Privacy Policy - Last updated Dec 15th 2022

The data controller is M19 Networks


District 1, Ho Chi Minh, Vietnam


The protection of your personal data is fundamental to us. This confidentiality policy outlines information pertaining to the manner in which we collect and process this data.


Personal data or Data shall mean any information relating to an identified or identifiable natural person.


Data controller shall mean the person that determines the purposes and means of the processing.

Remit of the personal data protection policy

This personal data protection policy is applicable to all of our applications.

What data is collected?

With your prior consent, we are likely to collect and process the following data in whole or in part when you use our applications.


We are also likely to use cookies which correspond to small files containing letters and figures downloaded onto your device when you access our applications.


This data is collected via external tools (Software Development Kit or SDK) implemented by our partners, which are an integral part of the application.


You will find hereafter the list of our partners implementing SDKs through our applications:

Purposes of processing undertaken by M19 Networks and legal basis for processing

Data collected by M19 Networks is used to:


We collect the data listed hereinabove, in whole or in part, only once we have your express consent for the purposes for which they are to be processed, through a pop-up in our applications.


At any time you can withdraw your consent from the Settings page in our various applications.

Term of data storage

M19 Networks stores your personal data for a maximum duration of 13 months after collection. Beyond this term, data may be rendered anonymous and stored solely for statistical use and will not be exploited, in any nature whatsoever.

Categories of recipients of data collected

The recipients of the Data are the teams of M19 Networks that need to have access as well as the partners mentioned above in article 2. We may however share Data collected with our technical service providers for the aforementioned purposes. We stringently request that our partners always act in compliance with Data protection legislation applicable and grant special attention to confidentiality of this Data. By application of the applicable regulation, any sub-contractor who may process this personal data for M19 Networks undertakes as follows:


M19 Networks may also disclose/transfer your personal data to third parties in the following particular circumstances:

Data transfer

In such instance as your Data is transferred outside of the United States, we ensure that:

Personal data concerning children

M19 Networks does not knowingly collect any personal data concerning children under 13 years old.

Your rights concerning data collected

You have all of the following rights concerning the data we collect:


You are entitled to obtain from the controller confirmation as to whether or not data related to you are being processed.


You are entitled to receive confirmation that your personal data is or is not processed and, when processed, you are entitled to access said data. This right also includes that of receiving a copy of data processed.


You are entitled to request that your data be amended, updated or completed when inaccurate, incorrect, incomplete or obsolete.


You are entitled to request deletion of your data solely on those grounds for which provision is made by applicable regulation and in particular when:


You are entitled to request that the data controller limit the use of your data solely on those grounds for which provision is made by applicable regulation and in particular when:


You are entitled to reclaim your data provided to M19 Networks, in a structured format, commonly used and machine-readable, and the right to transfer this data to another data controller, for instance so as to change service provider.


You have the right to provide specific or general guidelines for the retention, erasure and disclosure of your personal data to designated third parties after your death.

If you consider that M19 Networks has defaulted in respect of its obligations in light of your personal data, at any time you may issue a complaint or make a claim to the competent authorities.

Terms for exercising rights


You may exercise the aforementioned rights by sending an email to the following address: support@m19networks.com.


Due to the obligation of security and confidentiality in Data processing incumbent upon M19 Networks, you are hereby informed that your request will be processed subject that you provide proof of your identity, notably by producing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.


M19 Networks will determine whether this is admissible or not within one month following receipt of the claim. In such instances as it is deemed admissible, M19 Networks will provide all information requested or implement the rights claimed within the aforementioned deadline.


If, given the complexity of the claim or the number of requests received, the aforementioned deadline cannot be respected, M19 Networks will notify you prior to expiry of this deadline, of this deadline being pushed back by a maximum of two months following its decision.


M19 Networks hereby notifies you that it will be entitled, where applicable, to object to any requests which are clearly abusive (in their number, repetitive nature, or systematic).


In such an instance as M19 Networks does not follow up on your request, we will inform you of the aforementioned deadlines of the grounds on which our decision is based and your option to refer a complaint.

Personal data security

We take all necessary security measures so as to prevent as far as practically possible any alteration or loss of your data or any unauthorised access thereunto.

In such instances as we should be aware of any illegal access to personal data concerning you and corresponding to processing for which we are responsible, we undertake to notify you of the incident as soon as possible if this fulfils a legal requirement.

Updating the present policy

The present policy may be updated at any time, notably pursuant to legal and/or regulatory provisions and/or any recommendations of appropriate authorities. We hereby invite you to consult this page regularly.