1.          INTRODUCTION

(i)         This NagaWorld End User Data Privacy Policy (“Privacy Policy”) in combination with other relevant privacy notices that we provide to you inform you of the policies and practices regarding the collection, use and disclosure of any personal information that we and our service providers collect from or about users in connection with the mobile applications (the “Application”) and/or websites (the “Sites”) that have been integrated with the Application (together the “Services”).

(ii)        By using, accessing, or registering with an Application, you consent to our collection, use, processing, and disclosure of information in accordance with this Privacy Policy.

2.         THE TYPES OF INFORMATION WE COLLECT IN THE Services

Through your use of the Services, we may collect personal information from you in the following ways:

(i)         Personal information you provide to us:

  • We may collect personal information from you, such as your first and last name, address, e-mail, telephone number, sex, age, country when you create an account.
  • If you provide feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
  • We also collect other types of personal information that you provide voluntarily, such as any information requested by us if you contact us via email regarding support for the Services.
  • We will collect the financial and transaction information necessary to provide you with the Services, including account numbers, payment card expiration date, payment card identification, verification numbers, and transaction and payment history.

(ii)        Personal Information collected from third parties: We may collect certain information from identity verification services and consumer reporting agencies in order to provide some of our Services.

(iii)       Personal Information collected via technology: we and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:

  • Device data, such as mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
  • Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
  • Location Information: If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect your location information when you use the Services; for example, to provide our fraud detection services. If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

(iv)       Publicly or commercially available or shared information:

  • We sometimes gather publicly or commercially available information, including information from social networks you use, and combine this with other information about you so that we can better understand your needs, interests, and preferences.

(v)        Cookie, beacons, and similar technologies: We, along with certain third parties such as content providers and advertisers, may use technologies called cookies, beacons, or pixels, as well as other tools (collectively known as “technologies”) that communicate information from your device to a server, including those owned by third parties. These technologies can be embedded in online content, videos, and advertisements. They allow a server to read certain types of information from your device, know when you have viewed particular content or a particular advertisement, and determine the time and date on which you viewed the content as well as information about your device, including the IP address of your device. Among other purposes, these technologies help us to do the following:

  • Remember your information so you will not have to re-enter it;
  • Track and understand how you use and interact with the Services;
  • Personalize the Services to your preferences;
  • Manage and measure the usability of the Services;
  • Understand the effectiveness of our communications;
  • Improve our Services.

(vi)       Other information we collect:

  • We also collect other information about you, your devices, or your use of Services that you choose to send us.

3.         HOW WE USE YOUR INFORMATION COLLECTED IN THE services

(i)         General Use – In general, we use your personal information collected through your use of the Services to respond to your requests as submitted through the Services, to provide you the Services you request, and to help serve you better. We use your personal information, in connection with the Application, in the following ways:

  • Facilitate the creation of, and secure and maintain your account;
  • Identify you as a legitimate user in our system;
  • Provide improved administration of the Services;
  • Provide the Services you request;
  • Improve the quality of experience when you interact with the Services;
  • Send you administrative e-mail notifications, such as security or support and maintenance advisories.

(ii)        Marketing and promotion:

  • We may use your personal information to send surveys, offers, and other promotional materials related to the Services, and provide personalized and/or generalized advertising and direct marketing communications, promotions, and offers that might interest you relating to our and our partners’ products and Services, on our Services, websites, third-party websites, and online platforms such as social media sites (in accordance with applicable law). We will only send you personalized advertising, promotions, and offers when you have provided your consent to receive marketing communications from Samsung, where required by applicable laws.

(iii)       Compliance and protection – We may use your personal information to:

  • Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
  • Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern the Service; and
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber-attacks and identity theft.

(iv)       Creation of Non-Identifiable Data – The Application may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties in our discretion.

4.         Disclosure of information

We disclose your personal information collected through your use of the Services as described below.

(i)         In Accordance with Our Other Privacy Notices – Other than as described in this Privacy Policy in connection with the Application, this Privacy Policy does not apply to the processing of your information by us or third parties with whom we share information.

