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Privacy Policy

Last Updated: 10 April 2026

This Privacy Policy explains how NEXTGEN TECHNOLOGY AND ENTERTAINMENT JOINT STOCK COMPANY, Enterprise Registration No. 0110958885, a company incorporated under the laws of Vietnam, with its registered address at 5th Floor, IC Building, No. 82 Duy Tan Street, Dich Vong Hau Ward, Cau Giay District, Hanoi City, Vietnam ("Company," "we," "us," or "our"), collects, uses, discloses, stores, and protects personal information when you access or use our mini-program, games, short drama content, virtual currency, virtual items, and related services made available through TikTok or other third-party platforms.

For purposes of this Privacy Policy, the "Mini-Program" means our mini-program and all related services, including short drama content, mini-games, virtual currency, virtual items, advertisements, analytics, customer support, and other features.

This Privacy Policy is primarily intended for users located in the United States and is designed to address applicable U.S. privacy requirements, including the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), the Children's Online Privacy Protection Act ("COPPA"), and other applicable U.S. state privacy laws where applicable.

This Privacy Policy should be read together with our Terms of Service and TikTok's Privacy Policy.

1. Personal Information We Collect

We may collect personal information directly from you, automatically when you use the Mini-Program, and from third parties such as TikTok, payment processors, analytics providers, advertising partners, and service providers.

1.1 Information You Provide

We may collect the following information that you provide to us:

Account and Profile Information

Contact Information

User Content

If the Mini-Program allows comments, reviews, chats, posts, uploads, or other interactive features, we may collect the content you submit, including text, images, videos, audio, ratings, messages, and related metadata.

Customer Support Information

When you contact us, we may collect your inquiry details, screenshots, order information, device information, correspondence, and any other information you choose to provide.

1.2 Information Collected Automatically

Usage Data: We may collect information about how You use the Mini-Program, such as the short drama episodes You view, watch duration, and the features You access and the actions You take (e.g., likes, shares, comments).

Device Information: We may collect information about the device You use to access the Mini-Program, such as the device model, operating system, IP address, browser type, and unique device identifier (e.g., IDFA, GAID).

Location Information: With Your consent, We may collect approximate location information based on Your IP address or device settings, to provide location-relevant Content (if applicable).

Network Information:We may collect Your IP address, network type (Wi-Fi/cellular), and carrier information。

Log Data:We may collect access timestamps, error logs, crash reports, and referral URLs for debugging and performance monitoring purposes。

Payment Information: When You purchase virtual coins, payments are processed by the Platform (TikTok) or third-party gateways. We do not collect or store Your financial details (like full credit card numbers). We only receive transaction confirmations and order IDs to credit Your account

1.3 Information from Third Parties

We may receive information from:

TikTok or Other Platforms

When you authorize the Mini-Program, TikTok or another platform may provide information in accordance with its APIs, permissions, developer terms, and your account settings.

Payment Processors

Payment processors may provide transaction confirmation data, order IDs, refund status, and related payment records.

Analytics Providers

Analytics providers may provide aggregated, pseudonymized, or device-level analytics data to help us understand usage, improve services, and troubleshoot issues.

Advertising and Attribution Partners

Advertising partners, ad networks, mobile measurement partners, and attribution providers may provide information about ad impressions, clicks, installs, registrations, purchases, and campaign performance.

2. Categories of Personal Information Collected

For purposes of U.S. state privacy laws, including the CCPA/CPRA, we may collect the following categories of personal information:

  1. Identifiers, such as username, user ID, TikTok OpenID, email address, IP address, device identifiers, and advertising identifiers.
  2. Commercial information, such as purchase history, transaction records, virtual currency purchases, and premium content access.
  3. Internet or other electronic network activity information, such as viewing history, gameplay activity, interactions, clicks, session data, and log data.
  4. Geolocation information, limited to approximate location inferred from IP address or device settings.
  5. Audio, electronic, visual, or similar information, such as avatars, images, videos, or content you upload, if applicable.
  6. Inferences, such as content preferences, viewing preferences, game preferences, and ad interest segments.
  7. Customer support and communications information, such as your inquiries and correspondence with us.

We do not intentionally collect sensitive personal information such as government identification numbers, biometric identifiers, precise geolocation, health information, or financial account credentials. If we collect any information that is treated as sensitive personal information under applicable law, we will process it only as permitted by law and provide any required notices or choices.

3. How We Use Personal Information

We may use personal information for the following purposes:

3.1 Providing and Operating the Mini-Program

3.2 Personalization and Recommendations

3.3 Analytics and Improvement

3.4 Safety, Security, and Fraud Prevention

3.5 Communications

You may opt out of promotional communications by following the unsubscribe instructions in the message, changing your settings where available, or contacting us.

