隐私政策
Last updated: 15 December 2025
1. What does this notice cover?
This policy describes how Virtuos Holdings Pte. Ltd. and its affiliates (“Virtuos“, “we“, “us” or “our“) will make use of your data when you use our website/services and/or provide us with your personal data in any other way, for example through phone calls, business cards or visiting our office.
It also describes your data protection rights, including the right to object to some of the processing which Virtuos carries out. More information about your rights, and how to exercise them, is set out in the “Your choices and rights” section.
2. Personal data we may collect about you
We collect and process personal data about you when you interact with us and our websites or use our services. This includes:
| Category | Details |
|---|---|
| Contact Information | Your name, company name, email address and phone number |
| Marketing Information | Your marketing preferences, including any consents you have given us |
| Device Information | Information related to the browser or device you use to access our website |
Sometimes, we receive information about you from third parties. In particular social media platforms and business partners.
3. How do we use this information, and what is the legal basis for this use?
In certain jurisdictions, we have to have a legal basis to process your data. We explain each of these legal bases below. We also set out the purposes for which we process your data.
| Purpose | Legal Basis |
|---|---|
| We will collect, use and store your Contact Information to provide you with our services at your request. | It is necessary for us to process your personal data in order to perform our contract with you, or to take steps at your request prior to entering into a contract with you. |
| We will collect, use and store your Contact Information to manage our relationship with you. | We have a legitimate interest in managing our business and providing services to our clients. |
| We will collect and use your Contact Information and Marketing Information to send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners. | Your consent. |
| We will collect and analyse your Contact Information and Device Information in order to manage and operate our website, including to keep it updated and relevant, to develop our business and to inform our marketing strategy. | Your consent. |
There are instances where we have a legitimate interest to use your data. Our legitimate interest will vary depending on what we are using your data for, and we explain above what the interest is and how it relates to the processing operations that we are carrying out. Where we process personal data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals interests outweigh our interests in the processing taking place.
You can obtain more information about this balancing test by using the contact details at the end of the notice.
For further information on our use of cookies, please consult our Cookie Notice https://www.virtuosgames.com/cookies-notice/.
4. How we share your personal data
We may share your data with the following categories of recipients:
| Personal Data Category | Category of Recipient | Why? |
|---|---|---|
| Contact Information | Virtuos group companies | To operate, improve, and develop our services |
Your personal data also will be shared with government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.
In the event that a Virtuos business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
5. Where we transfer your personal data
Virtuos operates globally, which means your information may be stored and processed outside of the country or region where it was originally collected.
As a Singaporean headquartered company, most of our IT systems are hosted in Singapore and all of the information listed in [section 2] above is hosted in Singapore.
Where your personal data is to be transferred out of a country (e.g., Singapore), we will comply with the applicable privacy laws (e.g., Singapore’s Personal Data Protection Act (the “PDPA”)) in doing so.
In this regard, this includes us obtaining your consent unless an exception under applicable law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the applicable law (e.g., the PDPA). This may include us entering into an appropriate contract/legal instrument with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the applicable law permits us to.
Where personal information of EU data subjects is transferred outside the EEA, and where this is to an affiliate or vendor in a country that is not subject to an adequacy decision by a relevant body such as the European Commission (read more here), data is adequately protected by approved standard contractual clauses such as those approved by the European Commission (read more here) or a vendor’s Binding Corporate Rules (read more here).
A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.
6. Your choices and rights
In certain jurisdictions, you have the right to ask Virtuos for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Virtuos processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority in the country that you reside in or, the country of your place of work or the country where the alleged infringement took place.
In certain non-EU jurisdictions, we may also charge you a reasonable fee for the handling and processing of your requests in accordance with applicable laws and you will be notified in advance of such costs.
To the extent permitted by applicable law, please note that we are not required to respond to or deal with your request unless you have agreed to pay the fee.
Where we collect personal data to administer a contract with you or to comply with our legal obligations, this is mandatory and we will not be able to provide you with our services without this information.
In all other cases, provision of the requested personal data is optional.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.
If you wish to exercise any of these rights, please contact us at the contact details set out below.
7. How long we retain your personal data
Where you are a customer, Virtuos will keep your information for the duration of any contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this notice. For data about your visits to our websites or applications, Virtuos will retain this for as long as is reasonably necessary for the relevant purpose.
Further, applicable laws may require Virtuos to hold certain information for specific periods.
In other cases, Virtuos may retain data for an appropriate period after any relationship with you ends to protect itself from legal claims, or to administer its business.
For more information on our retention periods, please contact us via the contact details included below.
8. Updates to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
9. Contact us
If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact our Privacy Office/Data Protection Officer at privacy@virtuosgames.com.
