INTRODUCTION

VocaGame.com in this Privacy Policy may refer to NEVER STOP GAMING SDN BHD, its affiliates, group companies, and subsidiaries of NEVER STOP GAMING SDN BHD, including the representatives of NEVER STOP GAMING SDN BHD, such as financial, insurance, legal, accounting advisors, or other professional advisors of VocaGame.com, and third parties cooperating with NEVER STOP GAMING SDN BHD, such as partners, vendors, and subcontractors.
This Privacy Policy is an integral part and is inseparable from the Terms and Conditions of VocaGame.com. Capitalized terms used in this Privacy Policy have the same meaning as those stated in the Terms and Conditions of VocaGame.com.
VocaGame.com reserves the right to update this Privacy Policy from time to time to remain relevant and current with changing technologies, applicable laws, evolving business practices of VocaGame.com, and the needs of VocaGame.com users. If any changes are made to this Privacy Policy, VocaGame.com will provide a “Last Updated” date. VocaGame.com encourages users to periodically review this Privacy Policy to stay informed on how VocaGame.com manages data and personal information. By using the Service, users are deemed to explicitly agree to this Privacy Policy, and by continuing to use the Service after this Privacy Policy, users are deemed to have read, understood, and agreed to the updated Privacy Policy.
THIS PRIVACY POLICY REPRESENTS AN AGREEMENT BETWEEN THE USER AND VocaGame.com. USERS FULLY AND VOLUNTARILY AGREE TO THE TERMS AND CONDITIONS TO USE THE SERVICES ON THE VocaGame.com PLATFORM.

APPLICABLE LAWS AND REGULATIONS

VocaGame.com is subject to all applicable laws and regulations of the Republic of Indonesia, including those governing electronic information and transactions, the administration of electronic systems, and the protection of Users' personal data; including all implementing regulations and amendments to such regulations that govern and protect the use of important data and information of Users.

ACQUISITION AND PROTECTION OF DATA

VocaGame.com has the right to request Users' data and information, including but not limited to the following:

• Account-related information for VocaGame.com

Name
Username
Email
Phone Number
Address and/or location
Profile information, including Date of Birth, Gender
Transaction, financial, and/or banking information

• Information about the products, features, and services selected by the User

User's preferences and interests
User's experience information
Photos and media information on the User's device
QR Code scanning information
Real-time geo-location information
Survey results sent by VocaGame.com or on behalf of VocaGame.com
User’s activity logs (including but not limited to IP address, date and time of access, app features, website pages viewed, app operation processes, and other system activities, web browser type, and/or third-party sites or services used before interacting with the site)
Other User information, including but not limited to registration activity, login, transactions, and others

• Information from Third Parties

Personal information from third parties cooperating with VocaGame.com, such as vendors, agents, professional advisors, consultants, and others, may be collected by us in connection with the purpose of engaging third parties.
VocaGame.com may receive information about the User from Third Parties, provided that the Third Party has obtained the User's consent to share the necessary (relevant) information. For example, shipping and address information from VocaGame.com's operator, which VocaGame.com uses to improve its records and facilitate future purchases.

By providing the information listed in sections (a) to (c) above, the User waives the right to any claims, damages, demands, and lawsuits that may arise from the acquisition, storage, use, exploitation, and/or disclosure of information, including personal information, within the VocaGame.com System.

• The User hereby gives explicit consent to VocaGame.com to collect, gather, process, analyze, store, display, use, exploit, publish, transmit, disclose, distribute, delete, and destroy the personal data and information provided (input) by the User into the VocaGame.com System, including the User’s personal data, product photos, chats, and conversations within the VocaGame.com system. The User affirms that this consent for personal data and information is given voluntarily, competently, and knowingly, and the consent is provided at the time of creating a VocaGame.com account ("User Consent").

• Based on the User Consent, the User declares that all such data and information belong to VocaGame.com. To avoid doubt, personal data provided by the User, whether entered into the VocaGame.com Platform or not, belongs to the User as part of their full personal rights.

