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Privacy Policy

Topinsight Group Sdn. BHD. is a company specialising in escape room games (hereinafter referred to as the "Company","we", "us", "our" and its derivatives), offering the VR game "ZIGZAG: ESCAPE ROOM".

This policy stipulates how we collect, use, delete, protect, store, and otherwise process your personal information. If you have any questions about our privacy measures or this privacy policy, or wish to exercise the rights detailed in this privacy policy, please contact us at:

TOPINSIGHT GROUP SDN. BHD.

UNIT 6-1-1, QUEEN'S AVENUE, BLOCK 6, 1ST FLOOR, JALAN BAYAM OFF JALAN PEEL, 55100 KUALA LUMPUR W.P. KUALA LUMPUR MALAYSIA

Email: cnzigzag@gmail.com

1. SCOPE

This Privacy Policy applies to the personal information we process, including the personal information processed on our website, mobile applications, games, and other online or offline products. For ease of reading, this Privacy Policy refers to our website, mobile applications, games, and other products collectively as "Services."

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. The information we collect includes: information you provide to us on our website and through our mobile applications and games; information we automatically obtain when you use our Services; and information from other sources such as third-party services, organizations, and platforms, as detailed below:

A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us. Account Creation. When you create an account to play our games through Oculus, Steam, or other platforms, we may collect information from these platforms, such as your profile picture, display name, game platform user ID, or other information you provide through privacy settings on these platforms.
Beta Tester Information. If you sign up to be a beta tester for our services, we will collect your email address, name, age, gender, VR headset type/model, platform type, platform username, and Discord username.
Purchases. We may collect aggregate information from Oculus or Steam (e.g., content purchased and refund metrics). Any payments for our services are processed through Oculus or Steam. We do not collect or store any payment card information for purchases made on our services.
Interactive Features. We and others using our services may come into contact with personal information you submit or provide through our interactive features (such as the game itself, forums, blogs, and social media pages). Unless otherwise provided by applicable law, any information you provide on these features will be considered "public" information and is not subject to the privacy protections described in this document. Exercise caution before disclosing personal information to strangers through our services.
Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contest activities we offer. In some jurisdictions, we are required to publicly share information about winners of sweepstakes and contests.
Business Development and Strategic Partnerships. We may collect personal and third-party information to assess and seek potential business opportunities.

B. Information Collected Automatically

When you use our services, we may automatically collect personal information:
Automated Data Collection. When you use our services, we may automatically collect certain information such as your Internet Protocol (IP) address, user settings, cookie identifiers, platform identifiers, game analytics, player event data, bugs, and crash information, browser or device information, general location information (including approximate location derived from IP address), and hardware information such as your GPU (type and clock speed), CPU (type and clock speed), system memory, operating system region, and internet service provider. We may also automatically collect information about your use of our services, such as the pages you visit before, during, and after using our services, the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our services.
Cookies, Pixel Tags/Web Beacons, and Other Technologies. We and third parties that provide content, advertising, or other functionalities on our services may use cookies, pixel tags, local storage, and other technologies (collectively, "Technologies") to automatically collect information about you during your use of our services.

C. Information Collected from Other Sources We may obtain information about you from other sources, including other users and third-party services and organizations. For example, if a user chooses to send us game excerpts.

3. HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including providing services, administrative management, and marketing our products and services, detailed as follows.

A. Providing Services

We use your information to provide you with services, such as:

Managing your information and account;
Accessing certain areas, features, and characteristics of our services, including games;
Responding to customer or technical support requests;
Communicating with you about your account, activities on our services, and policy changes.

B. Administrative Purposes

Where we have a legal basis, we use your information for various administrative purposes, such as:

Product development (including market research);
Detecting security incidents, preventing malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for such activities;
Measuring user interest and engagement with our services;
Improving, upgrading, or enhancing our services;
Developing new products and services;
Ensuring internal quality control and security;
Verifying personal identity;
Debugging to identify and repair errors in our services;
Audits related to interactions, transactions, and other compliance activities;
Enforcing our agreements and policies;
Creating aggregated analysis information, such as information about the devices you use to access our services;
Processing applications when you apply for jobs we post on our services.

