Privacy Policy

PRIVACY POLICY OF NEURASPHERE TECHNOLOGY CO., LTD.

NEURASPHERE TECHNOLOGY CO., LTD. (hereinafter referred to as "the Company," brand name: NSPHERE, official platform website: www.nsphere.store), as the provider of game top-up services, fully recognizes the importance of personal information. This Privacy Policy (hereinafter referred to as "this Policy") is formulated in accordance with the Personal Data Protection Act (PDPA) of Thailand and relevant data protection laws and regulations. It aims to clarify the rules for the Company's collection, use, storage, protection, and disclosure of users' personal information, and to safeguard the security and legitimate rights and interests of users' personal information.

In the course of using the game top-up services (hereinafter referred to as "the Services") provided by the Company, the User (hereinafter referred to as "you") will inevitably be involved in the submission and processing of personal information. By submitting a top-up order, completing payment, recharging your user wallet, or otherwise actually using the Services through the Company's official platform, you are deemed to have fully read, understood, and agreed to all the contents of this Policy, and have consented to the Company's processing of your personal information in accordance with the provisions of this Policy. If you do not agree to any clause of this Policy, you shall immediately cease using the Services.

I. GENERAL PROVISIONS

1.1 Scope of Application
This Policy applies to all acts of the Company in collecting, using, storing, protecting, and disclosing your personal information in the course of providing the Services, including but not limited to information processing activities such as your submission of wallet recharge transactions, submission of top-up information, consultation with customer service, and application for refund through the Company's official platform (www.nsphere.store).

This Policy does not apply to the information processing acts of third-party platforms (such as game developers, payment institutions, network operators, etc.). The Company shall not be liable for the privacy policies and information processing acts of third parties, and you shall consult the relevant privacy policies of third parties on your own.

1.2 Core Definitions

Personal Information: Refers to information that can directly or indirectly identify your personal identity, including but not limited to game account, game server, character name, payment account information, wallet transaction records, and contact information (such as email or phone number provided when consulting customer service).

Anonymized Information: Refers to information that cannot identify a specific individual and cannot be restored to identify a specific individual through reasonable means after technical processing. Such information is not personal information and may be freely used by the Company for purposes such as service optimization and commercial analysis.

II. SCOPE AND METHODS OF PERSONAL INFORMATION COLLECTION

2.1 Collection of Necessary Information
To realize the core functions of the Services (including wallet recharge and game top-up), the Company needs to collect the following necessary personal information from you. If you refuse to provide such information, the Services will not be able to be completed normally:

Payment-related Information (for Wallet Recharge): Including information related to your PROMPTPAY QR code payment for wallet recharge, such as a payment identifier, payment time, payment amount, and any applicable variable handling fee, which are used to complete the fund settlement for the wallet recharge and order verification.

Wallet Transaction Records: Including records of wallet top-ups, deductions for order payments, and wallet balance, which are used for transaction history tracking, dispute handling, and financial reconciliation.

Game-related Information (for Top-up Orders): Including game account, game server, and character name, which are used to accurately locate the top-up target and ensure the correct delivery of the top-up service.

Order-related Information: Including order number, top-up amount, and top-up time, which are used for order status tracking, dispute handling, and after-sales rights protection.

2.2 Collection of Non-necessary Information
When you use additional services such as after-sales consultation and refund application, the Company may need to collect your contact information (such as email or phone number). The provision of such information is voluntary, and you have the right to refuse to provide it. However, refusal to provide it may result in the Company's inability to respond to your after-sales needs in a timely and effective manner.

2.3 Methods of Collection

Active Submission: Personal information actively provided by you when performing wallet recharge, filling in top-up information, submitting orders, or contacting customer service on the Company's official platform.

Third-party Acquisition: On the premise of transaction necessity and compliance, obtaining necessary payment verification information from payment institutions (for wallet recharge verification) and obtaining top-up status confirmation information from game developers (only for verifying whether the top-up is successful).

Automatic Collection: When you use the Services, the Company may automatically collect technical information such as your device identifier and network connection status to ensure service stability, security protection, and fraud prevention. Such information usually cannot directly identify your personal identity.

III. PURPOSES OF PERSONAL INFORMATION USE
The Company strictly follows the principles of lawfulness, fairness, necessity, and minimality in using your personal information, and only uses it for the following legitimate purposes directly related to the Services:

Providing and Managing Wallet Services: Including processing wallet recharge transactions, managing wallet balances, recording transaction history, and settling funds with payment institutions.