• The User hereby affirms that the personal data they provide (input) into the VocaGame.com System (including documents uploaded and/or provided to VocaGame.com) is genuine, authentic, true, accurate, complete, not misleading, up-to-date, and is the User’s own personal right, or they have the authority to provide the User’s personal data to the VocaGame.com System.

• VocaGame.com protects all information provided by the User when using any services on VocaGame.com, including maintaining the confidentiality, integrity, and availability of personal data it manages.

• VocaGame.com has the right to request authentication and updates of the User's personal data from time to time, so that the User’s data and information remain accurate, complete, and up-to-date, including temporarily suspending and/or permanently discontinuing services if the User has not updated and authenticated their personal data.

• The User has the right to update their personal data from time to time.

• The User understands that the use of certain features within VocaGame.com requires further authentication of personal data and is subject to the Terms of Use of VocaGame.com as well as the terms and conditions of specific features on VocaGame.com. The User affirms that the User Consent is explicit consent for the acquisition, storage, use, exploitation, and/or disclosure of personal data the User provides (input) into the VocaGame.com System and specific features on VocaGame.com, and acknowledges that this consent is given voluntarily, competently, and knowingly.

• The User releases VocaGame.com from any demands, legal claims, damages, and/or demands related to transaction processing failures on the VocaGame.com application caused by inaccuracies/insufficient information in the Personal Data provided by the User to VocaGame.com.

USE, STORAGE, UTILIZATION, AND PROCESSING OF DATA

• VocaGame.com will collect, use, store, utilize, process, analyze, transmit, and disclose Users' personal data for the following purposes and other purposes permitted by applicable laws and regulations:

Service and Product Transaction Processes. The purposes include but are not limited to: (i) receiving, processing, and verifying the selection, ordering, purchasing, payment, return, transfer, and redemption of Products, (ii) know-your-customer ("KYC") requirements, (iii) internal data processing, (iv) communicating with Users regarding orders, data verification, products and services, and promotional offers, (v) monitoring and identifying User transaction patterns, (vi) billing, activation, provision, maintenance, support, troubleshooting, deactivation, replacement, upgrade or renewal of Services, (vii) administrative purposes, (viii) processing all forms of User activities including but not limited to transaction processing, payment verification, product delivery, service usage, (ix) managing or responding to User inquiries, (x) using bank account information including name and account number to verify payment/receipt by the User, (xi) to fulfill or enforce applicable notices related to the Services.
Providing, troubleshooting, and improving VocaGame.com Services. VocaGame.com uses Users' personal data to: (i) provide functionality, analyze performance, fix errors, and enhance the usability and effectiveness of the Services, (ii) ensure the Services function technically as intended and help identify and resolve issues.
Recommendations and personalization. VocaGame.com uses Users' personal data to recommend features, products, and services that may be of interest to the User, to better understand, analyze, and predict User preferences and interests, to combine this information with other data to tailor the User experience, and to personalize the User’s experience with the Services.
Providing image and camera services. When Users use image and camera services, VocaGame.com uses images, videos, and other personal data to respond to User requests, provide requested services, and enhance VocaGame.com services.
Compliance with legal obligations. In certain cases, VocaGame.com collects and uses Users' personal data to comply with laws, regulations, and respond to emergency situations. For example: (i) collecting Users’ bank account information for identity verification and other purposes, (ii) responding to court orders, subpoenas, or other legitimate legal or law enforcement requests, (iii) requests or official orders from authorities, agencies, or institutions under applicable legal provisions, including but not limited to disputes, investigations, legal processes, and resolution between VocaGame.com and Users, between Users, or Users and third parties, as well as other illegal activities, (iv) requests from banking, financial, or authorized non-financial institutions, and/or third parties based on official requests and applicable laws, (v) providing emergency assistance in situations that may threaten the life, health, or physical safety of the User or others.
Communication with Users. VocaGame.com uses Users’ personal data to communicate with them regarding the Services through various channels (e.g., phone, email, chat).
Advertising, promotion, and personalization. VocaGame.com uses Users’ personal data to: (i) display promotional and interest-based advertising for features, products, and services that may interest the User, including using advertising identifiers or similar identifiers provided by other software platforms to facilitate analytics or promotional content delivery, (ii) facilitate User access to and use of Services and/or third-party offers, (iii) send subscription offers, messages, news, and posts within the Service on behalf of VocaGame.com.
Fraud and money laundering prevention and credit risk assessment. VocaGame.com uses Users' personal data to prevent and detect fraud, money laundering, and abuse to protect the security of Users, VocaGame.com, and others. Credit risk scoring methods may also be used.
Service development. VocaGame.com uses Users’ personal data to develop new services and improve existing ones, and to provide Users with information about third-party content or related products, services, and software, including to communicate with Users in various ways, for example to provide or send: (i) updates or notifications about service or related third-party content improvements or updates; (ii) promotional notices, contests, offers, and upcoming events; (iii) personalized information, surveys, marketing materials, advertisements or content. Also for: (i) detecting, monitoring, investigating, mitigating or preventing fraud and technical or security issues or to protect the property of VocaGame.com; (ii) enabling business continuity and disaster recovery operations; (iii) obtaining legal services, seeking legal advice, and/or enforcing the legal rights of VocaGame.com or its members; (iv) statistical purposes; (v) business, product, quality, and service development including promotional activities, studies, research, and cooperation with third parties.
When necessary for clearly beneficial purposes for the User and where User consent cannot be obtained in a timely manner.
Other purposes as informed by VocaGame.com to the User from time to time, and as required, permitted, or mandated by applicable laws and regulations.

