Privacy Notice

Last Updated: July 1, 2023

Introduction

The Game is provided, operated and managed by Nuverse (Hong Kong) Limited ("Nuverse") and Second Dinner Studio, Inc ("SecondDinner"). Each of Nuverse and Second Dinner collects and processes your personal data independently. This Privacy Notice explains how Nuverse, whose registered address is at Unit 1003, 10/F., Tower 2, Silvercord, 30 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong, collects, uses, discloses and otherwise processes your personal data. For information regarding how SecondDinner collects, uses, discloses and otherwise processes your personal data, please refer to SecondDinner Privacy Notice.


Information We Collect
We may collect and use the following information from and about you, such as:


Information You Provide


Automatically Collected Information
We automatically collect certain information from you when you use the Services, like your device or app usage data when you access the Services, such as through SDKs or APIs. This information may include, for example, technical information about your system, network, or device (e.g., your operating system, device model, system language, and device resolution), information about your usage of the services (e.g., items you purchase on the Services), and information about your experience on the Services to infer your interests. We also automatically collect certain information from you when you use the Services through cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”). We and our service providers and business partners may use these technologies, for example, to measure and analyze how you use the Services, including which pages you view most often and how you interact with content, enhance your experience using the Services, facilitate payments on the Services, improve or promote the Services, and measure the effectiveness of advertisements and other content. We will obtain your consent to our use of cookies where required by law.


Information from Other Sources
We may receive information about you from other sources, including through service providers, business partners, or other third parties. For example, our third-party partners may use technologies such as software development kits (SDKs) or APIs to gather information about your activities on our Services and other sites. This may include, for example, log-in records, purchase history, and information about how your app is working. Please see <How We Share Your Information> for more details on our collaborations with our partners, including advertising and analytics partners.
Some of the information that we collect is required for certain features to work, for example, we collect third party account information (e.g., from Facebook) to allow you to log in using a third party service. Some of the above personal information may be collected whenever you are using the Services, irrespective of your account login or registration status.

How We Use Your Information
As explained below, we use the information we collect about you to improve, support and administer the Services, to allow you to use its functionalities, and to fulfill and enforce our applicable Terms of Service. We may also use your information to, among other things, show you suggestions, promote the Services, and customize your experience.
We generally use the information we collect from and about you:


How We Share Your Information
We are committed to maintaining your trust. We want you to understand when and with whom we may share the Information We Collect. We may share the Information We Collect:


We will occasionally include links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own Privacy Policies and please check these policies before submitting any information to these sites.


Data Security
We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information. Therefore, be sure to consult the security measures adopted by third parties in their respective privacy policies.


Data Retention
We retain information for as long as necessary to provide the Services and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Services, and enhancing its safety, security and stability), and for the exercise or defense of legal claims.
The retention periods will be different depending on different criteria, such as the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Services, we keep this information for as long as you have an account.
In some cases, we may aggregate or anonymize your personal information and use it in a way that is designed to be unable to identify you, for research or other purposes, to the extent allowed by applicable law.


Your Rights and Choices
Depending on where you live, you may have certain rights with respect to your personal information, such as a right to know how we collect and use your personal information. You may also have a right to access, change, oppose, request a copy of your authorization, file complaints before the competent authorities, withdraw your consent, or limit our collection and use of your personal information as well as to request that we delete it, and potentially others. In certain circumstances, you can also ask us to provide additional information about our collection and use of your personal information. Please note that your exercise of certain rights may impact your ability to use some or all of Nuverse's features and functionalities.
If you previously chose to share precise location information, you can prevent your device from sharing precise location information (e.g.,GPS location information) with the Services at any time through your device’s operating system settings or by contacting us by email as described in the “Contact Us” section.
If you have registered for an account, you may also be able to access, review, and update certain personal information that you provided to us by logging into your account and using available features and functionalities.
You may also be able to control the information we collect about you through your device browser settings to refuse or disable Cookies. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, your choice to disable Cookies is specific to the particular browser or device that you are using when you disable Cookies, so you may need to separately disable Cookies for each type of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Services may no longer be available to you.
You may also opt out of marketing or advertising emails by using the “unsubscribe” link or mechanism noted in marketing or advertising emails.
Please contact us by using the contact information provided in the “Contact Us” section if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification.


Information Relating to Minors
The Services are not directed at children under the age of 13. The minimum age to use the Services may differ depending on the country or region you are in. If you believe that we have collected personal information from a minor under the minimum age, please contact us through the methods listed in the “Contact Us” section.


