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📌Security Policy

Article 1. Introduction

  1. Welcome. You come to the products and services(s) operated by Smart Group Inc. ("SGI") and its subsidiaries, affiliates, member companies of SGI (individually and collectively referred to as, "SGI", "We", or "Our"). SGI strictly carries out its responsibility in relation to information security in accordance with regulations on the protection of personal information in law and is committed to respecting the privacy and interest of all users in SGI services. We understand the importance of personal data. You have trusted SGI and believe that SGI is responsible for the management, protection, and handling of your personal data. You in a proper way. This information security policy ("Security Policy" or "Policy") is designed to help You understand how SGI collects, uses, discloses and/or processes personal data that You have provided SGI and/or keep about You, whether present or future, as well as to help You make a wise decision before you give it to We have any personal data of You. This security policy is also designed to help SGI customers currently living in the European Union (EU) understand their rights to personal data as specified in the EU Data Protection General Regulations when they use Services.

  2. "Services" or "Services" means Services, and/or Web Sites, and/or any products or services provided by SGI.

  3. "Personal Data" means data, whether true or not, about an individual through which identification can be made, or from such data and other information that an organization has or has access to. Common examples of personal data may include names, resident registration numbers and contact information.

  4. By using Services, registering an account with SGI or visiting the Web site, You confirm and agree that You accept the methods, requirements, and/or policies described in this Privacy Policy, and hereinafter You agree to allow SGI to collect, use, disclose and/or process personal data of You as described in this Privacy Policy.

  5. IF YOU DON'T AGREE TO ALLOW, SGI COLLECT YOUR PERSONAL DATA PROCESSING AS DESCRIPTED IN THIS POLICY, DO NOT USE THE SGI SERVICES OR ACCESS THE SERVICES OR THE SGI SITE. If we change our Privacy Policy, We will post those changes or the revised Privacy Policy on our Web site. We have the right to modify this Privacy Policy at any time without your prior consent, the You continue to use SGI Services yourself as You have agreed to that revised Security Policy.

Article 2. WHEN WILL SGI COLLECT PERSONAL DATA?

1. SGI will/may collect personal data about You:

  • when you register and/or use SGI Services, Services or Websites, or open an account with us;

  • Personal losses or assets caused by the content not of the services provided by us;

  • when you submit any form including, but not limited to, an application or other forms relating to any SGI products and services, in an online form or in another form;

  • when you conclude any agreement or provide other documents or information relating to the interaction between You with SGI, or when You use our products and services;

  • When you interact with us, such as through phone calls (can be recorded), letters, faxes, face-to-face meetings, social media and email applications;

  • when you use SGI's electronic services, or interact with We go to the Service or Website or SGI Services. This case includes, but is not limited to, through the cookie file that We can deploy when You interact with our Services or Web Sites;

  • when you make transactions through the SGI Services or Web site;

  • when you provide feedback or submit a complaint to SGI

  • when you register for a contest, Service or events under Electronic Service or in promotional programs;

  • in the process of You play the Electronic Service(s); and

  • When you send personal data of You give SGI for any reason.

2. These are just some common cases where SGI collects Your personal data, not fully reflect the cases in which SGI will collect your personal data.

Article 3. What data will SGI collect?

1 Personal data that SGI can collect includes, but is not limited to

  • first name;

  • email address;

  • the date of birth

  • address

  • telephone number;

  • gender;

  • information sent by or relating to the device(s) used to access SGI Services:

  • any other information about You (i) when You log in to use SGI Services, and (ii) when You use Services, as well as (iii) information about How you use SGI Services; and

  • aggregated data about the content users use

2. You agree not to provide for We have any inaccurate or misleading information and You agree to inform SGI of any inaccurate information or when there is a change in information. SGI reserves the right (depending on SGI's own decision) to request other necessary documents to verify the information You provide.

3. If You use a social network account (such as Facebook, Google), an application account (such as a Zalo account, Apple account) of You ("Social Network Account") and/or phone number of You to log in, use SGI Services or link to the Zagoo ID account of You. You understand and agree that SGI has access to information about You're my friend. You have voluntarily provided your Social Network Account Service Provider, your telecommunications provider. You follow the policies of these service providers, and SGI will manage and use these personal data of You follow the provisions of this Policy at all times.