C. Marketing and Promoting

Our Products and Services We may use personal information to tailor and provide you with content and advertisements. We market to you through email campaigns, targeted online advertising on social media, and trade shows and other events. If you have any questions about our marketing practices, or if you wish to withdraw consent for the use of your personal information for marketing purposes, you can contact us at any time.

D. Other Purposes

We also use your information for other purposes at your request or where allowed by applicable law.

Consent. We may use personal information for other purposes that have been clearly disclosed to you at the time you provide your personal information, or for which we have obtained your consent.
Promoting Safety, Integrity, and Protection. We use the information collected to verify accounts and activity, combat harmful conduct, detect and prevent bad experiences, maintain the integrity of our services, and promote safety and security.
Sharing Content with Friends. Our services may offer various tools and functionalities. For example, our recommendation services may allow you to forward or share certain content with friends, such as invitation codes inviting your friends to use our services.
Fulfilling Our Legal Obligations. We may process personal information when necessary to fulfill our legal obligations, including when we sincerely believe that the law requires us to do so, or as described in "B. Disclosure to Others" necessary circumstances.

4. WHAT IS OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION

Necessary to fulfill our Terms of Service and provide services;
In accordance with your consent (which you may withdraw at any time);
Necessary to fulfill our legal obligations;
Occasionally necessary to protect the vital interests of you or others;
Required for the public interest;
Necessary for the legitimate interests of us (or others), unless these interests are overridden by your interests or the need to protect fundamental rights and freedoms related to personal data.

5. HOW WE SHARE YOUR INFORMATION

We share your information with third parties for the following business purposes: providing our services, protecting ourselves or others, or in the event of significant business transactions such as mergers, sales, or asset transfers, as described below.

A. Providing Services

We may share your information with the following categories of third parties.

Service Providers. We may share your personal information with our third-party service providers who use this information to help us provide our services. This includes providers offering us IT support, hosting, payment processing, customer service, marketing, and related services.
Business Partners.We may share your personal information with business partners to provide you with the products or services you request. We may also provide your personal information to business partners with whom we jointly offer products or services.
APIs/SDKs. We may use third-party Application Programming Interfaces ("APIs") and Software Development Kits ("SDKs") as part of the functionality of our services. For more information about our use of APIs and SDKs, please contact us.

B. Protecting Ourselves or Others

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us on our websites and through our mobile applications and games, information we obtain automatically when you use our Services, and information from other sources such as third-party services, organizations and platforms, as described below.

We may access, preserve, and disclose information related to you if we sincerely believe it is necessary or appropriate to: comply with law enforcement or national security requirements and legal processes, such as court orders or subpoenas; protect the rights, property, or safety of you, us, or others; enforce our policies or contracts; collect amounts owed to us; or assist in an investigation or prosecution of suspected or actual illegal activities.

C. In the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase, or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and contract.

6. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Rights. Under applicable law, you have the right to:

Access information about your personal information.
Request correction of inaccurate, incomplete, or outdated personal information.
Request the deletion or anonymization of your personal information;
Request restrictions on our processing of your personal information;
Have the right to object to our processing of your personal information for direct marketing purposes or based on our legitimate interests;
Revoke consent to our processing of your personal information. If you do not provide personal information or revoke consent to processing, some features of our services may not be usable;
Request data portability and obtain an electronic copy of the personal information you have provided to us, and understand the circumstances in which your personal information is shared with third parties.

7. SECURITY OF YOUR INFORMATION

We take measures to ensure the secure handling of your information in accordance with this Privacy Policy. We have implemented appropriate safeguards to ensure that your personal information is always protected, and we require our third-party service providers and partners to implement appropriate safeguards as well.

By using our services or providing us with personal information, you agree that we may communicate electronically with you about security, privacy, and administrative issues relating to your use of our services.

