Privacy Policy

Introduction

• NSPhere’s reference in this Privacy Policy means Neurasphere Technology Company Limited, affiliates of Neurasphere Technology Company Limited, group companies and subsidiaries of Neurasphere Technology Company Limited, including Representatives of Neurasphere Technology Company Limited, namely financial, insurance, legal, accounting advisors, or other NSPhere’s advisors who provide professional services to NSPhere, and third parties that work with Neurasphere Technology Company Limited, namely partners, vendors, and subcontractors

• This Privacy Policy is an integral part and is an integral part of the Terms and Conditions [nsphere.store Products] (insert link). Capitalized terms used in this Privacy Policy have the same meanings as those contained in the [nsphere.store Products] Terms and Conditions.

• NSPhere has the right to update this Privacy Policy from time to time to keep it relevant and up-to-date with changing technology, applicable laws, evolving NSPhere business practices and the needs of NSPhere’s User. If any changes are made to this Privacy Policy, NSPhere will provide a “Last Updated Date”. NSPhere urges NSPhere’s User to periodically review this Privacy Policy in order to stay informed about how NSPhere manages your data and personal information. By using the Services, User is deemed to have given explicit consent to the Privacy Policy and by continuing to use the Services after the Privacy Policy, User is deemed to have read, understood and agreed to the updated Privacy Policy.

• THIS PRIVACY POLICY IS A FORM OF A BINDING AGREEMENT BETWEEN THE USER AND NSPhere’S USER KNOWLEDGELY AND VOLUNTARY AGREE TO THESE TERMS TO USE THE SERVICES ON THE NSPhere PLATFORM.

Applicable laws and regulations

• NSPhere is subject to all applicable laws and regulations and policies of the government of the The Kingdom of Thailand, including those that regulate electronic information and transactions, electronic system operations, and protection of User's personal data; including all implementing regulations and changes to these regulations that regulate and protect the use of important data and information of User.

Data Retrieval and Protection

NSPhere has the right to request User data and information, including the following:

• Information regarding NSPhere’s account:

1、Name
2、Username
3、E-mail
4、Telephone Number
5、Address and/or location
6、Profile, including date of birth, gender
7、Photo ID and Selfie (Selfie)
8、Transaction, Financial, and/or Banking Information

• User’s behavior in NSPhere Platform and/or while using Information Services, product selection, features, and services:

1、Information on User preferences and interests
2、User experience information
3、Photo and media information on User's device
4、QR Code scanning information
5、Geo location information in real time
6、Information on survey results sent by Gaming or on behalf of Gaming
7、User track records (logs) which include but are not limited to the device IP address, date and time of access, application features, website views viewed, application work processes and other system activities, type of web browser, and/or site or service sites from third parties that are used before interacting with the site
8、User's other information which includes other things

• Information from third parties:

1、Personal Information originating from third parties that work with NSPhere such as vendors, agents, professional advisors, consultants and other parties may be collected by us in connection with the purpose of the third-party engagement.
2、NSPhere may receive information about User from Third Parties as long as the third-parties have obtained the User's consent to provide the required (relevant) information, for example, delivery information and addresses from NSPhere operators, which NSPhere uses to correct the NSPhere records and deliver subsequent purchases. to make it easier.

By providing the information in letters a to c above, User waives the right to claims, losses, demands, and claims that may occur for the acquisition, storage, use, utilization, and/or disclosure of information, including personal information, in the NSPhere System.

• User hereby gives explicit consent to NSPhere to obtain, collect, process, analyze, store, display, use, utilize, publish, transmit, disclose, disseminate, delete and destroy the personal data and information that the User submits (input) into NSPhere System, including the User's personal data, product photos, chat and conversation in the NSPhere system and the User hereby declares that the approval of such personal data and information is carried out without coercion, in a capable condition, and with a conscious state, where the consent is given by the User when create a NSPhere account (“User’s Consent”).

• Upon User's Consent, User hereby declares that all such data and information is the property of NSPhere. For the avoidance of doubt, the User's personal data, whether entered into the NSPhere Platform or not entered into the NSPhere Platform, belongs to the User as part of the complete personal rights.