• VocaGame.com may cooperate with companies and other third parties who facilitate or assist in the development of certain services for and/or on behalf of VocaGame.com, including:

Providing assistance to Users;
Carrying out services related to the Platform (including but not limited to maintenance services, database management, feature analysis, and improvement of the Platform);
Assisting VocaGame.com’s professional advisors and external auditors, including legal advisors, financial advisors, and consultants. These third parties will only have access to User Data to perform these tasks for and/or on behalf of VocaGame.com and are contractually bound not to disclose or use such Personal Information for any other purpose.

• In disclosing information, VocaGame.com may share portions of User Data so that the information becomes non-identifiable (aggregate/anonymous data), which may be used by third parties for Platform development, database management, analysis or service improvements, promotion, and advertising.

• VocaGame.com may also combine User Data with other information in such a way that it no longer associates with any User, and may disclose such combined information to third parties for purposes mentioned in point 3.

• For the purposes of developing, enhancing, improving, protecting, and maintaining Platform products and/or Services, VocaGame.com may be required to process, utilize, display, disclose, publish, transmit, transfer, and/or disseminate Personal Data to third parties. For clarity, such third parties may include, but are not limited to:

Third parties within the same corporate group, subsidiaries, affiliates, partners, and vendors of VocaGame.com, in connection with the provision of the Platform, business operations, service delivery, data management, and other activities;
Interests of VocaGame.com, its affiliates, corporate group, and subsidiaries for business development, product, quality, and service improvements, including promotions, studies, research, and collaborations with other third parties;
The interest of VocaGame.com in fulfilling transaction purposes, such as the sale of all or part of VocaGame.com’s assets, including any purchase, sale, lease, merger, amalgamation, acquisition, disposal, or financing involving VocaGame.com, its affiliates, subsidiaries, or corporate group;
Third parties involved in corporate transactions, such as joint ventures, restructurings, reorganizations, divestitures, mergers, acquisitions, consolidations, takeovers, asset sales, or liquidations;
Third parties related to service providers engaged by VocaGame.com to perform functions on behalf of VocaGame.com. Examples include removing duplicate information from User lists, analyzing data, marketing support, providing search results and links (including paid listings and links), processing payments, delivering content, conducting reviews, assessing and managing credit risks, and providing customer services where applicable. These third-party service providers have access to Personal Data necessary to perform their functions, but are not permitted to use it for any other purposes;
Other third parties (including agents, vendors, suppliers, contractors, and third parties providing services to VocaGame.com or Users, or performing tasks on behalf of VocaGame.com through commercial collaborations) for or in connection with VocaGame.com’s purposes involving third parties or in third-party collaborations (depending on the circumstances), which may include allowing such third parties to introduce or offer products or services to Users, or to conduct other activities including marketing, research, analysis, and third-party product development (as applicable).

