PRIVACY POLICY

This Privacy Policy specifies how Vinpearl JSC, VinWonders JSC and their affiliated companies (collectively, “Vinpearl”) collect and use your personal information in relation to Vinpearl’s websites, applications, products and services (together, “Vinpearl’s Products”). 

This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties or have their own Privacy Policy.

This Privacy Policy includes the following contents:
1.    What We Collect
2.    How We Use 
3.    Collection and use of cookies
4.    How We Share 
5.    Where We Store
6.    How We Secure 
7.    Internet Advertising and Third Parties
8.    Access and Option
9.    Minor’s Personal Information
10.    How Long We Store Personal Information
11.    Contacts, Notices, and Amendments
12.    Additional Information for the EU
13.    Examples of Information 

1.    What We Collect

We collect your personal information in the course of providing Vinpearl’s Products to you.

Here are the sources from which we gather your information:

•    Information Given to Us: You may provide us with information about you in relation to Vinpearl’s Products. 
•    Automatic Information: Certain types of information is automatically obtained by us when you interact with Vinpearl’s Products. We use cameras and other similar technology (collectively, “camera”) to recognize people and vehicles going in and out of our business areas and other areas under our management.
•    Other Sources of Information: We might receive information about you from other sources, such as service suppliers, partners, and publicly available sources. 

2.    How We Use 

Your personal information may be used to administer, deliver, and improve Vinpearl’s Products. The purposes for using personal information may include:

•    Provide Vinpearl’s Products: To administer, process and deliver Vinpearl’s Products and handle contracts related to Vinpearl’s Products, including without limitation registrations, subscriptions, purchases, incentive, promotional programs and payments.
•    Assess, Evaluate, and Improve Vinpearl’s Products: To assess the use, evaluate performance, fix errors, support and develop Vinpearl’s Products.
•   Recommendations and Personalization: To recommend Vinpearl’s Products that you may like, recognize your preferences, and personalize your experience with Vinpearl’s Products.
•    Comply with Law: In certain cases, we have a legal obligation to collect, use, or retain your personal information. 
•    Communicate with You: To communicate with you in relation to Vinpearl’s Products through relevant channels such as email, chat, SMS and call and to answer your requests.
•    Marketing: We use your personal information to promote Vinpearl’s Products in accordance with the local laws. We may display interest-based ads for Vinpearl’s Products. 
•    Fraud and Abuse Prevention and Credit Risks: We use your personal information to locate and handle fraud to protect our customers, ourselves, and others. We may also use scoring methods to assess and manage credit risks.
•    Other Purposes Where Consent is Required: We may ask for your consent when we use your personal information for certain relevant purposes that we communicate to you.


3.    Collection and use of cookies

We use cookies, pixels, and other similar technologies (collectively, “cookies”) to recognize your browser or device, understand more about your preferences, deliver to you certain basic features and services, and for other purposes, including:
•    Identifying you when you sign in to use Vinpearl’s Products. This allows us to provide you with suggestions, display content personalized to you, and provide other customized features and services.
•    Paying attention to your preferences. This allows us to respect what you like and do not like, such as the language and configuration that you chose. 
•    Researching and analyzing information to improve Vinpearl’s Products. 
•    Preventing fraudulent activity.
•    Improving safety.
•    Delivering content, including ads, relevant to your interests on our sites and third-party sites.
•    Evaluate the performance of Vinpearl’s Products.

Cookies allow you to utilize certain essential features of ours. For examples, if you reject our cookies, you may be unable to use certain products that require your sign-in information, or you may have to manually adjust some preferences or language settings every time you visit our sites..

Approved third parties may also create cookies when you interact with Vinpearl’s Products. Third parties usuaully include search engines, providers of measurement and analytics services, social media networks, and advertising companies. Third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, and to perform services on our behalf. 

You can manage browser cookies through your browser settings. Through the 'Help' feature on most browsers, you will know how to prevent your browser from accepting new cookies, how to receive notification from the browser when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may need to manually adjust some preferences every time you visit a site and some features and services may not work.

 

4.    How We Share 

Information about our customers is an important part of our operation and our business does not sell our customers’ personal information to others. We share personal information only as described below. We also share personal information with Vingroup and its subsidiaries, all of these companies are subject to this Privacy Policy or similar policies.