International Data Transfers
The personal information we collect from you may be stored on servers located outside of the country where you live. We store the information we collect in secure servers located in the United States and Singapore. Where we transfer any personal information out of the country where you live, including for one or more of the purposes as set out in this Policy, we will do so in accordance with the requirements of applicable data protection laws.


Privacy Policy Updates
We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you of any material changes to this policy by updating the “Last Updated” date at the top of the new Privacy Policy, posting the new Privacy Policy, or providing any other notice required by applicable law. We recommend that you review the Privacy Policy from time to time to stay informed of our privacy practices.


Contact Us
Questions, comments and requests regarding this Privacy Policy should be addressed to legal@marvelsnap.com
SUPPLEMENTAL TERMS JURISDICTION-SPECIFIC
If you are using the Services in the following jurisdictions, the respective jurisdiction-specific terms below will apply. In the event of a conflict between the provisions of the Supplemental Privacy Policy –Jurisdiction-Specific section of this Privacy Policy that are relevant to your jurisdiction from which you access or use the Services, and the rest of this Privacy Policy, the relevant jurisdictions’ Supplemental Privacy Policy – Jurisdiction-Specific provisions will supersede and control.


United States
If you are using our Services in the United States, the following additional terms apply:
Your Rights and Choices
Depending on where you live, you may be entitled to certain rights with respect to your personal information, subject to certain exceptions, as described below:


You may also have other choices regarding the use and disclosure of your personal data. For example, you may be able to manage third-party advertising preferences for some of the third parties we work with to serve advertising across the Internet by using the choices available at https://www.networkadvertising.org/managing/opt_out.asp and https://www.aboutads.info/choices.
You may exercise the rights above rights by contacting us via the methods listed in the “Contact Us” section above. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.
You may appeal any decision we have made about your request by replying to the communication you receive from us communicating our decision. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Services may change or no longer be available to you.


California Residents
Categories of Personal Information About You We Collect, Use, and Disclose
Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about the users of our Services. During the 12 months leading up to the effective date of this Policy, we collected all of the types of personal information described in the “Information We Collect” and “How We Use Your Information” sections of this Policy. Depending upon the types of services you use, the categories of personal information we collect are: identifiers (such as name, address, phone number, email address, IP address, social media handles, and passwords); demographic information (such as gender and age); commercial information (such as your purchase and transaction history or your virtual assets); other financial data that you provide; internet or other network or device activity (such as technical device information and a record of your use of Services); geolocation information, including precise location (e.g., GPS) with your permission; information from third-party accounts that you may use when logging in, signing up, or linking to our Services, such as your name, profile picture, other public information, and information about your social connections with your permission; user-generated content; messages you send on the Services, including when you contact us; inferences we make from other data; and other information that identifies or can be reasonably associated with you.
We collect the above categories of information from you, our service providers, our business partners, social network services, and other parties. We use these categories of information, for example, to enable us to deliver the Services; to communicate with you; to enable us to review, improve, promote and develop our Services to better serve you and the Nuverse community, including by performing analytics; to enable us to deliver you a more personalized gaming experience; to promote the Services, including by advertising on other platforms, where applicable; to promote the safety, and security, and stability of the Services, including by scanning, analyzing, and reviewing messages; to protect the rights of the Services; for legal compliance; and for other purposes, with your consent. For more detail regarding the purposes for which we use information, please see the “How We Use Your Information” section.
Depending on the circumstances, we may share any of the above categories of information we collect with: our corporate group; service providers; business partners; other parties, including government entities, when required by law or to protect our users and services; third party integration services pursuant to that service and your settings; and with your consent or in connection with a corporate transaction. In addition, we may share commercial information and financial data, including your payment information, with payment processors. See the “How We Use Your Information“ and “How We Share Your Information” sections for more information.


Other California Rights


We do not sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising or targeted advertising where restricted by applicable law. Although some of the information we collect may be considered sensitive personal information, we only process such information in order to provide the Services and within other exemptions under applicable law, such as when we process your sensitive personal information in order to perform the services or provide the goods you request from us.


Australia
Certain entities in our corporate group, located outside of Australia, are given limited remote access to your information so that they can provide certain functions, as described in the section on "How we share your information."