4. If You Don't Want to We collect these personal information/data. You can choose not to participate at any time by notifying SGI's Data Protection Officer in writing or by email. More information about the content can be found in the "You can withdraw permission, request access, or adjust information" You've provided for How are we?" below. However, You need to keep in mind that, You deny or revoke permission We collect, use or process personal data of You can influence the fact that You use Services. For example, the location determination service will not work if You do not allow the application to access the location of You or even terminate Services between You and SGI.

Article 4. COLLECTION OF OTHER DATA

1 As with most websites and other mobile applications, the device of You send information that might include: data about You, recorded by a host when You use SGI Services. This information typically includes but is not limited to the IP address, operating system of your computer/mobile device, browser type, mobile device type, mobile device specifications, unique device identifier (UDID), or mobile device identifier (MEID), of your mobile device, the reference address of the Web site (if any), You have accessed it on the SGI website or mobile app and access time and sometimes "cookie" (which can be disabled by using your browser option) to help the site remember your last visit. If You log in, this information is associated with your personal account. This information is also included in anonymous statistics to help We understand that customers have accessed using the Services and Web site of What are we like.

2. SGI Services are provided through mobile applications that can gather accurate information about the address of the mobile device of You use technologies like GPS, Wi-Fi, etc. We collect, use, publish and/or process this information for one or more purposes including, but not limited to, location-based services that You request or forward the contents related to You're based on the location of You or allow You share the location of You give other Users as part of the Services provided by our mobile applications. For the majority of mobile devices, You can withdraw permission to We were able to gather this information based on the location of You pass the settings on the device. If you have any questions about how to disable location services on your mobile device, please contact your mobile device service providers or device manufacturers.

3. SGI Services can use technologies such as ARKit (Argued Reality or AR – Virtual Reality Technology), Camera API, TrueDepth API, etc. or similar technologies provided by the mobile device's operating system; these technologies are used to record information expressed on the user's face and for features in the application. For this information, We do not use for any purpose other than the features provided in the application; You have permission to deny camera access to these features at any time (but You need to note that, when If you stop granting camera access to the application, some of the application's features will not work); and We do not store or share this information with any third party.

Article 5. Cookies

  1. Sometimes. We can use cookies or other features to allow We or third parties collect or share information that will help We improve our Web site, our services, and our services. We provide, or help We offer new services and features. "Cookie" is the identifier. We send to your computer or mobile device, enabling We identify the computer or equipment of You and for We know when Services or Websites are used or accessed, by how many people and to monitor activities within our Web Site or Services. We can link cookie information to Personal Data. Cookie also links to information about content. You have chosen for the shopping sites you have viewed, or the Electronic Services that You played. This information is used for example, shopping cart tracking. Cookies are also used to provide content based on the interest of You and to monitor the use of Services.

  1. You can deny cookies by selecting the appropriate settings on your browser. However, please note that if You perform this operation You may not be able to use the full functions of our Web Site, Services, or Services.

Article 6. How do SGI use the information you provide to SGI?

1 SGI may collect, use, disclose and/or process personal data of You for one or more of the following purposes:

  • to review and/or process an application for registration/transaction of Friend with We're either dealing or correspondence You with third parties through Services;

  • to administer, operate, provide and/or administer the work You use and/or visit the Services, Web Sites, and Services of We (including but not limited to), your preferences, as well as your relationships and user accounts You with Us;

  • to meet, process, settle or finalize a transaction and/or meet the requirements of You for certain products and services and notify You about service issues and unusual account operations;

  • to enforce the Terms of Service of We or any end-user license agreement, terms and conditions apply;

  • to protect personal safety and the rights, property or safety of others;

  • for identification and/or verification;

  • to maintain and manage any software updates and/or other updates and support may be required at any time to ensure the Services of We operate smoothly;

