Services, Websites, and Games (including, but not limited to, your preferences, Accounts, and relationships with us);
To fulfill, process, resolve, or complete a transaction and/or meet your requests regarding specific Services or products;
To notify you of Service-related matters, including abnormal Account activity;
To enforce our Terms of Service or any other agreements or applicable terms related to end users;
To protect the personal safety and rights, property, or safety of others, or those under your guardianship;
To identify and/or verify your Account;
To maintain and manage any software updates and/or other updates or support required to ensure our Services function smoothly;
To address or facilitate the resolution of customer service requests you make, respond to inquiries submitted by you or by someone on your behalf, provided the person has adequate documentation proving authorization;
To contact you via phone, text message, fax, email, mail, or other methods for purposes of managing/administrating your relationship with us or your use of our Services, including conveying information related to our Services. You acknowledge and agree that we may communicate with you via postal mail or notifications through appropriate communication means, which may disclose certain Personal Data (e.g., Personal Data written on an envelope);
To notify you when another user sends you a private message or posts a comment for you in the Games, on the Website, or through our Services;
To conduct research, analysis, and development activities (including, but not limited to, data analytics, surveys, and development/creation of product features and Services), analyzing your usage of our Services to improve them and/or enhance your customer experience;
To enable advertising campaigns, surveys, and other assessments, understand target audience composition and size, and improve their experience with Inter ITS Services;
For marketing purposes. In such cases, we may send you information, marketing materials, and promotions related to Inter ITS products and/or Services, including those from Inter ITS subsidiaries or affiliates, via various communication methods. These may relate to existing or future products or Services;
To compile statistics and research to fulfill reporting requirements and/or maintain our internal records, as required by applicable regulations or laws;
To perform due diligence, verification, or other screening activities (including, but not limited to, background checks) to comply with legal obligations or our internal risk management policies and procedures;
To audit our Services or Inter ITS operations;
To prevent or investigate actual or suspected violations of our Terms of Service, including fraud, illegal activities, misconduct, or any other wrongdoing related or unrelated to your use of our Services or arising from your relationship with us;
To store, host, or back up your Personal Data (possibly for disaster recovery purposes, including but not limited to war, fire, natural disasters, or other severe incidents), or for other reasons;
To facilitate or process a business asset transaction or potential business asset transaction involving Inter ITS, its subsidiaries, or affiliates, as a participant or with other third-party organizations. A "Business Asset Transaction" includes purchases, sales, leases, mergers, consolidations, or any other acquisition, liquidation, or financing activities of a business or part thereof; and/or
Any purpose that we notify you of at the time of seeking your consent.

For purposes that depend on specific circumstances not listed above, we will inform you of such purposes when seeking your consent, except where processing Personal Data without your consent is permitted by applicable data protection or other laws.

By providing your consent, you agree to allow us to process your Personal Data for all the purposes stated above. If you agree only to some purposes, please do not check the consent box for this Privacy Policy. However, please note that doing so may impact your ability to use our Services.

Article 7: HOW DOES INTER ITS PROTECT AND STORE YOUR PERSONAL DATA?

Inter ITS implements various security measures and makes efforts to ensure the safety of your Personal Data within its systems. User Personal Data is stored behind secured networks and is accessible only by authorized personnel with special access to Inter ITS systems. However, absolute security cannot be guaranteed.

The duration for which Inter ITS processes your Personal Data begins from the time you consent to its processing until the last time you use our Services, continuing for a minimum of 5 (five) years from that point. Even if you request deletion of your Personal Data per Section 12.2, we may still retain, use, and/or disclose your Personal Data under this Privacy Policy to fulfill our obligations under applicable data protection and other relevant laws.

Inter ITS will retain Personal Data in compliance with applicable data protection laws and/or other laws. Inter ITS reserves the right to delete Personal Data if it reasonably determines that (i) retaining such data no longer serves the purpose for which it was processed; (ii) retention is no longer necessary for any legitimate or business purpose; and (iii) no other legal interest justifies continued retention. Depending on applicable law, we may safely delete your Personal Data without prior notice.

