VIRTUOS WEBSITE PRIVACY NOTICE

Last updated: 17 July 2026

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

Wecollect 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.

 

Or if permitted by law, where we have a legitimate interest in promoting our services to our clients.

 

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.

 

Or if permitted by law, where we have a legitimate interest in operating our site and improving its operation.


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.volmigames.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 at privacy@virtuosgames.com.



U.S. Privacy Disclosures and State Law Addendum

This set of U.S. Privacy Disclosures and State Law Addendum (the “U.S. Addendum”) supplements the Privacy Policy and applies solely to personal information relating to individuals located in the United States. In the event of a conflict between this U.S. Addendum and the main Privacy Policy, this U.S. Addendum controls with respect to U.S. residents. Virtuos complies with all applicable United States federal and state privacy and data protection laws, including, without limitation, the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”) and other comprehensive U.S. state privacy laws, to the extent applicable.
Except where expressly stated otherwise, Virtuos acts solely as a service provider or processor in the United States. It does not sell personal information or share personal information for cross‑context behavioral advertising.
1. Consumer Privacy Rights Under U.S. Law
Residents of certain U.S. states are afforded specific rights with respect to their personal information under applicable privacy and data protection laws. Subject to applicable law, these rights may include:
• Right to Know or Access
• Right to Correction
• Right to Deletion
• Right to Data Portability
• Right to Limit Use of Sensitive Personal Information
• Right to Non‑Discrimination
• Right to appeal controller decisions
• Right to request list of sub- processors


2. Data Retention
In our role as service provider, we retain personal information only for as long as necessary to perform services, comply with legal obligations, or as otherwise permitted by law. Upon termination of services, personal information is deleted, de‑identified, or returned in accordance with contractual obligations.
We retain information about you only for as long as necessary to provide our Services, maintain our website, comply with applicable law, and contractual obligations. We may retain your personal information, posts, and service records for as long as you are a customer to provide you with the Services.
After it is no longer necessary for us to retain information about you, we will dispose of your information in a secure manner or anonymize the information.
Aggregated data is retained and used by Company for analysis, product improvement, and troubleshooting purposes. In some cases, social media content may continue to exist on the Social Networks even after you or we delete it from our Services, and you will need to contact the relevant Social Network directly if you would like to remove this content.
3. How We Collect Information
The Privacy Policy applies to information we collect:
  • on the Site;
  • through mail, in e-mail and other electronic messages between you and the Site; or
  • through mobile and desktop applications, and forms you download from the Site;
  • in person;
  • through our job application and granting process; and
  • with your consent through our surveys.
4. Types of Personal Information we Collect
We collect the following categories of personal information from users of our Site and Services:
Identifiers: Such as your name, email address, IP address, or other similar identifiers that may be linked to you or your devices.
Internet Activity: Information related to your browsing history, search history, and interactions with our Service.
User Content: Any messages, comments, or other content that you submit, post, or otherwise transmit using our Service.
Geolocation Data: We may collect or process Information about your physical location by recording the US postal zip code at your location or residence.
5. How We Use Your Information
We use your personal information for the following purposes:
To operate, maintain, improve, and enhance our Service.
To send you information, status updates, notices, and other information related to the Service, including billing and account information.
To present the information on the Site and their contents to you;
To provide you with information about our Services that you request from us;
To conduct our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection;
To notify you about changes to the Site or any Services we offer or provide though it;
To allow you to participate in interactive features on the Site;
For any other purpose, such as surveys, with your consent.
Security: To protect the security and integrity of our Service and to prevent fraud or other malicious activity.
Legal Compliance: To comply with our legal obligations, enforce our terms of service, and address disputes we may need to provide your information to law enforcement agencies upon submission of a subpoena, or other lawful process. Depending on the nature of the request, we may not be able to advise you that law enforcement agencies are requesting such information.
Do Not Sell: We keep your personal information private and do not sell it to other entities.
At any time, you can request the removal or modification of your personally identifiable information or opt-out of receiving email communications from us by sending an e-mail to us. You can also opt-out of receiving email communications from us by clicking on the “unsubscribe” link in our emails. We will make a reasonable effort to accommodate your requests.
6. Changes to the Privacy Policy
We may update the Privacy Policy from time to time by posting modifications to the Privacy Policy at the Site. By using the Site following such changes, you agree to be bound by such changes. Please check the Site periodically to familiarize yourself with any changes that may have been made to the Privacy Policy. You can determine when the Privacy Policy was last changed by checking the “Last Updated” reference above.
7. Children Under the Age of 13
We do not knowingly collect or solicit personal information from children under 13.
8. Our Use of Cookies, Third Party Links, and Other Tracking Mechanisms
We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Site. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
  • Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity after you have logged in, as you move through our Site and Services.
  • Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Third-Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site, and Services. We use these tools to help us improve our Site’s and Services’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons, session replay, or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/.
You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Ad Networks. Users in the United States may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on a consumer choice website, your opt out may not be effective.
9. Global Privacy Control and Universal Opt‑Out Signals
We recognize and honor browser‑based privacy preference signals, including the Global Privacy Control (“GPC”). The GPC is a setting available in certain web browsers and browser extensions that allows users to automatically communicate their preference to opt out of certain data processing activities, such as the sale or sharing of personal information.
When we receive a GPC signal from your browser or device, we treat it as a valid request to opt out of the sale or sharing of your personal information, to the extent required by applicable law. This means that, where required, we will limit the use of your personal information for purposes such as cross‑context behavioral advertising or similar activities.
You do not need to take any additional action to submit this request. The GPC signal is automatically transmitted by your browser when it is enabled.
10. Use of De-identified Data
We may use de-identified data, which cannot be linked to you or individuals using our services for the purposes of providing Services, product development, employee training, research and development and to gain insights on product improvement and other operational purposes that enhance our Services and your experiences with us. We take reasonable measures to ensure that our process of de- identifying information about you, and your use of the services cannot be associated or linked to you. When we share de-identified data with our service providers, partners or other third parties, we enter contracts that restrict the use of the data and the identification of the data to you and other users of our services.
11. Disclosure of Your Information to Third Parties
We may disclose personal information that we collect or you provide as described in this Privacy Policy:
  • To contractors, service providers and other third parties we use to support our business;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, in which personal information held by us about Site’s users is among the assets transferred;
  • To fulfill the purpose for which you provide it;
  • For any other purpose disclosed by us when you provide the information; or
  • With your consent.
We may also disclose your personal information:
  • To comply with any court order, law or legal process, including to respond to any government or regulatory request;
  • To enforce or apply the [insert link to terms and conditions] and other agreements, including for billing and collection purposes; or
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, Affiliates, our customers or others.