3.6 Advertising and Attribution

We may use personal information to:

Where required by applicable law, we will provide opt-out rights for targeted advertising or "sharing" of personal information for cross-context behavioral advertising.

3.7 Legal Compliance

We may use personal information to comply with applicable laws, regulations, court orders, legal processes, tax obligations, accounting obligations, payment obligations, platform requirements, and governmental requests.

3.8 Other Purposes with Consent

We may use personal information for other purposes with your consent or as otherwise disclosed at the time of collection.

4. How We Disclose Personal Information

We do not sell your personal information for money. However, certain advertising, analytics, or attribution activities may be considered a "sale," "sharing," or "targeted advertising" under some U.S. state privacy laws. Please see Section 8 for your choices.

We may disclose personal information as follows:

4.1 TikTok and Other Platforms

We may share information with TikTok or other platforms as necessary to operate the Mini-Program, comply with platform rules, authenticate users, process purchases, enable platform analytics, prevent fraud, and satisfy platform requirements.

TikTok's processing of your information is governed by TikTok's Privacy Policy.

4.2 Service Providers and Processors

We may disclose personal information to service providers that perform services for us, including:

These service providers are authorized to use personal information only as necessary to provide services to us or as otherwise permitted by law.

4.3 Advertising, Analytics, and Attribution Partners

We may disclose identifiers, device information, event data, usage data, and transaction event data to advertising networks, analytics providers, and mobile measurement partners to measure campaign performance, attribute conversions, prevent fraud, and deliver or personalize ads.

Examples of events may include app or mini-program launch, registration, episode view, game start, level completion, coin purchase, or premium content unlock.

4.4 Legal and Safety Disclosures

We may disclose personal information if we believe in good faith that disclosure is necessary to:

4.5 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or transfer of business, personal information may be disclosed or transferred as part of that transaction.

4.6 Aggregated or De-Identified Information

We may disclose aggregated, anonymized, or de-identified information that cannot reasonably identify you for analytics, research, marketing, business, or other lawful purposes.

5. Cookies, SDKs, and Tracking Technologies

We and our service providers may use cookies, local storage, SDKs, pixels, APIs, device identifiers, advertising identifiers, and similar technologies to:

Because the Mini-Program operates through TikTok, TikTok SDKs and platform technologies may also collect information according to TikTok's own policies and settings.

You may be able to manage certain tracking technologies through your device settings, browser settings, TikTok settings, or in-app settings. Disabling certain technologies may affect the functionality of the Mini-Program.

6. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Our general retention periods are:

CategoryRetention Period
Account InformationFor the duration of your account or use of the Mini-Program, plus up to 12 months after account deletion or inactivity, unless a longer retention period is required or permitted by applicable law.
Transaction RecordsUp to 5 years, or longer if required for tax, accounting, payment, dispute resolution, fraud prevention, or legal compliance purposes.
Usage DataUp to 24 months for analytics, service improvement, personalization, recommendation, and product optimization purposes.
Device and Log DataUp to 12 months for security monitoring, troubleshooting, fraud prevention, and technical maintenance purposes.
Customer Support RecordsUp to 24 months after resolution of the relevant inquiry, complaint, or dispute, unless longer retention is necessary for legal, compliance, or dispute resolution purposes.
Advertising and Attribution DataUp to 24 months, or as otherwise required by advertising partners, attribution providers, applicable platform rules, or applicable law.
User ContentFor as long as it remains available in the Mini-Program or as long as reasonably necessary for service operation, moderation, safety, legal compliance, dispute resolution, or protection of our rights.

We may retain information longer where necessary to comply with law, resolve disputes, prevent fraud, enforce our agreements, maintain security, or protect legal rights.

7. Data Security

We use reasonable technical, administrative, and organizational measures designed to protect personal information from unauthorized access, disclosure, alteration, loss, misuse, or destruction. These measures may include encryption, access controls, logging, security monitoring, employee training, and vendor management.

However, no system or method of transmission or storage is completely secure. We cannot guarantee absolute security.

8. U.S. State Privacy Rights

Depending on your state of residence, including if you are a California resident, you may have certain privacy rights under applicable U.S. state privacy laws.

These rights may include:

8.1 Right to Know and Access

You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, purposes of collection, categories of third parties to whom we disclose information, and other information required by applicable law.

8.2 Right to Delete

You may request that we delete personal information we have collected from or about you, subject to exceptions permitted by law.

8.3 Right to Correct

You may request that we correct inaccurate personal information we maintain about you.

8.4 Right to Data Portability

You may request a copy of certain personal information in a portable and readily usable format, where technically feasible.

