Privacy Policy

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Last updated: 17 July 2026

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1. What does this notice cover?

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Thispolicy describes how Virtuos Holdings Pte. Ltd. and its affiliates ("Virtuos","we", "us" or "our") will make use of your data when you use ourwebsite/services and/or provide us with your personal data in any other way,for example through phone calls, business cards or visiting our office.

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Italso describes your data protection rights, including the right to object tosome of the processing which Virtuos carries out. More information about yourrights, and how to exercise them, is set out in the “Your choices and rights”section.

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2. Personal data we may collect about you

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We collectand process personal data about you when you interact with us and our websitesor use our services.

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This includes:

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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

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Sometimes, we receive information about you fromthird parties. In particular social media platforms and business partners.

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3. How do we use this information, and what is the legal basis for this use?

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Incertain jurisdictions, we have to have a legal basis to process your data. Weexplain each of these legal bases below. We also set out the purposes for whichwe process your data.

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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.

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There are instances where we have a legitimateinterest to use your data. Our legitimate interest will vary depending on whatwe are using your data for, and we explain above what the interest is and howit relates to the processing operations that we are carrying out. Where weprocess personal data on the basis of a legitimate interest, then – as requiredby data protection law – we have carried out a balancing test to document ourinterests, to consider what the impact of the processing will be on individualsand to determine whether individuals interests outweigh our interests in theprocessing taking place. You can obtain more information about this balancingtest by using the contact details at the end of the notice.

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You can obtain more information about this balancing test by using the contact details at the end of the notice.

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For further information on our use of cookies,please consult our Cookie Notice

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4. How we share your personal data

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We mayshare your data with the following categories of recipients:

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Personal Data Category

Category of Recipient

Why?

Contact Information

Virtuos group companies

To operate, improve, and develop our services

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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.

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5. Where we transfer your personal data

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Virtuos operates globally, which means your information may be stored and processed outside of the country or region where it was originally collected.

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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.

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Whereyour personal data is to be transferred out of a country (e.g., Singapore), wewill comply with the applicable privacy laws (e.g., Singapore’s Personal DataProtection Act (the “PDPA”)) in doing so. In this regard, this includesus obtaining your consent unless an exception under applicable law applies, andtaking appropriate steps to ascertain that the foreign recipient organisationof the personal data is bound by legally enforceable obligations to provide tothe transferred personal data a standard of protection that is at leastcomparable to the protection under the applicable law (e.g., the PDPA). Thismay include us entering into an appropriate contract/legal instrument with the foreignrecipient organisation dealing with the personal data transfer or permittingthe personal data transfer without such a contract if the applicable lawpermits us to.

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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).

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A copy of the relevant mechanism can be obtained foryour review on request by using the contact details below.

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6. Your choices and rights

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ncertain jurisdictions, you have the right to ask Virtuos for a copy of your personal data; to correct, delete or restrictprocessing of your personal data; and to obtain the personal data youprovide in a structured, machine readable format. In addition, you can object to the processing of yourpersonal data in some circumstances (in particular, where we don’t have toprocess the data to meet a contractual or other legal requirement). Where wehave asked for your consent, you may withdrawconsent at any time. If you ask to withdraw your consent to Virtuosprocessing your data, this will not affect any processing which has alreadytaken place at that time.

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These rights may be limited, for example iffulfilling your request would reveal personal data about another person, or ifyou ask us to delete information which we are required by law or havecompelling legitimate interests to keep. If you have unresolved concerns, youhave the right to complain to a dataprotection authority in the country that you reside in or, thecountry of your place of work or the country where the alleged infringementtook place.

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In certain non-EU jurisdictions, we may also charge you a reasonable feefor the handling and processing of your requests in accordance with applicablelaws and you will be notified in advance of such costs. To the extent permittedby applicable law, please note that we are not required to respond to or dealwith your request unless you have agreed to pay the fee.

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Where wecollect personal data to administer a contract with you or to comply with ourlegal obligations, this is mandatory and we will not be able to provide youwith our services without this information. In all other cases, provision ofthe requested personal data is optional.

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Theserights may be limited, for example if fulfilling your request would revealpersonal data about another person, or if you ask us to delete informationwhich we are required by law or have compelling legitimate interests to keep.

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If youwish to exercise any of these rights, please contact us at the contact detailsset out below.

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7. How long we retain your personal data

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Where youare a customer, Virtuos will keep your information for the duration of anycontractual relationship you have with us, and, to the extent permitted, afterthe end of that relationship for as long as necessary to perform the purposesset out in this notice. For data about your visits to our websites orapplications, Virtuos will retain this for as long as is reasonably necessaryfor the relevant purpose.

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Further,applicable laws may require Virtuos to hold certain information for specificperiods. In other cases, Virtuos may retain data for an appropriate periodafter any relationship with you ends to protect itself from legal claims, or toadminister its business.

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For moreinformation on our retention periods, please contact us via the contact detailsincluded below.

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8. Updates to this privacy notice

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Wereserve the right to update this privacy notice at any time, and we willprovide you with a new privacy notice when we make any substantial updates. Wemay also notify you in other ways from time to time about the processing ofyour personal information.

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9. Contact us

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Ifyou have questions about this privacy notice or wish to contact us for anyreason in relation to our personal data processing, please contact ourPrivacy Office/Data Protection Officer at at privacy@virtuosgames.com.

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