Completing Game Top-up Services: Including processing top-up orders, deducting payments from wallet balances, and cooperating with game developers to complete top-up operations.

Handling After-sales Services and Disputes: Including responding to your consultations regarding wallet transactions or top-ups, order verification, refund applications, and retaining relevant information for handling possible service disputes.

Security Assurance and Risk Control: Used to identify abnormal recharge or top-up behaviors, prevent risks such as fraud, money laundering, and account theft, and ensure the security of your wallet, account, and funds.

Compliance with Legal Obligations: Retaining necessary personal information and service records to comply with relevant laws and regulations of Thailand, including but not limited to financial record-keeping and responses to lawful requests from administrative or judicial authorities.

Service Optimization: On the basis of anonymization, analyzing aggregated user behavior data (such as top-up patterns) to optimize the Company's service processes and platform functionalities.

Without your explicit written authorization or as otherwise required by law, the Company will not use your personal information for any purposes other than those mentioned above.

IV. STORAGE AND PROTECTION OF PERSONAL INFORMATION

4.1 Storage Period
The Company will only store your personal information for a reasonable and necessary period required to fulfill the purposes outlined in this Policy, to complete the Services, to handle subsequent disputes, and to comply with legal obligations. The specific storage periods are as follows:

Wallet Recharge/Payment Records and Top-up Order Information: Retained for a period of 2 years from the date of the transaction or order completion, used for handling possible after-sales disputes, financial audits, and compliance reviews.

After-sales Consultation and Refund-related Information: Retained for a period of 1 year from the date of problem resolution, used for tracing after-sales processing records.
After the expiration of the above storage periods, the Company will delete or anonymize your personal information in accordance with the law and will no longer retain information that can identify your personal identity, unless further retention is required by law.

4.2 Storage Methods and Locations
The Company stores your personal information in secure servers located within Thailand. We adopt a range of technical measures, including but not limited to encrypted storage, access control, and network security protocols, to prevent personal information from being leaked, tampered with, damaged, or lost.

4.3 Security Protection Measures
The Company has established a comprehensive personal information security management system and adopts the following technical and organizational measures to ensure the security of your personal information:

Technical Measures: Utilizing SSL/TLS encrypted transmission for data in transit, data encryption and pseudonymization for data at rest, firewall protection, intrusion detection systems, and regular security vulnerability assessments.

Organizational Measures: Implementing a strict information access authorization and control system. Access to personal information is restricted to authorized personnel on a need-to-know basis for specific business purposes. All employees receive regular training on information security and data protection compliance.

Incident Response: Formulating a personal information security incident emergency response plan. In the event of a suspected or actual personal information breach, the Company will activate the response plan immediately, take remedial measures, and, where required by the PDPA or other applicable laws, notify you and the relevant regulatory authorities without undue delay.

V. RESTRICTIONS ON DISCLOSURE OF PERSONAL INFORMATION
The Company strictly protects the confidentiality of your personal information. Without your explicit prior consent, we will not disclose your personal information to any third party, except in the following specific circumstances:

Legal and Regulatory Requirements: Disclosing your personal information to relevant government authorities, law enforcement agencies, or judicial bodies in accordance with mandatory requirements of applicable laws and regulations of Thailand, or in response to valid legal processes (e.g., court orders, subpoenas).

Service Fulfillment: Disclosing necessary personal information to trusted third-party service providers strictly required to perform specific functions on our behalf, such as payment processors (for wallet recharge settlement) and game developers (for executing top-up operations). In such cases, the Company enters into contracts with these providers requiring them to protect your information, use it only for the specified purpose, and comply with applicable data protection laws.

Protection of Legitimate Rights and Interests: Disclosing relevant personal information within a reasonable and necessary scope to protect the vital legitimate rights and interests of the Company, you, or other individuals or the public, such as for the purposes of fraud prevention, investigation of potential violations of our Terms and Conditions, or responding to security or technical issues.

Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, your information may be disclosed or transferred as a business asset, subject to confidentiality commitments.

Anonymized Information: The Company may share or publish aggregated, anonymized, or de-identified user data with partners or for analytical purposes. Such data does not contain any information that can be used to identify any individual user.