•    Transactions Involving Third Parties: We provide you with services, software, and content provided by third parties for use on or through Vinpearl’s Products. You can tell when a third party is involved in your transactions, and we share information related to those transactions with that third party. 
•    Third-Party Service Providers: We employ and/or cooperate with other companies and individuals to perform certain functions and carry out certain incentive programs, cross-sale programs, etc. Other examples may include: sending communications, processing payments, evaluating credit and compliance risks, analyzing data, providing marketing and sales support (including advertising and event management), managing customer relationship, and training. These third party providers have access to personal information needed to perform their roles, but may not use it for other purposes. Further, they must comply with this Privacy Policy and the applicable data protection law.
•    Restructuring, Business Transfers: As we continue to develop our business, we might restructure, sell or buy businesses or services in accordance with the laws. In such transactions, personal information, database and right to use information generally are amongst the transferred business assets but remains subject to the Privacy Policy (or the individual consents otherwise). Also, in the event that Vinpearl or substantially all of its assets are acquired, your information will be one of the transferred assets.
•    Protection of Us and Others: We may disclose account and other personal information when we believe such disclosure is required by law, to enforce or apply our terms and other agreements, or to protect the rights, assets, or the safety of ourselves, our customers, or others. This may include releasing exchanging information to other organizations for fraud prevention and detection and credit and property risk reduction.
•  Your Choice: Other than as set out above, you will be notified when your personal information is shared with third parties, and you can elect not to share the information.

5.    Where We Store

Vinpearl is located in Vietnam and has offices in many countries and regions in the world. Depending on your interactions with Vinpearl’s Products, your personal information may be stored in or accessed from multiple countries, including Vietnam. Whenever we transfer personal information to other countries, we make sure that the information is done so in accordance with this Privacy Policy and as authorized by data protection laws.

6.    How We Secure 

At Vinpearl, security is our highest priority. We design our systems with your security and privacy in mind.
•    We employ appropriate technical and security measures to prevent unauthorized access and use of your personal information. We also regularly cooperates with security experts to be updated with the latest information on network security to ensure the safety of your personal information. When collecting data, we maintain and secure your personal information at a server system and these information is secured by firewalls, access control measure and data encryption. 
•    The information of your card, which is issued by the relevant financial institution, is protected by us in accordance with international standards on the principle that no important data of the card (card numbers, full names, CVV number) is recorded in our system. Your payment transaction is made by the relevant bank system.

7.    Internet Advertising and Third Parties

Vinpearl’s Products may include third-party advertising and links to other websites and applications. Third party advertising partners may collect information about you when you interact with their content, advertising, or services. 

8.    Access and Option

You can see, update, and remove certain information about your account and your interactions with Vinpearl’s Products. If you cannot access or update your information yourself, you can always contact us for assistance.

You have many options in relation to the collection and use of your personal information. Many of Vinpearl’s Products include settings that provide you with options as to how your information is being used. You can choose not to provide certain information, but then you might not be able to utilize certain Vinpearl’s Products.

•    Account Information: If you want to add, update, or delete information related to your account, please access to www.vinpearl.com or contact us via call center with hotline 1900.232.389. When you update or delete any information, we usually keep a copy of the prior version for our records for technical purpose.
•    Communications: If you do not want to receive promotional contents from us, please unsubscribe or adjust your communication preferences in www.vinpearl.com (or use other methods specified in the relevant contracts with you). If you do not want to receive in-app notifications from us, please adjust your notification settings in the app or your device. 
•    Advertising: If you don’t want to see interest-based ads, please adjust according to instructions of relevant advertising website (or use other methods specified in the relevant contracts with you) . 
•    Browser and Devices: The Help feature on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

9.    Minor’s Personal Information

If you’re under 18, you may enter into contracts and accept this Privacy Policy only with the approval of your parent or guardian.

10.    How Long We Store Personal Information

We retain your personal information to ensure your continued use of Vinpearl’s Products, for as long as it is needed to meet the relevant purposes described herein, as may be required by law (including for tax and accounting purposes), or as otherwise informed to you. How long we keep certain personal information will be different based on the purpose for its use, and we will adhere to the law when deleting your personal information.