Third Party Links
  • Please be aware that our Sites and email communications may contain links to other websites on the Internet that are owned and operated by third parties. When you press these links you are transferred to the websites of these third parties. The privacy and data processing practices of those websites are covered by the Privacy Policies of the operators of these sites, not our Privacy Policy. We encourage you to review the privacy policies of other websites to understand their privacy practices.
12. Additional California Disclosures

CCPA/CPRA Right

Explanation of the Right

Right to Know / Access

Consumers may request disclosure of categories of PI collected, sources, purposes, categories of third parties, and specific pieces of PI.

Right to Delete

Consumers may request deletion of PI collected from them unless an exception applies.

Right to Correct

Consumers may request correction of inaccurate PI maintained by the business.

Right to Opt-Out of Sale or Sharing

Consumers may direct the business not to sell their PI or share it for cross-context behavioral advertising.

Right to Limit Use of Sensitive PI

Consumers may limit use and disclosure of SPI to what is necessary to perform requested services or operations. We do not collect or process sensitive PI.

Right to Non-Discrimination

Consumers must not receive different prices, services, or treatment for exercising CCPA rights.

Right to Notice at Collection

Consumers must receive a Notice at Collection describing categories of PI, purposes, sale/sharing status, and retention.

Right to Opt-Out of ADMT

Consumers may opt out of automated decision-making technology used for significant decisions.

Right to Access ADMT Information

Consumers may access information about logic, outputs, and effects of ADMT systems applied to them.

Right to Appeal ADMT Decisions

Consumers may appeal an ADMT-driven decision impacting them.

Right to Notice of Financial Incentives

Consumers must receive a notice explaining any financial incentives and terms if PI is exchanged for benefits.

Category of Personal Information Collected

Purpose(s) for Collection and Use

Categories of Vendors / Third Parties

Is PI Sold or Shared?

Identifiers

Account creation, service provision, communication, security, fraud prevention

IT service providers, customer support vendors, cloud hosting providers

No

Sensitive Personal Information

Identity verification, compliance, fraud prevention

Payment processors, identity‑verification vendors, security service providers

No

Customer Records Information

Service delivery, billing, account management

CRM platforms, billing processors, service providers

No

Commercial Information

Order fulfillment, analytics, service improvement

Payment processors, analytics providers, logistics vendors

No

Internet / Network Activity

Site functionality, security, analytics, advertising

Cookie vendors, analytics tools, ad tech partners

No

Geolocation Data

Service localization

Security vendors, analytics platforms

No

Audio/Visual/Electronic Data

Quality control, support interactions, security

Customer service platforms, communications vendors

No

Professional or Employment Information

B2B relationship management, onboarding verification

CRM systems, verification tools

No

Education Information

Applicant screening, credential verification

HR systems, verification vendors

No

Inferences

Personalization, advertising, customer experience

Analytics partners, ad tech partners

No


13. Selling or Sharing of Personal Information
Do Not Sell or Share My Personal Information
California residents have the right to direct a business that sells or shares personal information to stop selling or sharing their personal information.
Our Practices
We may disclose personal information to certain third parties or service providers for purposes such as analytics, advertising, or other operational functions. Some of these disclosures may constitute a “sale” or “sharing” of personal information under California law.
Your Right to Opt Out
You have the right to opt out of the sale or sharing of your personal information at any time.
You may exercise this right by:
  • Clicking the “Do Not Sell or Share My Personal Information” link located on our website; or
  • Enabling an opt‑out preference signal, such as the Global Privacy Control (GPC), in your browser or device settings.
If we receive an opt‑out request through either method, we will process the request in accordance with applicable law.
14. Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, legal_notices@virtuosgames.com