Article 8: DOES INTER ITS DISCLOSE YOUR PERSONAL DATA?

In the course of conducting business, we may need to disclose your Personal Data to game developers, service providers, third parties, agents, and/or subsidiaries, affiliates, and/or member companies of Inter ITS, as well as other third parties, for one or more of the Purposes mentioned above. These third-party service providers, agents, and/or subsidiaries, affiliates, or member companies of Inter ITS, and/or such other third parties, will process your Personal Data on our behalf for one or more of the above-mentioned Purposes. These third parties include, but are not limited to:

Subsidiaries, affiliates, and member companies of Inter ITS;
Contractors, agents, service providers, and other third parties we engage to support our business operations. These include, but are not limited to, entities providing administrative or other services to us, such as postal services, telecommunications, IT services, and data centers;
Buyers or successors in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of Inter ITS's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings, in which Personal Data held by Inter ITS about our users is among the assets transferred; or to a partner in a business asset transaction in which Inter ITS or any of its subsidiaries, affiliates, or member companies is involved;
Authorized government agencies; and
Third parties to whom we disclose information for one of the Purposes, and who, in turn, collect and process your Personal Data for one or more Purposes.

In such cases, third parties may request us to disclose your gaming history and/or reveal records indicating which IP addresses accessed specific games. We may also share statistical information about your usage of our Services with these third parties. This information will not include any details that could be used to specifically identify you or disclose your Personal Data.

For clarity, we may disclose your Personal Data without your Consent if permitted to do so by applicable personal data protection laws or other relevant legal provisions.

Third parties may intercept or gain unauthorized access to Personal Data transmitted to or stored on the Website, software, applications, or technologies used, potentially causing inaccuracies or failures. Additionally, unauthorized persons may access, misuse, or exploit such data without our fault. While we will implement reasonable security measures to protect your Personal Data in compliance with personal data protection laws, we cannot guarantee absolute security as third parties may unlawfully access the Personal Data transmitted through games, the Website, or software, applications, and technologies used.

Article 9: PERSONAL DATA OF CHILDREN (EXCEPT CHILDREN RESIDING IN THE EU)

Our Services are diverse and cater to audiences of various age groups. For children under 16 years of age, the creation of an Account and use of our Services requires the Consent and supervision of a parent or legal guardian.

Parents or guardians of children under 16 years of age must supervise and ensure that the child under their care does not independently register an Account to use our Services and/or provide their Personal Data to us without the Consent and supervision of the parent or guardian.

If Personal Data of a child under 16 is provided to us with the Consent of a parent or guardian, the parent or guardian hereby consents to the processing and use of the child’s Personal Data and agrees to be bound by this Policy on behalf of the child. Furthermore, parents or guardians confirm and ensure that any Personal Data provided for children aged 7 or older under their care is given with the child’s Consent in addition to the parent or guardian’s Consent.

Parents or guardians of children under 16 agree that, in addition to the child’s Personal Data provided by them, we may request Personal Data from the parents or guardians themselves for the purposes outlined in Section 6.1(e) of this Policy.

We will lock any Accounts used by children that do not comply with the above requirements and will remove/delete any Personal Data we believe has been submitted by children under 16 without meeting the stated requirements.

Article 10: PERSONAL DATA COLLECTED BY THIRD PARTIES

Our Services may use analytics tools (such as Google Analytics, Facebook Pixel, etc.) (“Analytics Tools”). These Analytics Tools may use cookies, which are text files placed on your device, to help the website analyze how users interact with our Services. Information generated by cookies regarding your use of the website (including your IP address) will be sent to and stored by the providers of the Analytics Tools. These providers will use the information to evaluate your use of our Services, compile reports on website activity for website operators, and provide other services related to website activity and internet usage.

Our Services may also use mobile measurement tools (such as AppsFlyer, Adjust, Firebase, etc.) (“Mobile Measurement Partners” or “MMPs”). MMPs utilize Software Development Kits (“SDKs”) installed on your device to help us track and optimize the delivery of our Services to you. Information generated by the SDKs regarding your use of our applications (including your IP address) will be sent to and stored by MMP providers. These providers will use the information to evaluate your use of our Services, compile reports on app activity for developers, and provide other services related to app activity and internet usage.