• User hereby declares that the personal data that the User submits (input) into the NSPhere System (including documents uploaded and/or provided to NSPhere) is original, authentic, true, accurate, complete, not misleading, up-to-date, and is a personal right Users and/or themselves are authorized to submit User's personal data to submit it to the NSPhere System.

• NSPhere protects all information provided by User when User uses all of the NSPhere Services, including maintaining the confidentiality, integrity, and availability of the personal data which it managed.

• NSPhere has the right from time to time to request authentication and updating of User's personal data, so that User's data and information are accurate, complete, and up-to-date, including temporarily discontinuing the Services and/or discontinuing the Services, in the event that the User has not authenticated and updated the User's personal data.

• User has the right from time to time to update the User's personal data.

• User hereby understands that the use of certain features in NSPhere requires further authentication of personal data and is subject to the NSPhere’s Terms of Use and the terms and conditions of certain features in NSPhere. User hereby confirms that the User’s Consent is an explicit consent to the acquisition, storage, use, utilization, and/or disclosure of the personal data that the User submits (input) into the NSPhere System and certain features in the said NSPhere, and states that the provision of the use of the personal data is carried out. without coercion, in a capable state, and with a conscious state

• User releases NSPhere from all claims, lawsuits, losses, and/or claims in connection with the failure of transaction processing on the NSPhere application caused by inaccuracies/inadequacy of Personal Data information that the User provides to NSPhere.

Use, Storage, Utilization, and Processing of Data

1、NSPhere will collect, use, store, utilize, process, analyze, transmit and disclose User's personal data for the following purposes and other purposes permitted by applicable laws and regulations:

• Services Process and Product transactions. With the aim of, among others, to (i) receive, process and verify the selection, order, purchase, payment, return, transfer, exchange of Products, (ii) know-your-customer (“KYC”) purposes, (iii) internal data processing ( iv) communicating with User regarding orders, data verification, products and services, as well as promotional offers, (v) monitoring and knowing User transaction patterns, (vi) billing, activation, provision, maintenance, support, troubleshooting, deactivation, replacement, upgrades or Services updates (vii) administrative purposes (viii) processing all forms of User activities including but not limited to processing transactions, payment verification, product delivery, use of services, (ix) managing or responding to User inquiries, (x) using bank name information which includes the name and account number to ensure payment/receipt by the User, (xi) to fulfill or enforce the notification applies to the Service.

• Providing, troubleshooting, and improving NSPhere Services. NSPhere uses User's Personal Data to (i) provide functionality, analyze performance, correct errors, and improve the usability and effectiveness of the Services, (ii) to ensure the Services is technically functioning as intended and to help identify and solve problems.

• Recommendations and Personalization. NSPhere uses User’s Personal Data to recommend features, products and services that may be of interest to User, to better understand, analyze and predict User preferences and interests, combine such information with other information to customize User experience, and personalize User experience with the Services.

• Provides image and camera services. When User uses the User's image and camera services, NSPhere uses the images, videos, and other personal data to respond to the User's request, provide the requested service to the User, and improve the NSPhere Services.

• Comply with legal obligations. In certain cases, NSPhere collects and uses User’s Personal Data to comply with laws, regulations and respond to emergency situations. For example (i) NSPhere collects from Users information regarding bank account information for identity verification and other purposes, (ii) to respond to court orders, subpoenas or other lawful requests or other legal or law enforcement processes, (iii) official requests or orders of authorities, authorized officers or institutions based on applicable legal provisions, including but not limited to disputes, investigations, legal processes and dispute resolution processes between NSPhere and User, User and other User, and User with other parties as well as other illegal activities, (iv) ) requests by banking institutions, financial institutions or non-financial institutions authorized, and/or third parties based on official requests and applicable legal provisions, (v) to provide emergency assistance, emergencies, in situations that can threaten life, health or safety physical User or other person.

• Communication with User. NSPhere uses the User's Personal Data to communicate with the User in connection with the Services through different channels (e.g., by phone, email, chat).