8.5 Right to Opt Out of Sale, Sharing, or Targeted Advertising

We do not sell personal information for money. However, if our use of advertising, analytics, attribution, or similar technologies is considered a "sale," "sharing," or "targeted advertising" under applicable law, you may request to opt out.

8.6 Right to Correct

You may request that we correct inaccurate personal information we maintain about you.

8.7 Right to Limit Use of Sensitive Personal Information

We do not use sensitive personal information for purposes beyond what is necessary to provide the Mini-Program. If we collect any sensitive personal information, we will limit its use to what is necessary and will not use it for purposes beyond those disclosed at the time of collection.

8.8 Non-Discrimination

We will not discriminate against you for exercising any applicable privacy rights. We will not deny goods or services, charge different prices, or provide a lower quality of service to you because you exercised your privacy rights, unless the difference is reasonably related to the value of your data.

9. How to Exercise Your Rights

To exercise your rights, please contact us at support@nextgenteglobal.com with "Privacy Request" in the subject line. Please describe your request in detail so we can respond appropriately.

To verify your identity and protect your information, we may ask you to provide information sufficient to confirm your identity or to describe your request. We will endeavor to respond to your request within the timeframes required by applicable law.

9.1 Authorized Agents

If you are acting as an authorized agent on behalf of another person, we may require proof that you have written authorization from that person to act on their behalf, or that you are a duly authorized legal representative such as a parent or guardian of a minor or a legal guardian of an incapacitated person.

9.2 Timing of Response

We will endeavor to respond to verifiable consumer requests within 45 days of receipt. If we require more time (up to an additional 45 days), we will notify you of the extension and reason.

9.3 Fees

We do not charge a fee for responding to your privacy requests, unless your requests are manifestly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond.

9.4 Appeal Process

If we decline to take action in response to your privacy request, you may appeal our decision by contacting us at support@nextgenteglobal.com with "Privacy Appeal" in the subject line. We will endeavor to respond to your appeal within the timeframe required by applicable law.

9.5 Additional State-Specific Rights

Depending on your state of residence, you may have additional privacy rights not listed above. Please contact us for more information.

9.6 California-Specific Rights

If you are a California resident, California law provides you with specific rights regarding your personal information. Please see Section 8 for more information about your rights and how to exercise them.

9.7 California "Shine the Light"

California residents may request information about our disclosure of certain personal information to third parties for their direct marketing purposes. To make such a request, please contact us at support@nextgenteglobal.com with "California Shine the Light Request" in the subject line.

9.8 California Minors' Content Removal

If you are a California resident under 18 and have posted content in the Mini-Program, you may request removal of your content by contacting us at support@nextgenteglobal.com.

10. Children's Privacy

The Mini-Program is not intended for children under 13 years old. We do not knowingly collect personal information from children under 13.

If you are under 13, you must not use the Mini-Program or provide any personal information to us.

If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will take reasonable steps to delete the information and terminate the child's access.

If you are a parent or legal guardian and believe that your child under 13 has provided personal information to us, please contact us at support@nextgenteglobal.com.

Users between 13 and the age of majority must use the Mini-Program only with parental or guardian consent.

11. International Data Transfers

We are a Vietnam-based company. Your personal information may be transferred to, stored in, or processed in Vietnam, the United States, Singapore, or other countries where we or our service providers operate.

These countries may have data protection laws that differ from those in your state or country of residence. We take reasonable steps to protect personal information in accordance with this Privacy Policy and applicable law.

12. Third-Party Links and Services

The Mini-Program may contain links to or integrations with third-party websites, apps, platforms, payment processors, advertising networks, analytics tools, or other services.

This Privacy Policy does not apply to third-party services. We are not responsible for the privacy practices of third parties. You should review the privacy policies of TikTok and any other third-party services you use.

13. Your Choices

You may have the following choices regarding your personal information:

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will provide notice by updating the "Last Updated" date and, where appropriate, by providing an in-app notice, pop-up notice, or other reasonable notice.

Your continued use of the Mini-Program after the updated Privacy Policy becomes effective means that you acknowledge the updated Privacy Policy. If you do not agree with the updated Privacy Policy, you should stop using the Mini-Program.

15. Contact Us

If you have questions, complaints, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

NEXTGEN TECHNOLOGY AND ENTERTAINMENT JOINT STOCK COMPANY
Enterprise Registration No.: 0110958885
Address: 5th Floor, IC Building, No. 82 Duy Tan Street, Dich Vong Hau Ward, Cau Giay District, Hanoi City, Vietnam
Email: support@nextgenteglobal.com
Subject line for privacy requests: Privacy Request

We aim to respond to privacy inquiries within a reasonable time and in accordance with applicable law.