We and third parties may provide downloadable software applications for your use on or through our Services. These applications may independently access and allow a third party to view your identifiable information, such as your name, user ID, device IP address, or other information such as the games you are playing during any specific session, as well as any cookies or SDKs you have previously installed or that were installed on your behalf by a third-party website or application. Additionally, these applications may require you to provide further information directly to the third parties. The products or services of these third parties provided through these applications are not owned or controlled by Inter ITS. You are advised to review the terms and policies published by these third parties on their websites or elsewhere.

Article 11: DISCLAIMER ON CONFIDENTIALITY AND THIRD-PARTY WEBSITES

INTER ITS DOES NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION YOU PROVIDE ON THIRD-PARTY WEBSITES OR APPLICATIONS.
We implement various security measures to maintain the safety of your Personal Data stored or controlled by us. Your Personal Data is stored behind secure networks and is accessible only by a limited number of individuals with special access rights to our systems, who are required to keep the data confidential. When accessing our Services or your Personal Data, we recommend using a secure device. All Personal Data you provide is encrypted into our databases to be accessed only as described above.

To provide added value, we may include links to third-party websites and frame them within our Website or Games. We may also enter into co-marketing and other relationships to provide e-commerce, advertising, and other services and features to visitors. These linked sites have their own privacy policies and security measures, which are separate and independent. Even if a third party is affiliated with us, we do not control these linked sites, each of which has independent privacy and data collection practices. Data collected by our co-marketing partners or third-party websites (even if offered on or through our Website or Games) may not be received by us.

Therefore, we are not responsible or liable for the content, security measures (or lack thereof), or activities of third-party websites or applications. We strive to protect the integrity of our Website and Games and the links placed on each, and we welcome feedback about these linked websites (including, but not limited to, if a specific link is non-functional), using the contact information provided in Section 15 of this Policy.

Article 12: HOW CAN YOU WITHDRAW CONSENT, EDIT, REQUEST EDITS, PROVIDE, OR DELETE THE PERSONAL DATA YOU PROVIDED TO US?

Withdrawal of Consent
You can withdraw your consent for the collection, use, and/or disclosure of your Personal Data stored or controlled by us through the methods specified on our Account settings page. We will process your request in accordance with this Privacy Policy, the instructions, and the procedures specified on the Account settings page and our obligations under applicable law.

You acknowledge that your withdrawal of consent will not affect the legality of the processing based on consent before its withdrawal.

However, you should note that withdrawing consent will mean we can no longer provide Services to you, and we may need to terminate our relationship with you and/or your contract with us without compensation for any losses you may incur.

Editing, Requesting Edits, Providing, or Deleting Personal Data
If you have registered an Account with us, you may access and edit your Personal Data collected, stored, or controlled by us through the available system. If you have not registered an Account with us, or for certain Personal Data with specific procedures, you may request to edit your Personal Data stored or controlled by us through the methods specified on our Customer Support page. We will process your request in accordance with this Privacy Policy, our Customer Support procedures, and our legal obligations.

You may track your Personal Data stored or controlled by us by reviewing it on your Account settings page or by requesting it through other methods outlined in our Customer Support procedures. Your legal guardian or authorized representative may also make a request on your behalf. We will process such requests in compliance with this Privacy Policy, our Customer Support procedures, and applicable legal obligations.

You may request that we delete your Personal Data stored or controlled by us if (i) you believe it is no longer necessary for the purposes for which it was collected, (ii) you withdraw consent under Section 12.1, (iii) you object to its processing and we lack a legitimate reason to continue, (iv) it is processed inconsistently with the purposes for which consent was given, or (v) other legal reasons under applicable data protection laws. Personal Data deletion requests can be made as instructed on our Account settings page. However, please note that requesting data deletion means we will no longer be able to provide Services to you, and we may need to terminate our relationship and/or contract without compensation for any losses you incur.

In all cases, we require sufficient information from you to verify your identity and the nature of your request to process it appropriately under our procedures.