Brazil
If you are using the Services in Brazil, you acknowledge that you have read, understood, and agreed with the practices described in this Privacy Policy, so the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:
Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.
We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:


We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Brazilian Data Protection Authority (ANPD).
Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.
Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when it could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.
Retention of Data: We generally retain your personal information for as long as it is necessary to serve the purpose(s) for which such information was collected, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request.
If there is a legitimate interest justifying the storage, the possibility of opt-out will be offered when applicable, such as in cases involving marketing communications.
Contact: In case of doubt about your privacy, your rights or how to exercise them, please contact us by using the contact information provided in the “Contact Us” section.
DPO. If you wish to contact the Data Protection Officer, please contact us at: dpobrasil@bytedance.com
Access Logs. We keep your application access logs, under confidentiality, in a controlled and safe environment, for at least 6 months, in order to comply with legal obligations.
Language. The Policy may have been prepared in the English language and in the Portuguese language. If you are a user located in Brazil, you shall refer to the Portuguese version, which shall prevail.
Information related to younger users. By accessing the Services, you represent that you are over 13 years old.
International Transfers. International data transfers are necessary for us to provide our services. We will always rely on one of the international data transfer mechanisms under applicable data protection laws and regulations.


Canada
If you are using the Services in Canada, the following additional terms apply.
Your Rights. Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information in our custody and control and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out below. We may require certain personal information for the purpose of verifying the identity of the individual making the request.
Your Choices. You can unsubscribe from our marketing emails at any time by clicking the “unsubscribe” link included at the bottom of each email we send. You can also adjust your preferences regarding certain types of personalized advertising by using the Ads tools in Settings.
Transfer Outside Your Jurisdiction. We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec), including in the United States and Singapore, and other foreign jurisdictions where we or our service providers are located. For information about the manner in which we or our service providers (including service providers outside Canada) process personal data, please contact us using the contact information set out below.
Contact. If you are a resident of Canada, you can contact our Privacy Office using the contact information provided in the “Contact Us” section.


Egypt
If you are using the Services in Egypt, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.
You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged the Nuverse Privacy Policy and Terms of Use and agree to the use by your child of the Services and registration for an account.


India
If you are using the Services in India, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.


Grievance Officer For India. In accordance with Information Technology Act 2000 and rules framed thereunder, a Grievance Officer has been appointed and a complaint or other issue faced by a user of our platform or other issue faced may be submitted through the email provided in the “Contact Us” section.
The complaint should provide: (i) username of the relevant account holder (ii) specific content that is of concern and (iii) reason(s) for the request.


Indonesia
If you are using the Services in Indonesia, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:
Age, Parental and Guardian Consent. By accessing and/or using the Services, you represent that you are at least 21 years of age, or married, or not under guardianship. If you are below 21 years old and you are not married, or you are under guardianship:


Your Choices. You may withdraw your consent to Nuverse's disclosure of personal data to third parties. Upon your request, we will cease to display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of the Nuverse features and functionality.
You may request that Nuverse (i) disclose the history of personal data that we have collected; and/or (ii) erase and dispose of your personal data that we have collected on our server. Please note that by requesting that we erase or dispose of your personal data, you may not be able to use some of Nuverse features and functionality.
To exercise any of your rights, contact us by using the contact information provided in the “Contact Us” section.
Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.
Data Retention. We retain your information for as long as it is necessary to provide you with the Services. Where we do not need your information in order to provide the Services to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.
After you have terminated your use of our Services and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.
Language. This Privacy Policy has been prepared in the English language and Indonesian language. In the event of any inconsistency or different interpretation between the English text and Indonesian text, the English text shall prevail and the relevant Indonesian text shall be deemed to be automatically amended to conform with and to make the relevant Indonesian text consistent with the relevant English text. You acknowledge and agree that (i) you have read this Privacy Policy and understands the content of this Privacy Policy; (ii) you enter into this Privacy Policy freely and without duress, and (iii) you will not use the provisions under Law of the Republic of Indonesia No. 24 of 2009 on Flag, Language, State Emblem and National Anthem or any of its implementing regulations to invalidate this Privacy Policy.


Israel
If you are using the Services in Israel, the following additional terms apply. Your continued access to or use of the Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.
You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged this Privacy Policy and Terms of Use and agree to the use by your child of the Services and registration for an account.


