User Privacy Policy

1. Introduction

1.1 Welcome to the products and services operated by Divine Games Limitedhereinafter referred to as "Divine Games Limited" or "we"). Divine Games Limited strictly fulfills the legal obligations regarding personal data protection and is committed to respecting the privacy of all users of our products, services (hereinafter referred to as "services"), and websites (hereinafter referred to as "website"). We fully understand the importance of the personal data you trust and provide to Divine Games Limited and are committed to lawfully protecting and processing your personal data. This Personal Data Protection Policy (hereinafter referred to as "this policy") aims to help you understand the purposes and methods Divine Games Limited uses to process your personal data and to assist you in making an informed decision before allowing us to process any of your personal data.

1.2 Abbreviations and Definitions:

(a) "Services" refers to the cloud services and/or any products and services provided by Divine Games Limited;

(b) "Personal data" refers to information expressed in symbols, words, numbers, images, sounds, or similar forms that relate to or can be used to identify a specific individual. Information that can identify a specific individual includes data generated by individual activities, which, when combined with other stored data or information, can identify a specific person. Personal data includes basic personal data and sensitive personal data (according to Decree No. 13/2023/ND-CP).

2. When will Divine Games Limited collect personal data?

2.1 Divine Games Limited will/may collect your personal data in the following situations:

(a) When you register and/or use Divine Games Limited\' services or website, or create an account with us;

(b) When you submit any forms, including but not limited to application forms or other forms related to Divine Games Limited\' products and services, whether online or in other formats;

(c) When you sign any agreements or provide other documents or information related to your interactions with Divine Games Limited, or when you use our products and services;

(d) When you interact with us, for example, via phone calls (which may be recorded), letters, faxes, face-to-face meetings, social media platforms, or emails;

(e) When you use Divine Games Limited\' services, or interact with us through phone, website, or services (including but not limited to cookies that we may deploy while you are using our services or website);

(f) When you conduct transactions through Divine Games Limited\' homepage or website;

(g) When you provide feedback or submit complaints to Divine Games Limited;

(h) When you register for a competition or participate in promotional activities;

(i) When you submit your personal data to Divine Games Limited for any reason.

2.2 The above are just some common situations in which Divine Games Limited collects your personal data and do not cover all circumstances in which Divine Games Limitedmay collect your personal data.

3. What data will Divine Games Limited collect?

3.1 Divine Games Limited will only collect your basic personal data, including one or more of the following:

(a) Name;

(b) Email address;

(c) Date of birth;

(d) Identification document information (such as ID card, national ID, passport, including issue date and place of issue);

(e) Residential address;

(f) Payment method information, excluding client information from credit institutions, foreign bank branches, intermediary payment service providers, or other authorized entities;

(g) Phone number;

(h) Gender;

(i) Facial photos taken by your device;

(j) Information transmitted by the device related to your access to Divine Games Limited  services;

(k) Any other information you provide when logging into and usingDivine Games Limited  services, as well as information related to how you use Divine Games Limited services;

(l) Aggregated data of user-generated content.

3.2 You are responsible for providing complete and accurate personal data, and agree not to provide any inaccurate or misleading information. You agree to promptly notify Divine Games Limited if any information is found to be inaccurate or if there are any changes. Divine Games Limited has the right to request additional necessary documents to verify the information you have provided.

4. Collection of Other Data

4.1 Similar to most websites, when you submit information, the Divine Games Limited servers may record data related to your actions while using Divine Games Limited services. This information typically includes, but is not limited to:

• IP address

• Operating system of your computer/mobile device

• Browser type

• Type of mobile device

• Referring website address (if applicable)

• Pages visited on the Divine Games Limited website and visit times.

Sometimes, this information may include "cookies" (which you can disable through browser settings) to help the website record the last time you visited. If you are logged in, this information will be associated with your personal account. These details are also incorporated into anonymous statistical analysis to help us understand how customers access and use our services and website.

4.2 Divine Games Limited services may use technologies such as the Camera API or other similar technologies provided by the mobile operating system. These technologies are used to capture facial expression information from users and are applied within specific features of the app. We will not use this information for any purpose other than app functionality. You have the right to refuse camera access at any time (however, please note that some app features may not function properly if you revoke camera access). We do not store this information nor share it with any third parties.

