Date of Last Revision: December 25, 2023
This Privacy Policy (“Policy”)explains how we(“we”, “us”or “our”) collect, use, and share the information you (“user”, “you” or “your”) provide when you use our applications, websites, and all relating to services and products (“Services”).We consider the protection of information to be one of the most important management issues as a responsibility of an Internet content service provider. We will act in compliance with the laws and regulations applicable in countries and regions where we are conducting business (such laws and regulations are hereinafter collectively referred to as the “Applicable Laws”), and will make efforts to properly protect your information based on this Policy.
This Policy applies to any and all of Services and describes why and how we collect, store, and use your information, and the choices and rights you have about the information you provide or that we collect in connection with our Services. BY ACCESSING OUR WEBSITES OR OTHERWISE USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND ACCEPTED THE FOLLOWING TERMS. In case you do not agree to any of the terms, some basic functions in our Services may not be able to run normally, which may prevent you from using them.
We may periodically modify, adjust, or revise the terms of this Policy. We will announce to you the updated terms and obtain your consent (and/or the consent of your parent/guardian, if applicable) again. YOU ACKNOWLEDGE AND AGREE TO CHECK THE UPDATED TERMS REGULARLY. IF MAJOR CLAUSE CHANGES ARE INVOLVED, WE WILL MAKE AN ANNOUNCEMENT IN ADVANCE.
We may collect the following information about you:
Your profile information. You voluntarily give us information when you register our Services, including your username, password, information you disclose in your user profile.
Connected social media account information (third-party). Your social media account information (if you choose to log in to our services via your social media account(s) with the corresponding network(s)). In the case of Facebook, this refers to the email address and public profile of your Facebook account; in the case of Google, this refers to the account ID and the email address of your Google Account. We use such information to create your account for using our services in accordance with your request.
Proof of your identity or age. We sometimes ask you to provide proof of identity or age in order to use certain features, such as when you log in, we may ask you to register your age so that we can determine if you are suitable to experience/use our application.
User content. We process the content you generate on the Services, including audios and videos you upload or create, comments, feedback, reviews, and the associated metadata, such as when, where, and by whom the content was created (“User Content”).
User service information. Any information that you provide in communication with our support team, when you seek our technical and/or customer service support, and/or exercise any of your legal rights as the information subject. When receiving your request for support, we use such information to provide relevant support as you request. When receiving your request as the information subject, we use such information to verify the requestor’s identity to ensure that he/she is the person legally entitled to make the information access request or other request in accordance with Applicable Laws.
Messages. We collect information you provide when you compose, send, or receive messages through our Services. That information includes the content of the message and information about the message, such as when it was sent, received, or read, and message participants.
Purchase information and transaction records. If you purchase a product or a service, you will be required to provide information for making the payment of such product or service. Since credit card settlements are processed by appropriate third-party payment agencies, we will not retain your credit card number or security code.We may collect your transaction information such as the transaction serial number and transaction historical records after you purchased in order to resolve the transaction disputes.
If you choose to participate in our surveys or events, we may ask you to provide information such as your address, phone number, email address in order to verify your identity, enable you to participate in the events, and to deliver any prizes you may win.
Usage information. We collect information regarding your use of the Services, e.g., how you engage with other users and the users you follow.
Bugs, errors, and other information about crashes and diagnosis thereof. We use such information to conduct identity verification for security purposes, to identify and address bugs, and to evaluate and improve the functionality of our Services.
Cookies. We and our service providers and business partners use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze how you use the Services,enhance your experience using the Services and improve the Services.
Device information. Device ID, device information (name, device type, MAC address, IMEI, CPU, graphics card model, OS version and language, time zone, screen DPI, device resolution), registration time and login time. We use such information to provide and improve our Services thereof.
Malicious content information. In order to ensure a harmonious and healthy online environment in our Services, we collect malicious content information to avoid some words that may offend or distress other users via your nickname and/or chat information within the Services.
We may receive the information described in this Policy from other sources, such as:
We may obtain information about you from certain affiliated entities within our group companies, including about your activities on their applications, websites, and platforms.
We may receive information about you from others, including where you are included or mentioned in User Content, in a complaint, appeal, request or feedback submitted to us, or if your contact information is provided to us.
We may collect information about you from other publicly available sources.
We may receive information from payment fulfillment providers about you, such as about the delivery of products you have purchased.
In order to provide the Services, perform the Terms of Service, and/or any other agreements between you and us, and/or perform the legal liabilities under the Applicable Laws, we collect and process your information to:
allow you to access or restrict your access to the Services;
analyze and manage our services for system administration, user service, security, fraud-detection, checking the authenticity of an account owner, archival and/or backup purposes;
correct bugs or errors, improve our services and respond to customer desires and preferences, including language and location customization, personalized support and instructions, and other responses;
develop new services or products which user(s) request and improve the user experience;
verify and confirm payment;
deliver advertising that may be relevant to your interests (you can choose to turn this feature on or off in the device settings as stated hereunder);
communicate with other users and take action against violations;
personalize your experience, keep you up to date with the latest product announcements, provide software verification, upgrades and administration, notify special events, offer to participate in our surveys or activities, and provide other information pertaining to our services;
protect the integrity, safety, and security of our services, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of our services; and/or
track your process across our websites and applications to verify that you are not a bot and to optimize our services.