Argentina
If you are using the Services in Argentina, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.
Your rights and options. According to Law No. 25,326, Regulatory Decree No. 1558/2001 and the provisions and/or binding resolutions issued by the Agency for Access to Public Information ("AAIP"), you have the following rights with respect to your personal data: access, rectification and deletion regarding data protection. If you have questions about your privacy, your rights, or how to exercise them, please contact us using the information in the "Contact Us" section. If you have any questions about the processing of your personal data, we would like to clarify them.
We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the AAIP. You can contact AAIP through the site: https://www.argentina.gob.ar/aaip/datospersonales/derechos.

Mexico
If you use our services in Mexico, the following additional terms apply. In the event of a conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.
Data Controller. Nuverse (Hong Kong) Limited, whose registered address is at Unit 1003, 10/F., Tower 2, Silvercord, 30 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong.
How we use your personal data. Almost all of the purposes of the processing data indicated above in the main section of this Privacy Policy are necessary purposes. However, the following are secondary purposes:

The above purposes are not necessary to provide the Services, but allow us to provide you with a better experience. We offer you the ability to make choices about how we use and disclose your personal data. You may be able to limit the secondary purposes of personalized advertising by using the tools available to you in the Settings that allow you to limit certain features.
We use both human and automated means to process your data.
How we share your personal data. We may share your personal data with a third party for purposes other than processing on our behalf. We will obtain your consent to such disclosure as required by applicable laws.
By providing us with your personal data and using our Services, you agree to transfers that require your consent. You can always revoke your consent and exercise your rights as outlined below.
Language. The Policy may have been prepared in the English language and in the Spanish language. If you are a user located in Mexico, you shall refer to the Spanish version, which shall prevail.
Your Rights. You have the following rights with respect to your personal data: access, rectification, cancellation, objection, consent withdrawal, limitation of use and disclosure of your data. You may exercise your rights by sending your request to the contact information listed in the "Contact Us" section. To learn about the applicable requirements and the procedure for exercising your rights, please contact us at the contact information listed in the "Contact Us" section. If you are under 18 years of age, you may exercise your rights through a parent or guardian. Requests to exercise for your rights will be resolved as soon as possible according to the applicable data protection law and the nature of your request.
Information relating to minors. You may review more information on parental consent in the Terms of Service.


Philippines
If you are using the Aervices in the Philippines, the following additional terms apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.
Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Russia
If you are using our services in Russia, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.
What are legal grounds for data processing. When we process your personal data, we rely on your consent, performance of a contract, our legitimate interest and obligations to process personal data, when required by law.
By signing up and using the Services, you consent to the processing of personal data in accordance with this Privacy Policy.
Where we store your personal data. Your personal data may be transferred from Russia to the United States or Singapore and stored in that location, outside of the country where you live.

South Africa
If you are using the Services in South Africa, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.
You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged the Nuverse Privacy Policy and Terms of Use and agree to the use by your child of the Services and registration for an account.

South Korea
If you are using the Services in Korea, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Act on Consumer Protection in Electronic Commerce

Protection of Communications Secrets Act

Türkiye
If you are using our services in Türkiye, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated policy. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.
Legal bases for processing your personal data. Nuverse relies on the following legal bases while processing your personal data in accordance with Article 5 of the Law No. 6698 on Protection of Personal Data:

Your rights. According to Article 11 of the Data Protection Law, you have the following rights with respect to your personal data:

You may exercise your rights listed above by contacting us by using the contact information provided in the “Contact Us” section.
The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest free of charge. However, if your request incurs additional cost to our company, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.


United Arab Emirates
If you are using our services in the UAE, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:
How we share your personal data
In addition to the main text of this policy, by using the Services in the UAE you agree to the terms of this Privacy Policy and consent to our sharing of your personal data in line with the main text of this Privacy Policy.
Governing law and dispute resolution
By using our Services in the UAE, this Privacy Policy will be governed by and interpreted in accordance with the laws of the UAE. In the event of a dispute arising between the parties in connection with this Privacy Policy:


Vietnam
If you are using our services in Vietnam, the following additional terms apply. Your continued access to or use of the Services after the date of the updated Privacy Policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services. If any conflict arises between the main Privacy Policy and the additional terms, the following terms shall prevail:
Age, Parental and Guardian Consent. By accessing and/or using these Services, you represent that you are at least 16 years of age or not under guardianship. If you are below 16 years old or under guardianship:

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must cease accessing the Services.
Language. This policy has been prepared in the English language and Vietnamese. In the event of any inconsistency or different interpretation between the English text and Vietnamese text, the English text shall prevail and the relevant Vietnamese text shall be deemed to be automatically amended to conform with and to make the relevant Vietnamese text consistent with the relevant English text.