  • to address or facilitate customer service, to perform Your instructions, to address or respond to any questions sent by (or intended to be sent by) You or on behalf of You;

  • in connection with You or Contact You by telephone, text message and/or fax message, email and/or mail or other way for the purpose of managing and/or managing the relationship of Friend with We or the You use our Services, such as but not limited to communicating administrative information to You are related to our Services. You confirm and agree that such communication of We may be by mail, documentation or notification to You, may include disclosure of certain personal data about You to provide those documents as well as on the package/ envelope;

  • to keep open house You when another user has sent You either have a private message or post comments for You in Services or on the Web;

  • to conduct research, analysis and development activities (including, but not limited to, data analysis, survey, development and/or product and service characterization), to analyze the way You use Our Services, to improve the Services or Products of We and/or to improve your customer experience;

  • to enable advertising and other inspection and surveys, in addition to other activities, to validate the size and composition of the Electronic Services player, and to understand their experience with SGI Services;

  • for marketing purposes, in this case, to send to You through various means of communication, marketing and promotional materials related to products and/or services (including, but not limited to, third-party products and/or services that SGI may collaborate with or link to) may sell, market or promote, whether such products or services exist at this time or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function in e-marketing documents. We can use the contact information of You to send newsletters from We or from subsidiaries, affiliated companies, member companies of SGI;

  • to meet legal procedures or to comply with or in accordance with any existing legislation and the requirements of the competent State agency;

  • to prepare statistics and research that meet reporting requirements and/or maintain internal or regulatory records;

  • to perform an inquiry and verification process or other screening activities (including, but not limited to, background checks) in compliance with our statutory or regulatory obligations or risk control procedures, which may be required by law or may have been We apply;

  • to check the Services of We or SGI activities;

  • to prevent or investigate any actual or suspected violation of our Terms of Service, fraud, wrongdoing, omission or misconduct, whether in connection with You use the Services of We or no matter what arises from the relationship of You with Us;

  • for storage, host creation, backup (whether for disaster recovery or other purposes) of Your personal data;

  • to handle and/or facilitate a business asset transaction or a potential business asset transaction, such transaction relates to SGI as a party to or only to an SGI subsidiary or affiliated company as a party to or in relation to SGI and/or any one or more of its subsidiaries or affiliatesn conclusion of SGI as party(s), and other third-party organizations may participate in such transactions. "Transactions of business assets" means transactions of purchase, sale, lease, merger, consolidation or any acquisition, liquidation or financing of an organization or part of any business or property of an organization; and/or

  • to any purpose that We inform You at the time ask your permission. (generally referred to as "Objectives").

2. For the sake of purpose. We will/can collect, use, disclose or process personal data of You depend on the existing circumstances, that purpose may not appear above. However, We'll let you know. You know that other purpose at the time of obtaining your permission, unless the processing of the data applies without the consent of You are authorized to comply with the provisions of the law on the protection of confidential personal information or in accordance with the law.

Article 7. SGI PROTECTING AND STORING CUSTOMER INFORMATION

1. SGI takes various security measures and always strives to ensure the safety of personal data of You on SGI systems. User personal data is stored behind secure networks and can only be accessed by some employees with special access to SGI systems. However, absolute safety cannot be guaranteed.

2. SGI will maintain personal data in accordance with laws on the protection of personal information confidentiality and/or other current laws. That is, SGI will either destroy or remove the identity information from the personal data of You when SGI has a reasonable reason to determine that (i) retention of such personal data is no longer for the purpose of collecting such personal data; (ii) retention is no longer necessary for any legitimate or business purpose and (iii) no other legitimate interests to retain such personal data. If You Stop Using SGI Services, or Rights of You may use Web Sites, Services and/or Services terminated or withdrawn, We may continue to save, use and/or disclose personal data of You comply with this Privacy Policy and the obligations of We comply with the law on the protection of personal information. Depending on the law, We can destroy personal data of You safely without notice to You.

Article 8. Does SGI disclose information collected from the ACCESSORY?