For the purposes set forth above, our affiliates may be commissioned to process your information, provided that such affiliates comply with the terms and conditions hereunder. Affiliates in this Policy shall mean an entity that directly or indirectly controls, is controlled by, or is under common control with us hereto.
In all of the above cases and purposes, you acknowledge and confirm that we may analyze, profile, segment, merge, and/or update all collected information (regardless of whether in an aggregated or individualized manner) for the purposes of improving service quality and providing a better experience.
In specific cases, we may collect other information apart from the categories stated herein based on your consent. When this occurs, we will, upon requiring your additional consent, provide more information about any change to the way or purpose of our collection or processing which might be different from or not clarified in detail in this Policy.
UNDER ANY CIRCUMSTANCE WHERE OUR COLLECTION OR PROCESSING OF YOUR INFORMATION IS BASED ON YOUR CONSENT, YOU MAY WITHDRAW SUCH CONSENT AT ANY TIME WITH NO IMPACT ON THE VALIDITY AND LAWFULNESS OF COLLECTION OR PROCESSING BASED ON THE CONSENT MADE BEFORE ITS WITHDRAWAL.
We will not provide, disclose or share your information to or with third parties unless we have obtained your consent or such provision, disclosure or sharing of your information is permitted under Applicable Laws. However, we may provide your information to the following third parties:
If you choose to register to use the Services using your social network account details (e.g., Facebook, Google), you will provide us or allow your social network to provide us with your phone number, email address, username and public profile, if any. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you grant, the third party may be able to obtain your account information and other information you choose to provide.
We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services to ensure that the Services is safe and enjoyable.
Payment providers: If you choose to buy Virtual Items or conduct other payment related transactions, we will share information with the relevant payment provider to facilitate this transaction. For Virtual Items transactions, we share a transaction ID to enable us to identify you and credit your account with the correct value in Virtual Items once you have made the payment.
Analytics providers: We use analytics providers to help us in the optimization and improvement of the Services.
Each service provider has its own privacy policy and security measures for processing information, so when specific third-parties are involved in collecting information, please participate in their privacy policies. Since those contractors may access, collect, or process your information as the information controller and operate under their own privacy policies, please refer directly to their privacy policies on their official websites and learn more about their information processing practices.
3.3 Competent authorities
We may provide a certain portion of your information to judicial or administrative authorities as requested. Besides, we may disclose a certain portion of your information within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users, or a portion of the public.
In addition, as required by the Applicable Laws, we reserve the right to disclose your information in the cases that we, in our good faith, believe that disclosing such information is necessary to identify, contact, or bring legal action against you, if (a) you are violating any other agreements between you and us, such as the Terms of Service, this Policy, or otherwise damage us; (b) you are infringing third-parties’ rights and interests (including but not limited to intellectual property rights); and/or (c) we believe that it is necessary to prevent fraud or other illegal activities.
We may also share your information with other members, subsidiaries, or affiliates of our group companies, including to provide the Services, to improve and optimize the Services, to prevent illegal use and to support users.
We may also disclose your information to third parties:
in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your information to the prospective seller or buyer of such business or assets; or
if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
We will keep your information only for as long as your account is active or only for as needed to provide you the Services unless deleted in accordance with your request or as otherwise required by Applicable Laws. You acknowledge and agree that your information will be processed on our servers which may not be located in your country/region of residence. However, please remember that no matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Policy and any Applicable Laws.
In case you request to remove or delete your information, we will retain your information as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your information may result in the termination of some of our applicable services.
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where the Applicable Laws provide for longer storage and retention periods. Upon expiration of such period, your information will be deleted, blocked, or anonymized, in accordance with the Applicable Laws.
We have endeavored to take reasonable technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will use reasonable measures to protect your information, for example, by encryption, we cannot guarantee the security of your information transmitted via the Services; any transmission is at your own risk.
Please be aware that service providers with links to and/or from our Services may collect information about you and this Policy does not apply to, and cannot control the activities of, those other service providers. We highly recommend that you read the privacy policy of such service providers.
If you request in writing, we will provide you a copy of your information in an electronic format after passing our verification process. You also have the right to correct or modify your information, have your information deleted, object to how we use or share your information, restrict how we use or share your information, and make any other request as provided herein or regulated by the applicable regulations of the relevant authorities through sending an email to contact@vrole.ai. Upon receiving your request email, we will promptly conduct a verification process and make a response.
