Welcome to VISIONPLAY LIMITED! We understand the importance of privacy and prioritize safeguarding your personal information. Whether you are a new or long-time user, your trust is invaluable to us. This Privacy Policy ("this Policy") aims to explain in detail how we collect, use, store, disclose, and manage your personal information, so you can confidently use our services. This Policy applies to all products and services provided by VISIONPLAY LIMITED (hereinafter referred to as "the Company" or "we"), including our website, mobile applications, and any other services linked to this Policy (collectively referred to as "Services").

By using our services, you acknowledge and agree that your personal information will be processed in accordance with this Privacy Policy. If you have any questions or disagree with any of the terms, we recommend contacting us for further clarification before deciding whether to continue using our services.

1. Information We Collect

To provide quality services, we may collect different types of personal information depending on how you interact with us. This information helps us deliver a better and more personalized experience. The following are the main categories of information we collect:

• Account Information: When you register and create an account, you provide us with basic information such as your name, email address, phone number, username, and password. We use this information to help you create and manage your account, verify your identity, and provide personalized services. For instance, we may contact you via the email you provide to ensure your account's security and to deliver content relevant to your interests.

• Transaction Information: If you make purchases or transactions through our platform, we collect related information such as payment methods (excluding full credit card numbers), purchase history, invoices, and order details. This information is used to complete transactions, process payments, and provide customer support.

• Device Information: When you access or use our services, we automatically collect information about your device, including device type, operating system, device identifiers, IP address, browser type, and version. This information ensures the proper functioning and security of the services and helps provide a better user experience.

• Location Information: Depending on your device settings, we may collect data regarding your geographic location. This location information helps us provide location-based services, such as personalized recommendations or showing services near you. If you do not wish to share location information, you can disable it in your device's privacy settings at any time.

• Log Information: We record log information related to your use of our services, including access times, page views, click activities, and search queries. This data helps us better understand user behavior, improve service features, and detect and prevent potential security risks.

• Communication Information: When you contact our customer support team or communicate with other users via our platform, we may collect and store these communications, including emails, phone recordings, and online chat logs. This information is used to address your requests, provide assistance, and improve the quality of our services.

2. How We Use Your Information

We take your privacy seriously and will always comply with relevant laws and regulations when processing your personal information. We may use your information in the following situations:

• Providing and Improving Services: The information you provide helps us manage your account, process transactions, and provide technical support. We will also continue to optimize our services based on your usage habits and preferences to offer personalized content and suggestions.

• Identity Verification and Security: To ensure your account's security, we may verify your identity through email, SMS, or other means, ensuring that only you can access your account. We also monitor unusual activity to prevent fraud and unauthorized access.

• Communication and Notifications: We may contact you via email, SMS, or in-app messages to send important notifications or updates, including service changes, policy updates, security alerts, etc. You may also opt to receive promotional information related to our products or services, which you can unsubscribe from at any time.

• Personalized Advertising and Marketing: Based on your usage habits and interests, we may display customized advertisements and recommended content. We promise to only conduct personalized advertising with your explicit consent, and you may manage your advertising preferences via privacy settings.

• Legal Requirements and Obligations: In cases required by law or to fulfill judicial requests, we may need to disclose your personal information to government or law enforcement agencies. At all times, we will comply with applicable laws and take appropriate security measures to protect your information.

• Service Analysis and Improvement: We analyze aggregated usage information to continuously improve our services. For example, analyzing user patterns helps us optimize service performance, develop new features, and enhance overall user experience.

3. How We Share Your Information

We may share your personal information in the following situations while strictly complying with laws and regulations:

• Sharing with Service Providers: We may share your information with third-party service providers who perform specific functions on our behalf. These services include payment processing, data storage, website hosting, customer support, and data analysis. These service providers can only use your personal information according to our instructions and are prohibited from using it for other purposes. We require all third-party service providers to adhere to strict confidentiality obligations and ensure they have adequate security measures to protect your information.

• Business Transfers: If the company undergoes a business reorganization, merger, or sale, your personal information may be transferred as part of the assets. We will ensure that in such cases, the receiving party continues to comply with this Privacy Policy and protect your personal information.

• Legal Requirements: We may disclose your personal information if required by law or in response to legitimate government requests, such as court orders, law enforcement requests, or to protect the legal rights of our company, users, or the public. Such disclosures may be necessary for investigating fraud, security threats, or other illegal activities.

• Aggregated and Anonymized Information: We may also share anonymized or aggregated information with third parties. This type of information does not contain personally identifiable data and is mainly used for market analysis or evaluating advertising effectiveness.

4. Data Storage and Security

We prioritize the security of your personal information and have implemented a series of technical and managerial measures to ensure your data is appropriately protected during processing and storage. We use industry-standard security protocols and technology, including but not limited to:

• Encryption: Protecting information during transmission using encryption technologies such as SSL/TLS to prevent theft or tampering.

• Firewalls and Intrusion Detection Systems: Deploying advanced firewalls and intrusion detection systems to prevent unauthorized access and potential malicious attacks.

• Access Control: Implementing strict access controls for all personnel and third-party service providers who have access to personal information, ensuring only authorized individuals with specific job needs can access the data.