1. In the course of doing business, We will/may need to disclose personal data of You have Service Developers, Service Providers, third parties, agents and/or affiliates and/or affiliated companies and/or SGI member companies, and/or other third parties, for one or more of the above purposes. Third party service providers, agents and/or subsidiaries and/or affiliated companies or SGI member companies and/or other third parties as such will process personal data of You or on behalf of We are for one or more of the above purposes. Such third parties include, but are not limited to:

  • subsidiaries, affiliated companies and member companies of SGI;

  • contractors, agents, service providers and other third parties that We hired to support our business. These parties include, but are not limited to, parties providing administrative or other services to We such as postal companies, telecommunications companies, information technology companies and data centers;

  • the purchaser or other successor in the event of a merger, divestment, restructuring, reorganization, dissolution or sale or transfer of part or all of SGI's assets, whether in bankruptcy, liquidation or similar proceedings, in which SGI personal data retain the users of We are in the transferred assets; or to a partner in a business asset transaction in which SGI or any subsidiary, affiliated company or member company of SGI is involved; and

  • It's a third party. We disclose information because one of the purposes and those third parties, on the contrary, will collect and process personal data of You for one or more purposes

2. This case may require, in addition to other requirements, disclosure of the Service play history of You and/or disclose profiles that show which IP addresses have viewed which Services. We will also share statistical and demographic information about users of We and their use of Services with advertising and programming service providers. This case will not include any information that can be used to identify the specific identity of You either disclose personal information about You.

3.To avoid suspicion, in cases where the provisions of law on the protection of confidential personal information or other existing laws allow an organization such as We collect, use or disclose personal data of You without your consent, such permission of the law will continue to apply.

4. Third parties may block or unauthorized access to personal data sent to or present on the website, the applicable software, applications, technologies may malfunction or malfunction as expected, or someone may access, abuse or misuse information without our fault. However We will implement reasonable security measures to protect the personal data of You comply with the provisions of the law on the protection of confidential personal information; however, absolute confidentiality cannot be guaranteed such as but is not limited to the cases of unauthorized disclosure arising from hacking activities because of the bad or complicated intention of malicious content that is not our fault.

Article 9. INFORMATION ON CHILDREN (EXCLUDING CHILDREN IN EU)

Services of We are very diverse and provide for many people of different ages. For children under 14 years of age, account creation, use of the Services of We need the permission and supervision of the child's parent or guardian. The parent or guardian of a child under 14 years of age shall monitor and ensure that the child under 14 years of age is not self-registered to use the Services and/or provide the child's personal information to We without the supervision or consent of the child's parent or guardian. In the event that the personal information of a child under the age of 14 provided by the parent or guardian to us, or the parent, the guardian agrees to provide the child's information to We hereby agree to the processing and use of information of children under 14 years of age, and agree to be subject to this Policy on behalf of the guardian. We will lock any account used only by such child objects and will remove and/or delete any personal data that We believe it was sent by an...

Article 10. INFORMATION COLLECTED BY THIRD PARTIES

1. Website and Services of We can use Google Analysis, a web analysis service provided by Google, Inc. ("Google"). Google Analysis uses cookies, which are text files placed on your device, to help the site analyze how users use Our Services. Information generated by cookies about You use the website (including your IP address) that will be sent to and stored by Google on servers in the United States. Google will use this information to evaluate things. You use our Services, prepare a report on website activity for website operators, and provide other services related to website activity and Internet usage. Google may also send this information to third parties in case of such legislation, or if such third parties process it on behalf of Google. Google will not link the IP address of You with any other data that Google holds.

2. Website and Services of We can use AppsFlyer, a marketing application platform provided by AppsFlyer Ltd. ("AppsFlyer"). AppsFlyer uses the SDK (Software Development Kit) placed in the device of You to help We monitor and optimize your delivery of Incoming Services. Information generated by SDK about You use the application of We (including your IP address) will be sent to and saved by AppsFlyer on servers located globally. AppsFlyer will use this information to evaluate the job You use our Services, prepare a report on application activity for developers, run applications, and provide other services related to application activity and Internet use. AppsFlyer may also send this information to third parties in the event of such legislation, or where such third parties process information on behalf of AppsFlyer. AppsFlyer will not link the IP address of You with any other data that AppsFlyer holds.