• Advertising, promotion and personalization. NSPhere uses User's Personal Data to (i) display or conduct interest-based advertising and promotional activities for features, products and services that may be of interest to User which include but are not limited to advertising identifiers, including those provided by other software platforms, or similar identifiers, to facilitate NSPhere in conducting analytics or providing promotional content or other information that may be relevant and interesting to User, (ii) to facilitate User access and use of the Services and/or third party offers; (iii) to send subscription offers, messages, news and posts within the Services on behalf of NSPhere.

• Prevention of fraud and money laundering and credit risk. NSPhere uses User's Personal Data to prevent and detect fraud as well as money laundering and abuse to protect the security of User, NSPhere, and others. NSPhere may also use assessment methods to assess and manage credit risk.

• Developing Services. NSPhere uses User's Personal Data to develop new Services and improve existing Services and provide User with information about third party content or related Product, Services and software including to communicate with User about the various means they use, for example to provide or send to User: (i) upgrades or updates, or notifications about upgrades or updates of the Services or third party content or related products, services and software; (ii) notifications of upcoming promotions, contests, offers and events; (iii) personal information, surveys, marketing materials, advertising or customized content. Also for the purpose of (i) detecting, monitoring, investigating, mitigating or preventing fraud and technical or security issues or to protect the property of NSPhere; (ii) enable business continuity and disaster recovery operations; (iii) obtain legal services, to seek legal advice and/or to enforce the legal rights of Gaming or the legal rights of other members of NSPhere; (iv) for statistical purposes; (v) business development, products, quality, and services including promotional activities, studies, research, and cooperation with other third parties.

• When it is necessary for a clear purpose for the benefit of the User and User’s Consent cannot be obtained in a timely manner.

• Other purposes that are communicated from time to time by NSPhere to User, as well as required, permitted or required by applicable laws and regulations.

2、NSPhere may cooperate with other companies and third parties that facilitate or provide assistance in the development of certain Services for and/or on behalf of NSPhere, including:

• Provide User assistance;

• Carry out services related to the Platform (including but not limited to maintenance Services, database management, analysis and improvement of Platform features;

• Assist NSPhere in analyzing how the Platform Services are used and how they are developed;

• To assist NSPhere's professional advisors and external auditors, including legal counsel, financial advisors and consultants. These third parties only have access to User Data to perform such tasks for and/or on behalf of NSPhere and are contractually bound not to disclose or use such Personal Information for any other purpose.

3、In disclosing information, NSPhere may inform some of the User Data so that the information becomes information that cannot identify the User as a whole (aggregate data/anonymous data) which is intended for third parties that are used for Platform development, database management, analysis or service improvement, promotion and advertising.

4、NSPhere can also combine User Data with other information in such a way that the information is no longer associated with the User, then disclose the combined information to third parties, for the purposes as referred to in point 3.

5、For the purpose of developing, improving, perfecting, protecting, and maintaining Platform products and/or Services, NSPhere is sometimes required to process, utilize, display, disclose, publish, transmit, transfer, and/or disseminate Personal Data to third parties. For the avoidance of doubt, the third parties referred to in this paragraph may, including but not limited to:

• Third parties who are in the group of companies, subsidiaries, affiliates, partners, partners and NSPhere’s vendors for or in connection with purposes related to the provision of the Platform, business management, service delivery, data management and other activities;

• NSPhere’s interest, NSPhere’s affiliates, group companies and subsidiaries, for business development, products, quality, and services including promotional activities, studies, research, and cooperation with other third parties;

• NSPhere's interest in fulfilling the transaction's objectives, including the sale of all or part of NSPhere's assets including any purchase, sale, lease, merger or acquisition, disposal or financing of NSPhere, NSPhere affiliates and group companies;

• Third Party if there is a company transaction, such as: formation of a joint venture, restructuring, reorganization, sale of subsidiaries or divisions, merger, acquisition, consolidation, takeover, sale of assets, or liquidation;