5. COOKIES

5.1 At times, we may use "cookies" or other functionalities to help us or third parties collect or share information. This helps us improve our website and services or assist us in developing new services and features. A "cookie" is an identifier sent to your computer or mobile device, used to recognize your device and inform us when and by how many people our services or website are used or accessed, as well as track activity on our site. We may associate cookie information with personal data. Cookies may also be linked to content information you select on shopping pages, such as products you have viewed or services you have used. The uses of this information include, but are not limited to, tracking the contents of your shopping cart. Cookies are also used to deliver content based on your interests and monitor service usage.

5.2 You can choose to reject the use of cookies by adjusting the settings in your browser. However, please note that if you do so, you may not be able to use all the features of our website or services.

6. How does Divine Games Limited use your personal data?

6.1 Divine Games Limited may process your personal data for one or more of the following purposes:

(a) To review and/or process your registration application/transaction with us, or transactions or communications with third parties conducted through our services;

(b) To manage, operate, provide, and/or supervise your use and access to our services and website (including but not limited to your preferences), as well as to manage the relationship and user account between you and us;

(c) To respond to, process, resolve, or complete a transaction, and/or fulfill your requests for specific products and services, while notifying you of any issues with services or account activities;

(d) To enforce our terms of service or other applicable end-user license agreements and usage terms;

(e) To protect personal safety and the rights, property, or safety of others;

(f) To perform identity verification and/or authentication;

(g) To maintain and manage software updates and other necessary support to ensure the smooth operation of our services;

(h) To answer or assist customer service, carry out your instructions, resolve or respond to any questions you or representatives submit;

(i) To contact you via phone, SMS, fax, email, mail, or other methods to manage your relationship with us or your use of our services, such as conveying administrative information related to our services. You acknowledge and agree that our methods of contact may include postal mail or documents, which could involve the disclosure of some of your personal data (such as information on the envelope);

(j) To notify you when other users send private messages or leave comments on the website;

(k) To conduct research, analysis, and development activities (including but not limited to data analysis, surveys, development, and/or product and service feature design), analyze how you use our services, improve our services or products, and enhance your user experience;

(l) To allow for advertising and conduct checks or investigations, such as verifying the size and composition of game players and understanding their experience with our services;

(m) For marketing purposes, sending you marketing and promotional materials related to products and/or services through various communication methods (including but not limited to products or services from third parties we collaborate with or are in contact with). You can unsubscribe at any time via the opt-out feature in our electronic marketing materials or by visiting the personal data page on Divine Games Limited website. We may use your contact information to send you newsletters from us or Divine Games Limited subsidiaries and affiliates;

(n) To comply with legal processes or requirements from relevant laws and regulatory authorities;

(o) To create statistical data and research, meet reporting needs, and/or maintain internal or statutory records;

(p) To perform due diligence and other auditing activities (including but not limited to background checks) to comply with legal or regulatory requirements or risk control procedures implemented by us;

(q) To inspect the operation of our services or Divine Games Limited;

(r) To prevent or investigate any actual or suspected violations of our terms of service, fraudulent activity, illegal actions, misconduct, or other behaviors related to your use of our services, or issues concerning your relationship with us;

(s) To store, host, and back up your personal data (whether for disaster recovery or other purposes);

(t) To process and/or facilitate asset transactions or potential asset transactions. Asset transactions refer to buying, selling, leasing, merging, consolidating, liquidating, or financing activities involving Divine Games Limited or its subsidiaries/affiliates, or parties in collaboration with third parties;

(u) For other purposes that we have explained to you when seeking your consent. (Collectively referred to as "Purposes")

6.2 We may process your personal data for purposes not listed in the above terms based on specific circumstances. However, where permitted by law, we will notify you of these additional purposes after obtaining your consent.

7. How does Divine Games Limited protect and store personal data?

7.1 Divine Games Limited places great importance on complying with personal data protection laws and takes multiple security measures to ensure the safety of your personal data within Divine Games Limited systems. Users\' personal data is stored behind secure networks, and access to the relevant data in Divine Games Limited system is restricted to a limited number of authorized employees. However, we cannot guarantee absolute security.

7.2 Divine Games Limited will retain your personal data in accordance with personal data protection laws and/or other applicable legal regulations. This means that Divine Games Limited will delete or destroy your personal data when one of the following conditions is met: (i) The retention of that personal data can no longer achieve the original purpose for which it was collected; (ii) The retention of that personal data no longer fulfills any legal or business purposes; (iii) There is no other legal basis for continuing to retain that personal data, or in cases defined by other legal provisions. If you stop using Divine Games Limited services, or if your website and/or service usage rights are terminated or revoked, we may still retain, use, and/or disclose your personal data in accordance with this policy and personal data protection laws and/or other applicable legal regulations. As permitted by applicable laws, we may securely destroy your personal data without prior notice.

