AGORAX PRIVACY POLICY

Effective date: [30/09/2026]
Last updated: [30/09/2026]

AgoraX (“AgoraX”, “we”, “us”, or “our”) respects the privacy of individuals whose information may be processed in connection with our websites, digital services, campaigns and applications.

This Privacy Policy explains how we collect, use, store, disclose and protect information in connection with services operated or managed by AgoraX, including applications integrated with third-party platforms such as Meta/Facebook.

1. Information We May Collect

Depending on the service, campaign, application and permissions provided by the relevant platform, AgoraX may process information including:

• Information voluntarily provided by users when participating in campaigns, promotions, minigames or other activities;

• Information associated with interactions on social media platforms, where made available to us through authorized platform APIs;

• Content submitted by users, such as comments and replies;

• Relevant identifiers associated with posts, comments or replies;

• Date and time of interactions;

• Other information that is necessary to operate, verify or administer a campaign and that is made available through the applicable platform.

AgoraX only accesses information that is necessary for the relevant business purpose and that is made available through authorized services or permissions.

2. How We Use Information

We may use information for legitimate business purposes including:

• Operating and administering digital campaigns, promotions and minigames;

• Collecting and reviewing campaign entries;

• Validating whether participation complies with published campaign rules and eligibility requirements;

• Reviewing comments, replies and other eligible interactions for campaign administration;

• Identifying and verifying eligible participants and prize recipients;

• Preventing duplicate, fraudulent or otherwise invalid entries;

• Preparing campaign reports, statistics and performance analysis;

• Responding to questions, disputes or requests relating to a campaign;

• Maintaining security and integrity of our services;

• Complying with applicable legal or regulatory requirements.

Information will not be used for purposes materially unrelated to those described above without an appropriate legal basis or notice.

3. Use of Meta/Facebook Platform Data

Certain applications operated by AgoraX may connect to Meta products through the Meta Platform and Meta APIs.

For example, AgoraX may use an internal application to retrieve information relating to comments and replies submitted to posts published by Facebook Pages that AgoraX is authorized to manage.

Such information may be processed for purposes such as:

• collecting campaign or minigame entries;

• reviewing comments and replies against published participation rules;

• identifying duplicate or invalid entries;

• calculating eligible interactions where this forms part of the published campaign mechanics;

• supporting the selection and verification of eligible prize recipients; and

• preparing campaign administration reports.

AgoraX only accesses Meta Platform Data made available through permissions authorized by Meta and the relevant Page or account.

AgoraX does not sell Meta Platform Data.

Meta Platform Data will only be accessed by authorized personnel or service providers where access is necessary to perform the relevant campaign or service and subject to appropriate confidentiality and data-protection obligations.

4. Data Sharing

AgoraX may disclose information where reasonably necessary to:

• authorized AgoraX personnel involved in operating the relevant service or campaign;

• clients for whom AgoraX administers a campaign, where necessary for campaign verification, reporting or prize administration;

• technology or service providers supporting AgoraX's systems and campaign operations;

• professional advisers or authorities where required by applicable law.

We do not sell personal information obtained through Meta APIs to third parties.

5. Data Retention

AgoraX retains information only for as long as reasonably necessary to:

• administer and complete the relevant campaign or service;

• verify campaign results and resolve participant enquiries or disputes;

• fulfil contractual, audit or reporting requirements; and

• comply with applicable legal obligations.

When information is no longer required for these purposes, AgoraX will take reasonable measures to delete, anonymize or otherwise securely dispose of it in accordance with applicable requirements and internal procedures.

6. Data Security

AgoraX applies reasonable administrative, organizational and technical safeguards designed to protect information against unauthorized access, loss, misuse, alteration or disclosure.

Access to campaign and platform data is limited to personnel who require such access for authorized business purposes.

7. User Data Deletion Requests

Individuals may request deletion of personal information associated with services operated by AgoraX.

To submit a deletion request, please contact:

Email: ivy.ax@agorax.vn
Subject: Data Deletion Request

Please include sufficient information for us to identify the relevant campaign, application or data associated with your request.

After receiving a valid request, AgoraX will review the request and delete or anonymize the relevant information where required and permitted by applicable law.

Certain information may need to be retained where necessary to comply with legal, contractual, fraud-prevention or dispute-resolution obligations.

8. Third-Party Platforms

Our services may interact with third-party platforms, including Meta/Facebook.

The collection and processing of information directly by those platforms is governed by their respective privacy policies and terms. AgoraX is responsible for information that AgoraX receives and processes in accordance with this Privacy Policy.

9. Changes to This Privacy Policy

AgoraX may update this Privacy Policy from time to time to reflect changes to our services, technologies, legal requirements or data-processing practices.

The updated version will be published on this page together with the latest revision date.

10. Contact Us

For questions regarding this Privacy Policy or the handling of personal information by AgoraX, please contact:

AgoraX
Legal entity: AgoraX Company Limited (Vietnam)
Address: 5th Floor, 231-233 Le Thanh Ton, Ben Thanh Ward, Ho Chi Minh City, Vietnam.
Email: ivy.ax@agorax.vn
Website: https://www.agorax.vn/