• In relation to the implementation of widgets or content from within the VocaGame.com application and/or Platform, VocaGame.com declares that third parties may transmit, submit, and/or provide Users’ Personal Data to other parties working with the relevant third parties. In this case, such parties receiving the Users' Personal Data will be subject to obligations regarding the transmission and use of such data equivalent to those applicable to VocaGame.com's third parties.

• VocaGame.com reserves the right to store Users’ personal data and information for service purposes, this Privacy Policy’s purposes, regulatory compliance, and applicable legal purposes, including processing, transferring, and/or storing Users’ data and information both within and outside the territory of the Republic of Indonesia, while taking into account applicable regulations, including laws and privacy policies in the countries where Users’ data is processed, transferred, and/or stored.

• VocaGame.com endeavors to protect the security of Users' Personal Data during transmission using encryption protocols and software and ensures that any Personal Data collected and/or gathered by VocaGame.com will be securely stored in accordance with the applicable laws and regulations of the Republic of Indonesia. Users understand and agree that VocaGame.com will maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of Users’ Personal Data. Users agree that VocaGame.com will retain Personal Data as long as necessary to fulfill the purposes described in this Privacy Policy.

• The Platform may contain links to third-party websites. VocaGame.com is not responsible for the acquisition, collection, processing, analysis, use, storage, display, publication, transmission, dissemination, deletion, or destruction of Users’ Personal Data by such third parties. If Users provide information directly to such sites, their privacy policies and terms of service will apply, and all consequences of such actions are entirely the responsibility of the User.

• VocaGame.com, its affiliates, corporate group, and subsidiaries, including its representatives and third parties working with VocaGame.com in providing the Services, are entitled to use and process Users’ personal data and information to fulfill the Service purposes, the purposes of this Privacy Policy, and applicable laws and regulations. The use and processing of such data are governed by agreements containing confidentiality clauses binding the parties involved, including VocaGame.com’s representatives.

• VocaGame.com may transfer Users’ Personal Data to its affiliate platforms or service providers, or to third-party recipients. By agreeing to this Privacy Policy, Users also consent to the transfer of their Personal Data to VocaGame.com’s affiliate platforms, service providers, or third-party data recipients for service development, whether technical, commercial, or otherwise. Wherever Users’ Personal Data is transferred, stored, or processed by VocaGame.com, its affiliate platforms, third parties, or other service providers, VocaGame.com will take reasonable steps to protect the privacy of Users' Personal Data.

DATA STORAGE

The data and information of Users on the Platform will be stored for as long as they are used for the purposes outlined in this Privacy Policy and as required by applicable laws and regulations. VocaGame.com will cease storing User data and information immediately if VocaGame.com determines that the data collected is no longer relevant to the purpose of collection, storage of such data is no longer necessary, is not permitted to be stored, or is required to be deleted by applicable law.