• Third parties in relation to service providers employed by NSPhere to perform functions on behalf of NSPhere. Examples include removing repetitive information from User lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing payments, submitting content, rating, assessing and managing credit risk, and providing User services, where applicable. These third-party service providers have access to the Personal Data necessary to perform their functions, but may not use it for any other purpose; and

• Other Third Parties (including agents, vendors, suppliers, contractors, third parties who provide services to NSPhere or User, performing tasks on behalf of NSPhere’s name that enter into commercial partnerships with NSPhere) for or in connection with NSPhere purposes involving third parties or the purposes of NSPhere partnerships with third parties (depending on the circumstances), which may include allowing third parties to introduce or offer products or services to Users or carry out other activities including marketing, research, analysis and development of such third party products (depending on the circumstances).

6、In connection with the application of widgets or content from within the application and/or NSPhere Platform, NSPhere hereby declares that third parties will and may submit, submit and/or provide User’s Personal Data to other parties in cooperation with (relevant) third parties. In this case, other parties who receive User's Personal Data will be subject to obligations related to the transmission and use of the same data that applies to NSPhere’s third parties.

7、NSPhere has the right to store User's personal data and information to fulfill the purposes of the Services, the purposes of this Privacy Policy, the purposes of applicable laws and regulations, including processing, transferring, and/or storing User’s data and information, both within the The Kingdom of Thailand. Thailand and outside the territory of the The Kingdom of Thailand, with due observance of regulations, including laws and regulations and privacy policies in the countries where data and information of Users are processed, transferred, and/or stored.

8、NSPhere strives to protect the security of User's Personal Data during transmission by using encryption protocols and software and NSPhere ensures that Personal Data collected and/or collected by NSPhere will be stored securely in accordance with applicable laws and regulations in the The Kingdom of Thailand. User understands and agrees that NSPhere will maintain physical, electronic, and procedural safeguards in relation to the collection, storage and disclosure of User's Personal Data. User agrees that NSPhere will retain Personal Data for as long as necessary to fulfill the purposes described in this Privacy Policy.

9、Platform may contain links to third party sites. NSPhere is not responsible for the acquisition, collection, processing, analysis, use, storage, display, announcement, transmission, dissemination, deletion and destruction of User's Personal Data by such third parties. If User provides information directly to the site, then the privacy policy and terms of service on the site will apply, so that all consequences of such actions are entirely the responsibility of the User.

10、NSPhere, affiliates, group companies, and subsidiaries, including representatives of NSPhere, and third parties that work with NSPhere, in providing the Services have the right to utilize and process User's personal data and information to fulfill the purposes of this Privacy Policy, regulatory purposes applicable laws and regulations. The use and processing of such data is covered by the agreement and contains a confidentiality clause that binds the parties. In this case, including representatives of NSPhere.

11、NSPhere may transfer User's Personal Data information to affiliate platforms or NSPhere service providers or to third party recipients. Therefore, by agreeing to this Privacy Policy, User also gives consent to transfer Personal Data information to affiliate platforms or NSPhere service providers or to third party data recipients for the development of services of a technical, commercial nature and others. Wherever a User's Personal Data information is transferred, stored or processed by NSPhere or its affiliated platforms or third parties, or any other party providing NSPhere services, NSPhere will take reasonable steps to protect the privacy of the User's Personal Data Information.

Data Storage

• User data and information on the Platform will be stored as long as it is still used for the purposes referred to in this Privacy Policy and as required by applicable laws. NSPhere will stop storing User data and information immediately if NSPhere considers that the data that NSPhere has collected is no longer suitable for the purpose of data collection, storage of such data is no longer required, is not permitted to be stored or is required to be deleted by applicable law.

Data Deletion

1、For various information on the latest promos and exclusive offers, User can:

• unsubscribe if you do not wish to receive such information by clicking the “unsubscribe” link via e-mail sent by NSPhere to the User; or

• setting the 'Promo' notification on the NSPhere application.