We may charge a reasonable fee for processing your request. If we do, we will inform you in writing or via email of the cost and payment deadline. You are required to pay this fee (if applicable) within the specified time frame for your request to be processed promptly.

We reserve the right to deny requests to provide or delete Personal Data in specific cases as permitted by law.

Article 13. SUPPLEMENTARY PROVISIONS FOR USERS IN EUROPEAN UNION (EU) MEMBER COUNTRIES

Data Portability

You have the right to receive from us the Personal Data that you have previously provided to us, as well as data processed based on your consent, in a structured, commonly used, and machine-readable electronic format. You also have the right to request that we transfer this Personal Data to another party.

If you wish for us to transfer your Personal Data to a third party, please provide the detailed information of the third party. Note that we can only fulfill your request if it is technically feasible. We will not be responsible for the security of the Personal Data or any data derived from the processing of your Personal Data once the third party receives it. Furthermore, we may not provide certain Personal Data if doing so would infringe upon the rights of others (e.g., if providing the Personal Data we collected would reveal information about another individual).

Data Deletion

You may request us to delete your Personal Data that we have collected under the following circumstances:

You believe that the Personal Data is no longer necessary for us to retain;
We process your Personal Data based on your consent, and you wish to withdraw this consent. Additionally, we have no other legal or intended purpose to continue processing the data;
We process your Personal Data based on our legitimate interests, and you object to this processing. Please provide sufficient details to help us evaluate whether your objection outweighs our legitimate interests;
You no longer wish for us to use your Personal Data to send advertisements, special offers, sales programs, or promotional campaigns; or
You believe that your Personal Data has been unlawfully processed by us.

Please provide as much detail as possible about the reasons for your request to help us determine whether you have a valid basis for the deletion. However, we may retain Personal Data if we have a legitimate legal basis for doing so (e.g., to comply with local laws where Inter ITS or its subsidiaries operate, to protect ourselves against legal claims, or to ensure freedom of expression). If we retain your data for these reasons, we will inform you.

Please note that once your Personal Data is deleted, we may no longer be able to provide the same level of service as before, as we will no longer have information about your preferences.

You should also be aware that certain countries (e.g., Vietnam) and territories mandate that service providers like Inter ITS retain user information and Personal Data for a specific period (which may be up to 5 years) (“Retention Period”) from the last time the user used the services. In such cases, the laws of these countries or territories will take precedence, and your request to delete your Personal Data can only be fulfilled after the Retention Period has ended.

Data Storage of Personal Data

Objection to Profiling-Based Sales Programs and Targeted Marketing

You may object to our use of your Personal Data for profiling or targeted marketing campaigns at any time.

Limiting Data Processing to Storage Only

You may request that we restrict processing of your Personal Data to storage only in the following cases:

You believe your Personal Data is inaccurate, and you require time for us to verify its accuracy;
We wish to delete your Personal Data, but you prefer that we store it instead;
We no longer require your Personal Data for our purposes, but you need us to retain it for legal claims, enforcement, or defense; or
You object to our processing of your Personal Data based on our legitimate interests, and you wish for us to cease processing while determining whether the processing or storage is justified.

Transfer of Personal Data Outside of the EU

If your Personal Data needs to be transferred outside of the EU, this will be done following applicable data protection laws and the provisions of this Policy.

Children's Information

We do not knowingly collect or process Personal Data of children without appropriate parental or guardian consent. If you believe we have collected data of a child under applicable age restrictions, please contact us immediately.

Article 14. STORAGE OF PERSONAL DATA AND TRANSFER TO OTHER COUNTRIES

For services provided to the Vietnamese market by Inter ITS and/or its subsidiaries, affiliates, or member companies headquartered in Vietnam, your Personal Data will be stored in Vietnam in compliance with Vietnamese laws.

For EU users, the provisions of Section 13 of this Policy will apply.

Article 15. QUESTIONS, FEEDBACK, AND CONTACTING INTER ITS

If you have any questions, feedback, or inquiries about this Policy, please contact us at the email address: xuanht@metfone.com.kh