VI. USER'S RIGHTS TO PERSONAL INFORMATION
In accordance with the Personal Data Protection Act (PDPA) of Thailand, you have the following rights regarding your personal information. The Company will provide necessary assistance for you to exercise these rights:

Right of Access: You have the right to request access to and obtain a copy of your personal information held by the Company, and to be informed about the purposes of processing, categories of data, and recipients of the data.

Right to Data Portability: Where applicable, you have the right to receive your personal information which you have provided to the Company in a structured, commonly used, and machine-readable format.

Right to Rectification: If you find that the personal information about you stored by the Company is inaccurate, incomplete, or outdated, you have the right to request its correction, update, or completion.

Right to Deletion (Right to be Forgotten): Under certain circumstances specified by law (e.g., the data is no longer necessary for the purposes collected, you withdraw your consent), you have the right to request the deletion of your personal information.

Right to Restriction of Processing: You have the right to request the restriction of processing of your personal information under certain conditions (e.g., while the accuracy of the data is contested).

Right to Object: You have the right to object to the processing of your personal information based on legitimate interests or for direct marketing purposes.

Right to Withdraw Consent: You have the right to withdraw your consent to the Company's processing of your personal information at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. However, please note that withdrawing consent may prevent the Company from providing you with certain or all Services.

To exercise any of the above rights, please submit a written request to the Company's official customer service email (support@nsphere.store). You may be required to provide necessary information to verify your identity (such as order number, associated game account, or other identifiers). The Company will endeavor to respond to your request and provide feedback on the processing result within 5 working days after receiving the verified request, in accordance with the requirements of the PDPA.

VII. REVISION AND PUBLICATION OF THE POLICY
The Company reserves the right to revise or update this Policy from time to time in accordance with changes in relevant laws and regulations of Thailand, business development needs, or technological upgrades. The revised Policy will be published prominently on the Company's official platform (www.nsphere.store) with a publication period of not less than 7 natural days.

After the expiration of the publication period, if you continue to use the Services (including performing wallet recharge or submitting top-up orders), you are deemed to have read, understood, and agreed to the contents of the revised Policy. If you do not agree to the revised Policy, you shall immediately cease using all Services and may exercise your right to withdraw consent and request deletion of your personal information as outlined in Section VI.

VIII. DISCLAIMER
The Company shall not be liable for any leakage, loss, alteration, or damage of your personal information caused by the following circumstances:

Force Majeure Events: Including but not limited to unforeseeable, unavoidable, and insurmountable objective circumstances such as natural disasters, wars, terrorist attacks, major network failures, server outages, or widespread public health emergencies.

User Negligence: Consequences arising from your failure to properly safeguard your personal information, such as disclosing your game account password, wallet access credentials, or payment account details to others, or becoming a victim of phishing or other social engineering attacks.

Third-Party Liabilities: Leakage of your personal information due to security vulnerabilities, faults, or malicious acts of third-party platforms, service providers (e.g., payment gateways, game developers), or networks, where such leakage is not attributable to any breach of this Policy or negligence by the Company.

Information Publicly Disclosed by You: Risks arising from your voluntary disclosure of personal information to the public or to third parties through channels not controlled by the Company.

IX. CONTACT INFORMATION AND DISPUTE RESOLUTION

9.1 Contact Information
If you have any questions, complaints, suggestions, or wish to exercise your rights regarding this Policy or the handling of your personal information, you may contact the Company's Data Protection Officer or relevant team through the following method:

Official Customer Service Email: support@nsphere.store

9.2 Dispute Resolution
Any dispute arising out of or in connection with this Policy or the handling of your personal information shall first be resolved through friendly negotiation between the parties. If negotiation fails, either party has the right to submit the dispute to the exclusive jurisdiction of the competent courts located in Bangkok, Thailand. The resolution of the dispute shall be governed by the substantive laws of Thailand currently in effect, without regard to its conflict of law principles.

X. SUPPLEMENTARY PROVISIONS
This Policy shall take effect from the date on which you first use the Services. For matters not covered by this Policy, the provisions of the Personal Data Protection Act (PDPA) of Thailand and other relevant data protection laws and regulations shall apply.

NEURASPHERE TECHNOLOGY CO., LTD. reserves the right of final interpretation of this Policy.

Update Date: June 18, 2025