2、User can withdraw the User’s Consent provided related to the use of User's personal data and information, including stopping using, accessing the Services, and/or closing the account with due observance of the provisions of the applicable laws and regulations (including the retention provisions required by applicable laws and regulations). User hereby declares that User understands the consequences of withdrawing the User’s Consent, including but not limited to no longer being able to enjoy the Services.

3、Subject to the prevailing laws and regulations, User may apply for the data deletion to NSPhere through the NSPhere Customer Care by attaching:

• data deletion request form provided by NSPhere;

• valid proof of self (KTP/SIM/PASSPORT) in accordance with his/her personal identity on the NSPhere Account page; and

• reason for the deletion request.

4、User must understands first and agree to the Terms and Conditions of Account Deletion.

5、NSPhere agrees to delete the data submitted by User if it has complied with the provisions in item 3 above and has fulfilled its rights and obligations at NSPhere within a reasonable time.

6、NSPhere, by User's request, may collect User data and information which made unrecognizable.

7、NSPhere has the right to keep the User's data during the retention period that has been determined by NSPhere on the NSPhere system in accordance with the legislation.

8、NSPhere has the right to refuse a User's request to access and/or change or delete a User's Personal Data for reasons that are justified under the applicable laws and regulations.

9、Data deletion and data storage will be carried out by NSPhere in accordance with the provisions of the applicable laws and regulations.

Limitation of NSPhere's Liability

1、User is responsible for the security and mitigation of violations of the User's own NSPhere Account, such as maintaining the confidentiality of the User's Personal Data, implementing appropriate security, restricting access, creating a strong password and/or PIN (personal identification number), maintaining passwords and / or the PIN that the User creates and uses to access the User's Personal Data wherever the User stores Personal Data, maintaining a one-time password (“OTP”).

2、User is responsible for all misuse of the password and/or PIN (whether committed by the User and/or a third party) or misuse of the Platform, which is created and used by the User or a third party who obtains the word on the Platform and/or a third-party platform. affiliated with the User to access the User's Personal Data including Account, password and/or PIN to access or login to the User's application by parties other than the User and such misuse is not the responsibility of NSPhere.

3、User is required to immediately notify NSPhere if User believes that the password and/or PIN of the NSPhere Platform and/or third party platforms affiliated with NSPhere to access the Platform are misused by other parties who are not responsible and/or authorized.

4、NSPhere is not responsible for the exchange and provision of User's personal data and information which is carried out by the User himself, including that carried out between User. Included in this provision are any and all User errors that result in User data leakage.

5、NSPhere Platform is responsible for the protection and security of confidential personal data, including notifying User in the event of a failure in personal data protection through at least an e-mail of User who are registered on the NSPhere Platform and report to law enforcement officials or authorities related. In the event of a data leak, the party responsible for informing the User regarding the failure in data protection is the party or institution where the data is processed under this Privacy Policy.

6、NSPhere is not responsible for the authenticity, authenticity, correctness, accuracy, completeness of personal data entered by the User into the NSPhere Platform.

7、By giving User’s Consent, User waives the right to claims, losses, demands and lawsuits that may occur on the acquisition, storage, use, utilization and/or disclosure of data, including personal data, in the NSPhere Platform.

8、In the event that the User is a minor, NSPhere is not responsible for the input of the User's personal data and recommends that the parent/guardian of the child monitor the child's internet usage, so that the provision of the User's personal data is provided and/or under the supervision of the parent/guardian as the party responsible for authorized.