8. INTERNATIONAL DATA TRANSFERS

As a U.S. company, it is necessary for us to transfer your personal information to the United States and other third countries outside the UK/European Economic Area in order to provide you with our services, where the data protection laws may differ and offer less protection than the laws of your residence. When we transfer personal data from the UK/European Economic Area to third parties in third countries, we use standard contractual clauses approved by the European Commission and rely on the European Commission's adequacy decisions for certain countries (where applicable) for such transfers.

9. RETENTION OF PERSONAL INFORMATION

We retain the personal information described in this Privacy Policy as long as you use our services, or as necessary to achieve the purposes for which the personal information was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

10. CALIFORNIA RESIDENTS SUPPLEMENTAL NOTICE

This "California Residents Supplemental Notice" applies only to our processing of personal information of individuals governed by the California Consumer Privacy Act of 2018 ("CCPA"). The CCPA provides California residents the right to know what categories of personal information we have collected and whether we have disclosed that personal information for a business purpose (e.g., to service providers) in the past 12 months. California residents can find this information below:

Identifiers such as aliases, online identifiers, Internet Protocol addresses, or other similar identifiers.
California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Internet or other electronic network activity.
Information regarding a consumer's interaction with an Internet website or application.
Sensory data.
Audio, electronic, visual, or similar information.

Regarding the CCPA, TOPINSIGHT GROUP SDN. BHD. does not "sell" personal information, and we are not aware of any "sale" of personal information of minors under 16 years of age.

Other Privacy Rights for California Residents

If you are a California resident, subject to certain exceptions and applicable law, you may have certain rights regarding the information we process about you:

Right to Know. Regarding the above access right, you may request that we disclose to you the categories and specific pieces of your personal information that we have collected in the past 12 months, the categories of sources from which your personal information was collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose in the past 12 months, the categories of third parties with whom we have shared your personal information, and each business or commercial purpose for the disclosure.
Right to Delete. Regarding the above deletion right, you may request that we delete any personal information that we collected from you.
Right to Non-Discrimination. You have the right to not receive discriminatory treatment by us for exercising the rights afforded by the CCPA.
Authorized Agent. Only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your personal information.
Verification. To protect your privacy, we will take steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, email address, or game platform user ID.

If you are a California resident and wish to exercise any rights under the CCPA, please contact us, and we will process such requests in accordance with applicable law.

11. SUPPLEMENTAL FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please be aware that, in accordance with Chapter 603A of the Nevada Revised Statutes, we currently do not sell your personal information.

12. CHILDREN’S INFORMATION

Our services are not intended for children under the age of 13 (or other age as specified by local laws), and we do not knowingly collect personal information from children.

If you are a parent or guardian and wish to review the information collected from your child, or modify or delete such information, you can contact us. If we discover that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we are legally obligated to retain this information, and terminate the child's account and/or revert it to a minor experience (where applicable).

13. OTHER PROVISIONS

Third-Party Websites/Applications. The service may contain links to other websites/applications, and other websites/applications may reference or link to our services. These third-party services are not under our control. We encourage users to read the privacy policies of every website and application with which they interact. We do not endorse, screen, or approve the privacy practices or content of such other websites or applications and are not responsible for them. The risk associated with providing personal information to third-party websites or applications is borne by the user.

Regulatory Authorities. If you believe that our processing of your personal information violates applicable law, including the laws of the EU and UK, you have the right to lodge a complaint with your local regulatory authority.

Changes to the Privacy Policy. If there are any significant changes to this Privacy Policy, we will notify you and take any other steps required by applicable law.

14. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or wish to exercise the rights provided in this Privacy Policy, please contact us at:

TOPINSIGHT GROUP SDN. BHD.

UNIT 6-1-1, QUEEN'S AVENUE, BLOCK 6, 1ST FLOOR, JALAN BAYAM OFF JALAN PEEL, 55100 KUALA LUMPUR W.P. KUALA LUMPUR MALAYSIA

Email: cnzigzag@gmail.com