DATA DELETION

For various promotional updates and exclusive offers, Users may unsubscribe if they do not wish to receive such information by clicking the "unsubscribe" link in the email sent by VocaGame.com, or by adjusting the “Promo” notification settings in the VocaGame.com application.
Users may withdraw their consent regarding the use of their personal data and information, including by ceasing to use and access the Services, and/or closing their account, in accordance with the provisions of applicable laws and regulations (including retention requirements mandated by applicable law). The User hereby acknowledges that they understand the consequences of withdrawing their consent, including but not limited to no longer being able to enjoy the Services.
Subject to applicable laws and regulations, Users may request data deletion from VocaGame.com through the VocaGame.com Customer Service by providing: a completed data deletion request form provided by VocaGame.com; valid identification (ID card/driver’s license/passport) that matches the identity on their VocaGame.com Account page; and the reason for the deletion request.
Users are required to first read and agree to the Terms and Conditions of Account Deletion.
VocaGame.com will approve the User’s data deletion request if it meets the requirements outlined in point 3 above and the User has fulfilled all rights and obligations with VocaGame.com within a reasonable timeframe.
Upon User request, VocaGame.com may anonymize the collected data and information so that the User can no longer be identified.
VocaGame.com reserves the right to retain User data for the retention period established by VocaGame.com in its system in accordance with applicable laws and regulations.
VocaGame.com reserves the right to refuse a User's request to access and/or modify or delete their Personal Data on justified grounds based on applicable laws and regulations.
Data deletion and storage will be conducted by VocaGame.com in accordance with the provisions of applicable laws and regulations.

LIMITATION OF LIABILITY OF VocaGame.com

Users are responsible for the security and mitigation of breaches of their own VocaGame.com Account, such as maintaining the confidentiality of their Personal Data, implementing appropriate safeguards, restricting access, creating strong passwords and/or PINs (personal identification numbers), keeping their passwords and/or PINs secure wherever their Personal Data is stored, and safeguarding their one-time password ("OTP").
Users are responsible for any misuse of passwords and/or PINs (whether by the User or third parties) or misuse of the Platform, which are created and used by the User or third parties who obtain such information on the Platform and/or third-party platforms affiliated with the User to access the User’s Personal Data, including Accounts, passwords, and/or PINs used to access or log in to the User’s applications, if the misuse is done by parties other than the User. Such misuse is not the responsibility of VocaGame.com.
Users must immediately notify VocaGame.com if they believe that the passwords and/or PINs of the VocaGame.com Platform and/or third-party platforms affiliated with VocaGame.com have been misused by unauthorized and/or irresponsible parties.
VocaGame.com is not responsible for the exchange and disclosure of Users’ personal data and information carried out by the Users themselves, including interactions between Users. This includes any and all User errors that result in data leaks.
VocaGame.com is responsible for the VocaGame.com Platform, including the protection and safeguarding of personal data confidentiality, and shall notify the User in the event of a personal data protection failure, at minimum via the User’s registered email on the VocaGame.com Platform, and report the incident to law enforcement or the relevant authorities. In the event of a data breach, the responsible party for informing the User about the protection failure is the entity or institution where the data was processed in accordance with this Privacy Policy.
VocaGame.com is not responsible for the authenticity, accuracy, correctness, or completeness of personal data inputted by the User into the VocaGame.com Platform.
By providing their consent, the User waives any rights to claims, losses, demands, and legal actions that may arise from the acquisition, storage, use, processing, and/or disclosure of data, including personal data, on the VocaGame.com Platform.
In the case that the User is a minor, VocaGame.com shall not be held responsible for the entry of personal data by the User and encourages parents/guardians to monitor their child’s internet use to ensure that the submission of personal data is done with and/or under the supervision of a parent/guardian as the authorized party.
VocaGame.com shall not be held liable for data breaches caused by circumstances beyond its control or capability (Force Majeure). Force Majeure includes but is not limited to: (i) mass strikes, company shutdowns, and other industrial actions; (ii) riots, demonstrations, unrest, invasions, coups, sabotage, embargoes, drastic political/economic changes, terrorist attacks or threats, war (declared or undeclared), or preparations for war; (iii) earthquakes, hurricanes, landslides, floods, fires, explosions, storms, other natural disasters, epidemics or pandemics whether officially declared or not, as well as the enactment of new laws or regulations that directly or indirectly impact the implementation of this Privacy Policy, which result in the inability of a party to fulfill its obligations under this Privacy Policy; (iv) unavailability or disruption of delivery networks (including transportation routes); (v) unavailability or disruption of telecommunication, information systems and technology, widespread internet outages, or lightning strikes; (vi) system failures caused by third parties beyond the control of VocaGame.com (e.g., third-party hacking and/or viruses); (vii) malfunctioning of banking systems and/or networks; (viii) actions, rulings, laws, regulations, or restrictions issued by the government relating to the implementation of this Privacy Policy; and (ix) changes in economic and financial conditions, and regulatory restrictions affecting the use of this Privacy Policy.