9、NSPhere cannot be held responsible for data leakage caused by a cause that is beyond the ability or control of NSPhere (“Force Majeure”). What is meant by Force Majeure includes but is not limited to, among others (i) mass labor strikes, company closures, and other industrial actions; (ii) riots, demonstrations, riots, invasions, seizures of power, sabotage, embargoes, drastic political/economic changes, terrorist attacks or threats, war (whether declared or not) or threats of preparation for war; (iii) earthquakes, cyclones, landslides, floods, fires, explosions, storms, other natural disasters, epidemics or pandemics which are confirmed or not confirmed by a statement from the competent authority in that regard, as well as the promulgation of laws and regulations new ones that directly or indirectly affect the implementation of the Privacy Policy, which results in the non-performance of the obligations of a party in this Privacy Policy; (iv) unavailability or disruption of the use of the delivery network (including transportation routes); (v) unavailability or disruption of telecommunications networks, information systems and technology, shutdown or unavailability of extensive internet networks, or being struck by lightning; (vi) there are system failures caused by third parties that occur outside the authority of NSPhere (eg hacking (hacking) systems by third parties and/or viruses); (vii) non-functioning banking system and/or network; (viii) actions, decisions, laws, regulations or restrictions issued by the government regarding the implementation of the Privacy Policy; and (ix) changes to economic and financial conditions, as well as restrictions imposed by regulatory authorities regarding the use of the Privacy Policy.

Cookies

• Cookies are small data storage places on a computer or other device such as a smart phone or tablet, when the User browses and/or visits NSPhere Platform.

• User's computer or other device will automatically accept Cookies when the User browses and/or visits NSPhere Platform and when the User uses the NSPhere Services (Use of Cookies). However, the User can choose to make modifications or choose to refuse the Use of Cookies through the User's web browser settings preferences.

• NSPhere uses Google Analytics (Features), where data obtained from the use of these Features includes, User's IP address, User's device type, and others (Data). The data is used by NSPhere for Platform development and NSPhere’s Content as well as advertising. User can choose not to be accessed by the Features by downloading the Google Analytics Opt-Out Add-on on the User's web browser.

• NSPhere may provide User data and information derived from the use of Cookies to 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 data and information are not personally identifiable.

• User can control the use of cookies through the preferences of the User's web browser settings, namely by modifying or choosing to refuse the use of cookies. However, by making these settings, service performance when accessing NSPhere Platform may be affected, such as certain functions and pages on the NSPhere Platform cannot work optimally for services to User.

Intellectual Property Rights

• All works contained in the Services or Platform and its support system including but not limited to: (a) the layout, design and appearance of the Services or Platform contained or displayed on the NSPhere media; (b) logos, photos, images, names, brands, words, letters, numbers, text, and color arrangements found on the Services or Platform; and (c) the combination of elements as referred to in letter (a) and (b), fully constitutes the Intellectual Property Rights of NSPhere and no other party also owns the rights to the Services or NSPhere Platform.

• User is not allowed from time to time to:

1、copy, modify, adapt, translate, create derivative works from, distribute, sell, transfer, publicly display, reproduce, transmit, transfer, broadcast, describe or disassemble any part of or otherwise exploit the Platform (including support systems and facilities therein) which are licensed to User, except as permitted in this Privacy Policy;

2、license, sublicense, sell, resell, transfer, transfer, distribute or commercially exploit or otherwise provide software and/or software to third parties in any way;

3、publish, distribute or reproduce in any way any copyrighted material, trademarks or other information of NSPhere without obtaining the prior approval of the property rights of NSPhere or the rights owner who licensed the rights to NSPhere;

4、remove any copyright, trademark, or other proprietary notices contained in the NSPhere Services;

5、reengineer a NSPhere application or access and/or support system to (i) build a product or service counter, (ii) build a product or service using a similar idea, feature, function or graphic, or (iii) a copy of an idea, feature, function or graphics;

6、launch automated programs or scripts, including, but not limited to, web crawlers, web robots, web indexers, bots, viruses, worms or other similar applications and any program that can make multiple server requests per second, create heavy loads, or hinder the operation and/or performance of the Platform;

7、use robots, spiders, site search/retrieval applications, or other manual or automated processes to retrieve, index, 'data mine', or in any way reproduce or circumvent the navigational structure or presentation of NSPhere application and its content.

Privacy Policy Changes

• NSPhere has the right to update and/or change the Privacy Policy from time to time if necessary for the security and convenience of User transactions on the NSPhere Platform without prior notice. User hereby agrees that User is responsible for carefully reading and checking this Privacy Policy from time to time for any updates and/or changes. By continuing to access and use the services on the NSPhere Platform, User is deemed to have agreed to updates and/or changes in this Privacy Policy.