• Data Anonymization and De-identification: In appropriate situations, we anonymize or de-identify personal information to further reduce the risk of data breaches.

• Security Audits and Assessments: Regularly reviewing and assessing our information systems and security measures to identify potential risks and take corrective actions.

Despite these precautions, no data transmission over the internet or electronic storage can be guaranteed to be 100% secure. Therefore, while we do our utmost to protect your personal information, we cannot guarantee its absolute security. If you believe your account or personal information has any security vulnerabilities, please contact us immediately.

5. Data Retention

We will retain your personal information based on the specific purpose of data collection and applicable legal requirements, ensuring it is not kept longer than necessary for the related processing purposes. We determine data retention periods according to the following criteria:

• Account Status: As long as you are an active user of our services and continue using our services, your account information and related data will be retained.

• Legal and Compliance Requirements: Certain information may need to be retained for a specified period under applicable laws, even if the initial purpose of the information processing has ended, such as for tax, audit, or anti-fraud purposes.

• Dispute Resolution and Contractual Obligations: We retain data for the necessary time period to resolve any potential disputes or enforce our user agreements or other legal contracts.

Once data is no longer needed, we will take appropriate measures to securely destroy or anonymize it to ensure it cannot be linked to any specific individual.

6. Children's Privacy

We are committed to protecting the privacy of children. Our services are not intended for children under 13 years old, and we do not knowingly collect personal information from children under 13. If we become aware that personal information from a child under 13 has been inappropriately collected, we will promptly take steps to delete that data.

For minor users (as defined by relevant law), we encourage parents or legal guardians to actively supervise their children's online activities and guide them to exercise caution when providing personal information. If you are a parent or guardian and discover that your child has provided us with personal information without your consent, please contact us, and we will take appropriate steps to delete the information.

7. Cross-Border Data Transfers

Given that our services are provided globally, your personal information may be transferred, stored, or processed across different countries and regions. This means your information may be transferred to countries with different data protection laws than those in your country. For example, some of our servers are located in the United States or other countries, and you agree that your information may be processed in these countries.

Regardless of where your personal information is processed, we will comply with applicable laws and take reasonable security measures to protect your privacy. Specific measures may include:

• Data Transfer Agreements: Ensuring that data transferred across borders complies with the privacy standards of the jurisdictions involved, such as by signing standard contractual clauses or implementing appropriate transfer mechanisms.

• Applicable Data Protection Laws: Ensuring that data privacy regulations of the relevant countries or regions are followed during cross-border data transfers.

8. Your Rights and Choices

We respect and protect your rights concerning personal information. Under applicable data privacy laws, you have the following rights:

• Right of Access: You have the right to request confirmation of whether we are processing personal information related to you, and if so, to access that information. You can also request details on how we process this data.

• Right to Rectification: If you find that the personal information we hold about you is inaccurate or incomplete, you have the right to request correction or supplementation. You can update certain information yourself through account settings or contact customer support for updates.

• Right to Erasure: In certain circumstances, you have the right to request the deletion of personal information related to you. For example, when your personal information is no longer relevant to the purposes for which it was collected, you may request deletion. However, in some cases, we may retain data based on legitimate reasons or legal obligations.

• Right to Restrict Processing: In some situations, you can request that we restrict the processing of your personal information. For example, if you dispute the accuracy of the data or question the legality of our processing.

• Right to Data Portability: You have the right to receive the personal information you have provided to us in a structured, commonly used electronic format and to request that this information be transferred to another controller (where technically feasible).

• Right to Object: In certain situations, you have the right to object to our processing of your personal information based on specific circumstances, especially when we process data based on legitimate interests.

• Right to Withdraw Consent: If you have given us consent to process your personal information, you may withdraw that consent at any time. However, this does not affect the legality of processing based on consent before its withdrawal.

If you wish to exercise these rights or have any questions about our data processing, please contact us using the contact details listed at the end of this Policy.

9. Third-Party Links

Our services may contain links to third-party websites, applications, or services. These third-party platforms are operated by independent companies with their own privacy policies and data protection measures. We have no control over how these third parties handle your personal information and assume no responsibility for their privacy policies or practices.

We recommend that you carefully review the privacy policies of these third parties when accessing such links to understand how they collect, use, and share your personal information. We are not responsible for any interactions or transactions you have with third parties and disclaim any responsibility for their actions.

10. Changes to This Policy

To address changes in laws and regulations, technological advancements, or our business developments, we may update this Privacy Policy from time to time. If we make significant changes to this Policy, we will notify you via email, website announcements, or other appropriate means, and seek your consent where necessary.

We encourage you to review this Privacy Policy periodically to stay informed about how we handle your personal information. Any updates will be posted on this page with the "Last Updated Date" marked. Continued use of our services after policy changes indicates your acceptance of the updated terms.

11. Contact Us

If you have any questions, comments, or need further information about this Privacy Policy, or wish to exercise your privacy rights, please contact us at:

VISIONPLAY LIMITED

Email: support@visionplaytech.com

Address: UNIT 10, 32A WESTGATE DRIVE, WESTGATE, AUCKLAND, 0614, NZ