Namson Digital Privacy Policy Notice
I. Our Commitment and Privacy Pledge
Welcome to NAMSON Digital Company Limited. Your trust is our most valuable asset. This Privacy Policy is designed to clearly explain what data we collect, why we collect it, and how we protect it as you enjoy our games and services across all platforms (mobile, desktop, and web).
We are committed to building trust with our players by maintaining the highest standards of data privacy and security. We believe that your privacy is a fundamental right.
Our Core Principles: Transparency, Purpose Limitation, Data Minimization, Security, and Your Control guide every aspect of our data handling.
II. Data We Collect, Use, and Legal Basis
We collect the minimum data necessary to provide and improve our games. We rely on your relationship with us (Contract Performance) or our need to improve our service (Legitimate Interest) as the legal basis for processing.
We collect data across four primary categories:
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Identifiers (Via Platform API): We collect User ID, Device ID (IDFA/GAID), IP address, Username, and Email to facilitate Account creation, authentication, game access, and fraud prevention. These identifiers are obtained from third-party authentication providers, such as Google, Apple, Microsoft, and Steam APIs, which verify your identity and pass us only the necessary access tokens and user identifiers to set up your profile. The legal basis for this processing is Contract Performance.
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Gameplay and Usage Data: We collect Game progress, scores, session duration, crash reports, and button clicks for the Legitimate Interest of operating the game, improving features, balancing gameplay, and fixing bugs.
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Financial and Transaction Data: We do not collect or store any personal financial data or payment method details. All transactions are processed securely by our trusted third-party payment providers (e.g., Apple App Store, Google Play Store, Steam). We only receive a confirmation of payment and a non-sensitive Transaction ID from them to meet our Legal Obligations (e.g., for tax reporting and accounting).
Customer Support Data: We collect Communication content and support ticket metadata for Contract Performance to resolve technical issues and provide assistance.
III. Sharing and Disclosure of Data
We share data only with trusted parties under strict contractual terms (Data Processing Agreements - DPAs).
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A. Service Providers: We share data with third parties that perform essential functions for us, such as Cloud Hosting (e.g., AWS), Analytics Providers (e.g., Firebase), and Customer Support Tools.
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B. Advertising Partners: We may share certain identifiers (like Device ID) with advertising partners to measure ad performance and offer interest-based advertising, only where appropriate consent is obtained.
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C. Legal Requirements: We disclose data when legally required (e.g., court orders, law enforcement requests)
IV. International Data Transfers and Safeguards -
Since we utilize global cloud services and infrastructure to operate our games and store player data, your personal data may be transferred to and processed in countries outside of your country of residence (e.g., the United States).
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We ensure your data is protected during these transfers by implementing appropriate legal safeguards:
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Standard Contractual Clauses (SCCs): We implement the European Commission’s approved SCCs with our data processors to contractually ensure your data receives protection equivalent to EEA standards.
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Adequacy Decisions: We rely on the EU-US Data Privacy Framework for transfers to certified US entities.
V. Your Rights and Choices -
You have the right to control your data. We will fulfill your request within the legally mandated time frame ( 30 days).
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Right to Access/Know: Request a copy of the personal data we hold about you.
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Right to Correction: Request to correct any incomplete or inaccurate data.
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Right to Deletion (Right to be Forgotten): Request the permanent erasure of your personal data.
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Right to Object/Opt-Out: Object to certain processing activities, such as direct marketing.
VI. Data Retention and Children's Privacy -
A. Data Retention Period: We retain your user account data for the duration of your active game account. Following account closure, we retain certain security and transaction logs for a maximum of 120 days for audit and legal compliance, after which it is securely and permanently deleted.
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B. Children's Privacy: Our games are not directed at children under the age of 13. We do not knowingly collect personal data from anyone under 13 years old. If we become aware that we have unintentionally collected personal data from a child under 13 without verifiable parental consent, we will take immediate steps to delete that information from our records.
VII. Data Controller and Contact Information -
We are committed to providing easy access to the individual responsible for overseeing privacy.
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Data Controller and DPO: NAMSON Digital Company Limited, Bangkok, Thailand is the legal entity responsible for determining how your data is processed. Our Data Protection Officer (DPO) serves as the central point of contact for all privacy matters.
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Contact for All Privacy and Rights Requests: For all general questions and to submit a formal Data Subject Rights Request (Access, Deletion, etc.), please email info[at]namsondigital.com