7.3 To ensure the security of your personal data, Divine Games Limited will encrypt the data after collection in accordance with this policy, and store it in a database.

8. Will Divine Games Limited games disclose your personal data?

8.1 In the course of our business activities, Divine Games Limited may need to disclose your personal data to Divine Games Limited agents, subsidiaries, affiliates, and/or other third parties to achieve one or more of the purposes outlined above. These third-party service providers, agents, subsidiaries, affiliates, and other third parties will process your personal data on our behalf to achieve one or more purposes. These third parties include: (a) As necessary,Divine Games Limited subsidiaries, affiliates; (b) Contractors, agents, service providers, and other third parties we hire to support our business operations. These third parties include, but are not limited to, companies providing administrative or other services such as postal services, telecommunications companies, information technology companies, and data centers; (c) In the event of a merger, split, restructuring, dissolution, or sale or transfer of all or part of Divine Games Limited assets, the buyer or successor, whether the matter is ongoing or in bankruptcy, liquidation, or similar procedures, in which case user personal data owned by Divine Games Limited will become part of the transferred assets; or any parties involved in business asset transactions with Divine Games Limited or its subsidiaries or affiliates; (d) For the purposes above, we may disclose information to third parties who will also collect and process your personal data in accordance with these purposes.

8.2 In certain cases, in addition to other requirements, it may be necessary to disclose your service usage history and/or disclose records showing which IP addresses accessed which websites. We may also share statistical information about our users and their use of services with advertising service providers and program developers. This information will not include any personal data that can be used to identify you, nor will it disclose your personal information.

8.3 To avoid doubt, where permitted by personal data protection laws or other applicable legal provisions, if the law allows us to collect, use, or disclose your personal data without requiring your consent, such actions permitted by the law will remain valid.

8.4 Third parties may block or illegally access the personal data you send to the website or application, and certain applications, technologies, or programs may not function as expected, or may operate incorrectly, or there may be unauthorized access, misuse, or wrongful use of your information by others outside of our control. However, we will take reasonable security measures to protect your personal data in accordance with personal data protection laws, but we cannot guarantee absolute security. For example, if unauthorized disclosure occurs due to a hacker attack or the complexity of malicious content, this should not be considered our responsibility.

9. Children\'s Information (Divine Games Limited Does Not Collect)

Our services are only available to individuals who are 18 years old or older, and we require users to guarantee that they are at least 18 years old when providing personal information and relevant documents. Divine Games Limited does not provide services to individuals under the age of 18.

10. Information Collected by Third Parties

From time to time, we and third parties may provide applications for download for use within our services. These applications may be accessed independently and allow third parties to view your identifying information, such as your name, user ID, device IP address, or other information, including services you used during a specific visit, as well as cookies and SDKs that may have been installed by third-party applications or websites that you previously installed. Additionally, these applications may require you to provide further information directly to third parties. The products or services provided by these third parties are not owned or controlled by Divine Games Limited, and you should read the terms and policies published by these third parties on their websites or elsewhere.

11. Disclaimer Regarding Confidentiality and Third-Party Websites

11.1. Divine Games Limited does not guarantee the confidentiality of personal data and/or other information you provide on third-party websites or applications. We take various security measures to ensure the safety of your personal data stored or controlled by us. Your personal data is stored behind secure networks, and only a limited number of authorized employees with special access can view this data, and they are required to protect it. We recommend using secure devices when placing orders or accessing your personal data. All personal data you provide will be encrypted in our database and can only be accessed as described above.

11.2. To provide you with additional value, we may choose to link to third-party websites and embed them into our website or services. We may also participate in co-marketing and other partnerships to provide visitors with e-commerce services, advertising, and other services and features. These linked websites have their own privacy policies and security measures. Even though a third party may be affiliated with us, we cannot control these linked websites, each of which has its own privacy protection and data collection practices that are unrelated to us. Data collected by our marketing partners or third-party websites (even if provided through our website or services) may not be received by us.

Therefore, we are not responsible for the content, security measures (or lack thereof), and operations of these linked websites. These links are provided for your convenience, and you assume the risk of accessing these websites. However, we will strive to protect the integrity of our website and services, as well as the links set on each website, and welcome feedback on these linked websites (including, but not limited to, cases where a website is not functioning properly).