3. Services of We can also use TrueID, a facial recognition application and ID (such as resident registration, citizen ID, passport) provided by Software Development Co., Ltd. ("TrueID") to strengthen identification to secure your account. TrueID will use the camera on the device of You to record, capture your face and your ID, use algorithms and AI (artificial intelligence) to handle to detect abnormalities (such as fraud, face, and photos on your ID incorrectly…). TrueID will support We detect anomalies, provide recommendations, suggestions to validate your account. TrueID can send these information to a third party for storage, processing in case such legislation exists or if that third party processes it on behalf of TrueID. TrueID also has a duty to secure the credentials of You that TrueID stores, processing is similar to SGI's security obligations.

4. We, and third parties, may occasionally provide software application downloads to You use on or through Services. These applications can be accessed separately, and allow a third party to view, your identification information, such as your name, your user ID, the IP address of your device You or other information such as Services. You are playing in any specific access session, and any previous cookies, SDK You might already be installed or installed for You by a third-party software application or website. In addition, these applications may require You provide additional information directly to third parties. Third-party products or services delivered through these applications are not owned or controlled by SGI. You should read the terms and other policies published by those third parties on their website or elsewhere.

Article 11. EXCLUSION OF LIABILITY FOR SECURITY LIABILITY AND THIRD PARTY WEBS

1. SGI DO NOT SECURITY FOR PERSONAL DATA AND/OR OTHER INFORMATION YOU PROVIDE ON THIRD PARTY WEBS, APPLICATIONS. We take different security measures to maintain the safety of Personal Data of You're my friend. We keep or control. Personal Data of You are stored behind secure networks and can only be accessed by a limited number of individuals who have special access to our systems, and have been requested to secure those personal data. When You order or access your personal data, We recommend using a security device. All personal data or personal information You provide will be encrypted into the databases of We leave it accessible only as described above.

2. In order to provide for You value added, We can select different third-party sites to link to, and frame inside Web Sites or Services. We can also participate in marketing and other relationships to provide e-commerce, advertising and other services and features to visitors. These linked sites have privacy policies as well as separate and independent security measures. Even if that third party is connected to us, We also do not control these linked sites, each of which has its own privacy and data collection methods, independent of us. Data collected by co-marketing partners of We or third-party websites (even if provided on or through our Website or Services) may not be received by Us.

3. As a result, we are not responsible or legally responsible for the content, security measures (or lack of security measures) and the activities of these linked sites. These linked sites are just for the convenience of You and therefore You are responsible for accessing them. However, We seek to protect the integrity of the Site and Services of We and the links are placed on each of those sites and so on We welcome feedback on these linked sites (including, but not limited to, if a particular site does not work).

Article 12. HOW CAN YOU REMOVE THE NAME, DELETE THE NAME, ACCESS REQUEST OR CORRECT THE INFORMATION YOU HAVE PROVIDED TO US?

1. Withdrawal of Consentence

  • You may withdraw consent to allow the collection, use, and/or disclosure of personal data of You're my friend. We are keeping or controlling by sending text or email: contact@smartgroup-inc.com , and We will process the request in accordance with these Privacy Policy regulations and the obligations of We are regulated by law.

  • Nevertheless, You withdraw consent can mean We will not be able to continue to provide You with Services, and We may need to end the current relationship of You and/or the contract of Friend with We and shall not indemnify you for any loss.

2. Request Access to or Edit Personal Data

  • If You have registered an account with We, personally You can access and/or modify the personal data of You're my friend. We are maintaining or controlling through the Account Settings page or on the Website or Services. If You have not registered with us, personally You can request access and/or modify the personal data of You're my friend. We are keeping or controlling by sending a written request to us. We're going to need all the information from You to identify the identity of You as well as the nature of the request of You to be able to resolve Your request. Therefore, please submit a written request of You by sending a request at contact@smartgroup-inc.com

  • We can charge a reasonable fee for You to resolve and process Your personal data access requests. If we have a charge, We'll give it You estimate the fee in writing or email. Please note that We are not obliged to meet or resolve the access requirements of You unless You have agreed to pay the fee.