COOKIES

Cookies are small data storage files placed on computers or other devices such as smartphones or tablets when Users browse and/or visit the VocaGame.com Platform.
The User’s computer or other devices will automatically receive Cookies when the User browses and/or visits the VocaGame.com Platform and when the User uses services provided by VocaGame.com (“Cookie Usage”). However, Users may choose to modify or reject the use of Cookies through their web browser’s settings.
VocaGame.com uses Google Analytics (“Feature”), in which the data collected from the use of this Feature includes the User’s IP address, type of device, and other related information (“Data”). This Data is used by VocaGame.com for Platform and Content development as well as for advertising purposes. Users may opt out of being tracked by this Feature by downloading the Google Analytics Opt-Out Add-on on their web browser.
VocaGame.com may share User data and information derived from Cookie Usage with third parties, such as location data, advertising identifiers, or email addresses used for advertising segmentation, including but not limited to marketing and advertising needs, where such data and information cannot personally identify the User.
Users can manage Cookie Usage through their web browser’s settings by modifying or choosing to reject the use of Cookies. However, doing so may impact the performance of services when accessing the VocaGame.com Platform, such as certain functions or pages not working optimally for User services.

INTELLECTUAL PROPERTY RIGHTS

All works contained on the Services or Platform and its supporting systems, including but not limited to:
(a) the layout, design, and appearance of the Services or Platform as displayed on VocaGame.com media;
(b) logos, photos, images, names, brands, words, letters, numbers, texts, and color arrangements present on the Services or Platform; and
(c) the combination of elements referred to in points (a) and (b),
are entirely the Intellectual Property Rights of VocaGame.com, and no other party holds rights to the Services or Platform of VocaGame.com.
Users are not permitted at any time to:
Copy, modify, adapt, translate, create derivative works from, distribute, sell, transfer, publicly display, reproduce, transmit, broadcast, decompile, or otherwise exploit any part of the Platform (including its supporting systems and features) that is licensed to the User, except as permitted in this Privacy Policy;
License, sublicense, sell, resell, transfer, distribute or commercially exploit or otherwise make available the software and/or systems to any third party in any manner;
Publish, distribute, or reproduce in any way copyrighted materials, trademarks, or other proprietary information from VocaGame.com without prior written consent from the rights owner of VocaGame.com or from the rights holder who has licensed such rights to VocaGame.com;
Remove any copyright, trademark, or other proprietary notices contained in the services of VocaGame.com;
Reverse engineer the VocaGame.com application or its access and/or supporting systems to (i) build a competing product or service, (ii) build a product or service using similar ideas, features, functions, or graphics, or (iii) copy ideas, features, functions, or graphics;
Launch any automated programs or scripts, including but not limited to web crawlers, web robots, web indexers, bots, viruses, worms, or any similar applications and any program that may make multiple server requests per second, cause heavy load, or interfere with the operation and/or performance of the Platform;
Use any robot, spider, site search/retrieval application, or any other manual or automatic device or process to retrieve, index, "data mine", or in any way reproduce or circumvent the navigational structure or presentation of the VocaGame.com application and its contents.

CHANGES TO THE PRIVACY POLICY

VocaGame.com reserves the right to update and/or amend this Privacy Policy from time to time as deemed necessary for the security and convenience of User transactions on the VocaGame.com Platform, without prior notice. The User hereby agrees that they are responsible for carefully reading and reviewing this Privacy Policy periodically to stay informed of any updates and/or changes. By continuing to access and use the services on the VocaGame.com Platform, the User is deemed to have accepted such updates and/or changes to this Privacy Policy.

Last Updated: 11 July, 2025