12. How to Withdraw Consent, Request Access, Provide, Delete, or Modify Your Personal Data

12.1. Withdraw Consent

You may withdraw your consent for the processing of your personal data stored or controlled by us by sending an email to our Personal Data Protection Department at cs@wegtec.com. We will process your request in accordance with this Privacy Policy and applicable laws. Withdrawing consent does not affect the legality of the data processing that occurred before the withdrawal. Please understand that withdrawing consent to process your personal data may result in your inability to use our services or access Divine Games Limited website, which may lead to personal losses. In such cases, Divine Games Limited will be exempt from liability.

12.2. Request Access or Modify Personal Data

(a) If you have registered an account with us, you can access and/or modify the personal data we store or control through your account settings page or on our website or services. If you have not registered an account, you can request access or modification of your personal data by submitting a written request. To process your request, we require sufficient information to confirm your identity and the content of the request. Please send your request via email to our Personal Data Protection Department at cs@wegtec.com.

(b) We may charge a reasonable fee for processing requests to access personal data. If we charge a fee, we will provide an estimate of the fee in writing or via email. Please note that we are not obligated to respond to or process your access request unless you agree to pay the fee.

(c) In accordance with personal data protection laws, we have the right to refuse to modify your personal data if required and/or permitted by law.

12.3. Provide Personal Data

(a) You have the right to request that we provide your personal data to you or to a third-party entity or individual you designate. You can send a request for the personal data provision form to our Personal Data Protection Department via email at cs@wegtec.com.

(b) We may charge a reasonable fee for processing requests to provide personal data. If we charge a fee, we will provide an estimate of the fee in writing or via email. Please note that we are not obligated to respond to or process your request unless you agree to pay the fee.

(c) In accordance with personal data protection laws, we have the right to refuse to provide your personal data if required and/or permitted by law.

12.4. Delete Personal Data

(a) You can request that we delete the personal data we have collected about you by sending an email to our Personal Data Protection Department at cs@wegtec.com, under the following circumstances:

(i) You believe the data is no longer necessary for the purposes it was originally collected, and you accept the risks of deleting the data;

(ii) We process your personal data based on your consent, and you wish to withdraw consent with no other legal basis for us to continue processing your personal data;

(iii) You object to our processing of your personal data, and we have no legitimate reason to continue processing it;

(iv) You believe our processing of your personal data does not align with the original purpose or is unlawful;

(v) The data must be deleted as required by law.

(b) Please provide as much detail as possible so we can assess whether you have valid grounds to request deletion. However, if there is a legal basis, we may retain your personal data (e.g., due to legal requirements, or to protect ourselves from legal claims, or to safeguard freedom of speech). We will notify you of such cases. Please note that once your personal data is deleted, we may not be able to provide services as before since we will no longer know your preferences.

(c) Under relevant regulations, service providers like Divine Games Limited are required to retain user personal data for at least two years from the last use of the service ("Retention Period"). Therefore, your deletion request can only be processed after the retention period ends. We will make efforts to delete your personal data within 30 days after your request, and will notify you if more time is required.

12.5. Storage of Personal Data

We will store your personal data during the time you use our services and continue to store it for three (3) years after your last visit and/or use of the service ("Retention Period"). If the data is necessary for us to continue providing services or for legal requirements (e.g., tax, accounting, auditing regulations), the retention period may be extended.

12.6. Oppose Marketing Based on Personal Data

You have the right to object to our processing of your personal data for sending advertisements, special offers, or sales information, including profiling activities we conduct based on your personal data. In this case, we will stop processing your personal data for these purposes. Please provide sufficient details to help us assess whether you have legal grounds for objecting, and you can contact our Personal Data Protection Department via email at cs@wegtec.com. However, if we have legitimate grounds, we may retain your personal data and continue processing it.

12.7. Limit Processing of Personal Data to Storage Purpose

You have the right to request that we limit the processing of your personal data to only storage purposes. You can contact our Personal Data Protection Department via email at cs@wegtec.com under the following conditions:

(a) You believe your personal data is inaccurate and need time to verify its accuracy;

(b) We wish to delete your personal data, but you request that we store it only;

(c) We wish to delete your personal data because it is no longer necessary for our purposes, but you request we store it for establishing, performing, or defending legal claims; or

(d) You object to our processing of your personal data based on our legitimate interests, and you wish us to stop processing your personal data until we determine the necessity of processing it.

13. Inquiries, Concerns, or Complaints

If you have any questions or concerns about this policy, please contact us via email at divinegames@outlook.ie .