You have the right to access your information, i.e. the right to require free of charge, (i) information whether your information is collected, used, disclosed, or shared, (ii) categories of your personal information that have been collected in the preceding 12 months, (iii) categories of sources from which your information is collected, or (iv) business or commercial purpose for collecting or sharing your information (if any). You can also exercise the right to access your information through your profile on the Services. According to our reasonable and unilateral judgement, if your verifiable request affects or will affect the rights or freedom of other users or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs arising therefrom) or refuse to act on the request.
If we process your information, we shall endeavor to ensure, by implementing suitable measures, that your information is accurate and up-to-date for the purposes for which it was collected. If your information is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate information without undue delay according to Applicable Laws (such as GDPR)and you can modify the information you provided via your profile on the Services.
You have the right to obtain deletion of your information if the reason as stated in Section 2 of this Policy does not exist anymore, or if there is another legal ground for its deletion, you can through your profile on the Services or contact us log out your user account and delete all your information. If you want to withdraw your request, please login in and reactivate the game account within 15 days from submitting the application.You acknowledge and agree that as a result of deleting your account, you will lose access to our Services, your Virtual Items and other entitlements will be cleared. ONCE DELETION IS COMPLETE IT WILL BE IRREVERSIBLE, PLEASE PROCEED WITH CAUTION.
When our processing of information is based on Applicable Laws (such as GDPR) in your country/region of residence, you have the right to object to our processing. If you object, we will no longer process your information unless the information is necessary for the establishment, exercise, or defense of legal claims.
You have the right to restrict the processing of your information under the Applicable Laws (such as GDPR) in your country/region of residence.
You have the right to receive your information in a structured, commonly used, and machine-readable format and have the right to transmit that information to another controller under the conditions set out Applicable Laws(such as GDPR) in your country/region of residence.
You have the right to opt-out of the sale of your information (if any) and require us to make a statement regarding whether or not we sell your information and provide an opt-out mechanism or link to it except as otherwise stipulated in the CCPA.
You have the right not to receive discriminatory treatment by us for the privacy rights conferred by the CCPA, namely that we shall not offer financial incentive or a price or service difference due to your exercise of any of your rights under the CCPA unless such difference is reasonably related to the value of your information. Notwithstanding the foregoing, we have the right to deny your request to know, request to delete, or request to opt-out for reasons permitted by the CCPA or those regulations thereof, and such denial shall not be considered discriminatory.
You have the right to authorize an agent on your behalf to make a request to know, delete, or opt-out under the CCPA. When you use an authorized agent to submit any request provided above, we may require you to provide signed permission to authorize your agent to do so for the purpose of verifying your own identity, and the official permission by your agent to submit this request. In the case of failure to provide any of the requested materials, to protect the user’s information and information/data security, we are entitled to denying such request.
Notwithstanding the foregoing, if the Applicable Laws in your country/region of residence provide otherwise, such laws shall govern.
You represent and warrant that when you using our Services, you comply with the age requirements of the country/region in which you reside (or in your jurisdiction), and you have the right capacity and legal capacity required for using our Services.
The Platform otherwise is not directed at children under the age of 18. If we become aware that personal information has been collected on the Platform from a person under the age of 18 we will delete this information and terminate the person’s account.
If you are a minor or under the legal age of majority (“Minor” or “Children”), please do not send any information about yourself to us, including your name, address, telephone number, or email address.
Notwithstanding the foregoing, we recognize that we have a special obligation to protect children in regards to the collection and processing of information, and we do not and will not knowingly collect information from children without consent from their parents or legal guardians. We strongly urge parents and guardians to instruct their children never to disclose any of their information when using our services without the prior permission of their parents or legal guardians. If we learn that we have collected a child’s information, we will delete such information as quickly as possible. Also, if you believe that we might have any information from or about a child, please contact us via contact@vrole.ai.
To make the application work effectively, we sometimes place small data files called cookies on your device. Most application’s developer do this. A cookies is a small text file that the website saves when you visit the site. It enables the website to remember your actions and preferences, designed to improve user experience.
You can control whether or not to accept cookies based on settings or by using other tools. If, however, you deactivate cookies or limit the ability to set cookies, you may not be able to obtain the full benefit of our services or access all of its functions, which may limit your overall user experience.
We may install modules of other companies in the Vrole to analyze how the service and product have been used or provided. With regard to your personal information that is processed by a third-party through a module provided by such third party,the privacy policy of such third party will aplly and we also encourage you review it (if any).
We change this Policy from time to time. We will not reduce your rights under this Policy without your explicit consent. When we update the Policy, we will notify you by updating the “Last Updated” date at the top of the policy and posting the new Privacy Policy. If changes are significant,we’ll provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).Your continued access to or use of the Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.
If you have questions, comments, complaints or requests regarding this Policy, please contact us via contact@vrole.ai.We will endeavour to deal with your request as soon as possible. This is without prejudice to your right to make a complaint with a relevant information protection authority, where applicable.