  • We reserve the right to refuse to modify personal data of You comply with the provisions of law on the protection of confidential personal information, where such laws require and/or allow an organization to refuse to modify personal data in such cases.

Article 13. ADDITIONAL REGULATIONS FOR USERS IN EUROPEAN STATES (EU)

The provisions of this Article shall only apply if You are living in the European Union ("EU"). These provisions are more preferred to apply if there are differences in other provisions of this Privacy Policy.

1. Flexibility

  • You have the right to receive from We have personal information. You provided earlier for We and the information have been processed by permission of You follow a structured format, are available for normal use and can read machines and request permissions We transfer this personal data to another party.

  • If You Want We transfer personal data to a third party, Please ensure the details of this Third Party and note that We can only do as requested by You when these requirements are technically feasible. We will not be responsible for the security of Personal Data or Data obtained as a result of the processing of Personal Data of You when a third party receives these data. We may not provide You Specific Personal Data of You if this provisioning interferes with other rights (for example, when providing Personal Data that We have collected information that can leak other personal information).

2. Delete Data

  • You can ask We delete the Personal Data of You're my friend. We have collected in the following cases:

    • You believe that these Personal Data are no longer required to We hold Your Personal Data;

    • We handle Personal Data of You're my friend. We have collected with the permission of You and You wish to withdraw the permission of You and have no other basis to We can process this Personal Data;

    • You don't want to anymore We continue to use Personal Data of You have been collected by We to send advertising, special offers, sales programs and lucky programs; or

    • You believe that Personal Data of You're my friend. Our collection was handled against the law by us.

  • Please provide as much detail as possible the reasons of You to support We in determining whether Do you have a reasonable basis for requesting data deletion. However, We may retain Personal Data if there is a legal basis in accordance with law to We do this (e.g. in accordance with the laws of the country in which the subsidiary, the member company of the EPI is headquartered, or to protect We face legal requirements or guarantee of freedom of expression) however We'll let you know. You know about these cases. Please note that after deleting Personal Data, We may not be able to provide the same service before deleting because We won't be able to know about your preferences.

  • It should be noted that, in some countries and territories (such as Vietnam), it is mandatory for Service Providers such as SGI to retain information and personal data of users for a certain long term.

3. Keep Personal Data

We keep personal data of You as long as these Personal Data are needed to We provide you with services or products, either as required or permitted in accordance with law, such as the regulations of the Internet Electronic Service, Tax, Accounting. If You perform a request to remove the Personal Data of You and We determined that this was a reasonable request. We will try to delete the Personal Data of You within 30 days of the date You request and terminate the aforementioned retention period, or notify You if this takes more time.

4. Objection Against Customer Profile-Based Sales Programs and Target Customers

At any given moment You also have the right to object to the processing of Personal Data by You to send to You have advertising programs, special recommendations, and sales messages, including: We build Customer Profiles for these purposes and We will stop processing Personal Data of You to serve these purposes. Would you please provide for We have detailed information about the reason You ask to support We determined whether Do you have a legitimate grounds for protest? However, We can retain the Personal Data of You if there are legitimate grounds to We did this.

5. Restrictions on Processing Personal Data for Storage Only

You have the right to request that We limit the processing of Personal Data by You're my friend. We have had only for storage purposes, when:

  • You believe that Personal Data of You are inaccurate, within the time required to We verify the Personal Data of Are you correct or not.

  • We want to delete the Personal Data of Friend but You want We only store;

  • We want to delete the Personal Data of You because it is no longer necessary for the purpose of We but. You require storage to establish, implement or counter legal requirements; or

  • You object We handle Personal Data of You on the basis of legitimate interests of We and You want We terminate Personal Data processing when We determine whether it is important to process and retain these Personal Data.

Article 14. QUESTIONS, WORKS OR RECOVERY? Contact SGI

If you have any questions or questions about this Policy, please contact We're at contact@smartgroup-inc.com

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