(ii)        Disclosure for Law Enforcement – Regardless of any choices you make regarding your personal information, we may disclose your personal information to law enforcement, government authorities as described below:

  • Under certain circumstances, we may be required to disclose your personal information if required to do so by law, subpoena, or in response to valid requests by the competent authorities.
  • When we believe in good faith that disclosure in necessary to protect our rights, protect your safety of others, investigate fraud, or respond to a government request.

(iii)       Other cases – We may also disclose your information:

  • To our subsidiaries and affiliates, our contractors, service providers, and other third parties we use to support our business;
  • To fulfill the purpose for which you provide it and for any other purpose disclosed by us when you provide the information;
  • With your consent in any other cases;
  • If we believe disclosure is necessary or appropriate to protect our rights, property, or safety or those of our customers, or others.

5.         LINKS TO OTHER SITES

The Application and the Sites may contain links to third party websites. When you click on a link to any other website or location, you will leave the Application or the Sites and go to another site and another entity may collect personal and/or anonymous information from you. The Application’s or the Sites’ provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites. We encourage you to read the privacy policy of every website you visit.

6.         YOUR CHOICES REGARDING YOUR INFORMATION

You have several choices regarding use of information on the Services. [IT please note this Clause 6]

(i)         Access, Update, or Correct Your Information – You can access, update or correct your information by changing preferences in your account. For additional requests, please contact us.

(ii)        Opting Out of Email or SMS Communications – If you have signed-up to receive our email marketing communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information under “Contact Us” below. If you provide your phone number through the Services, we may send you notifications by SMS, such as provide a fraud alert. You may opt out of SMS communications by unlinking your mobile phone number through the Services.

(iii)       Opting Out of Location Tracking – If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the Application.

(iv)       Regarding your rights to access, correct, and/or update your information, we may:

  • Refuse your request to access, correct, or update your personal information if the cost of fulfilling such a request is disproportionate to the risks to your privacy, or if it may violate the rights of others, among other reasons;
  • Deny your request to access, correct, or update your personal information if it is being processed by us in order to fulfill regulatory functions. Allowing access or making corrections might hinder our ability to perform those functions properly;
  • Charge a fee for processing your request to access your personal information, as permitted by applicable laws; and
  • Maintain that this Privacy Policy remains valid and effective at all times, even if access is granted or corrections/updates to your personal information are made.

(v)        Before we accede to your access or correction request, we may need to verify your identity by checking identification document, and the legitimacy of your request. Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. We are not obliged to provide you with access to records or decisions that the organization has created for evaluative purposes.

7.         RETNETION AND SECURITY OF DATA

(i)         We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy and to the extent necessary as required under law, a contract, or with regard to our statutory obligations.

(ii)        We implement reasonable administrative, technical and physical measures in an effort to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.

8.         Transfer of Data

(i)         Your use of our Services will involve the transfer, storage, and processing of your personal information within and outside of your country of residence where necessary. In particular, your personal information will be transferred to Cambodia.

(ii)        Please note that the data protection laws and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country. We take appropriate measures, in compliance with applicable law, to ensure that your personal information remains protected.

9.         Other provisions

(i)         We reserve the right to update or modify our Application or this Privacy Policy at any time and from time to time without prior notice.  Any revisions to this Privacy Policy will be effective upon posting. The most recent version of this Privacy Policy is available at [IT to provide]. You should review this Privacy Policy periodically to ensure you are aware of any changes.  If you object to any changes to this Privacy Policy, you must cease using our Application. Your continued use of our Application after any changes or revisions to this Privacy Policy indicates your agreement to the terms of the revised Privacy Policy.

(ii)        If you have any questions or complaints about this Privacy Policy or the Application’s data collection or processing practices, or if you want to report any security violations to the Application, please contact by email at: [IT to provide].

(iii)       This Privacy Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

(iv)       If any provision in this Privacy Policy should be held illegal or unenforceable by a court having jurisdiction, such provision shall be modified to the extent necessary to render it enforceable without losing its intent, or severed from this document if no such modification is possible, and other provisions of this Privacy Policy shall not be affected and remain in full force and effect.

(v)        This Privacy Policy is governed by, and to be construed in accordance with Cambodian laws.