11.    Contacts, Notices, and Amendments

If you have any concern about privacy at Vinpearl or want to contact one of our data controllers, please contact us and we will try to resolve it. You may also contact us at the address below:
-    Email: [email protected]
-    Phone: 1900.232.389
Our business changes constantly, and our Privacy Policy may also change. You should check our website frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all personal information we have about you and your account. We will not change our Privacy Policy to make them less protective of personal information collected in the past without informing the relevant customers and giving them a choice.

12.    Additional Information for the EU

We provide additional information about the privacy, collection, and use of personal information of prospective and current customers of Vinpearl’s Products located in the European Economic Area.

•    Controller of Personal Information. Vinpearl JSC. (at Hon Tre Island, Vinh Nguyen ward, Nha Trang City, Vietnam) is the controller of the personal information collected or processed under this Privacy Policy.

•    Processing. We process your personal information on one or more of the following legal bases:
o    as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide Vinpearl’s Products, to respond to requests from you, or to provide customer support;
o    where we have a legitimate interest, as described in Section 2 of this Privacy Policy;
o    as necessary to comply with relevant law and legal obligations;
o    respond to lawful requests and orders; or
o    with your consent.

•    Your Rights. Subject to applicable law, you have the right to:
o    ask whether we hold personal information about you and request copies of such personal information and information about how it is processed;
o    request that inaccurate personal information be corrected;
o    request deletion of personal information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements;
o    request us to restrict the processing of personal information where the processing is inappropriate;
o    object to the processing of personal data;
o    request portability of personal information that you have provided to us (which does not include information derived from the collected information), where the processing of such personal information is based on consent or a contract with you and is carried out by automated means; and 
o    lodge a complaint with the supervisory authority if you believe that we violate your privacy rights.
You can exercise your rights of access, rectification, erasure, restriction, objection, and data portability by contacting us. If you wish to do any of these things and you are our customer, please contact us. If you are not our customer, please contact us at the address under Section 11 above.
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.

•    Transfers outside of the EU. When we transfer your personal information collected and stored within the EU to outside the EU we do so in accordance with the terms of this Privacy Policy and applicable data protection law. This may include the transfer of data pursuant to data transfer agreements that incorporate the Standard Contractual Clauses approved by the EU Commission.

 

13.    Examples of Information 

Information You Give Us

We mainly obtain information about you when you:
•    search for, subscribe to, or purchase Vinpearl’s Products;
•    create or use your account;
•    configure your settings for, provide data access permissions for, or otherwise interact with Vinpearl’s Products; 
•    register for or attend a Vinpearl event;
•    purchase or use content, products, or services from third-party providers through Vinpearl’s websites or apps (or other similar venues operated or provided by us); 
•    offer your content, products, or services on or through Vinpearl’s Products or Vinpearl’s websites or apps (or other similar venues operated or provided by us);
•    communicate with us through official channels such as our customer support centre, call centre, email; 
•    complete a questionnaire or other information request forms; 
•    post on Vinpearl’s websites or apps or similar venues.
Depending on your use of Vinpearl’s Products, we may obtain from you such information as:
•    your name, email address, physical address, phone number, and other similar contact information;
•    payment information, including credit card and bank account information;
•    information about your location;
•    information about your organization and your contacts, such as colleagues or people within your organization;
•    usernames, aliases, roles, and other authentication and security credential information;
•    content of feedback, testimonials, inquiries, communications with us; 
•    your image (still, video, and in some cases 3-D), voice, and other identifiers that are personal to you when you attend an event of Vinpearl or use certain Vinpearl’s Products; 
•    information regarding identity, including government-issued identification information, nationality; 
•    corporate and financial information; and
•    VAT, PIT numbers and other tax identifiers.

Automatic Information

We mainly automatically receive information when you:
•    are present in Vinpearl’s business centers; 
•    visit, interact with, or use Vinpearl’s Products (including when you use your computer or other device to interact with Vinpearl’s Products); 
•    download content from us;
•    open emails or click on links in emails from us; and
•    interact or communicate with us.
Examples of the information automatically collected may include:
•    network and connection information, such as the Internet protocol (IP) address used to connect your computer (or other device) to the Internet and information about your Internet service provider; 
•    computer and device information, such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting; 
•    the location of your device or computer;
•    authentication and security credential information;
•    content interaction information, such as content downloads, streams, and playback details, including duration and number of simultaneous streams and downloads; 
•    Vinpearl’s Products metrics, such as offering usage, occurrences of technical errors, reports, your settings preferences, backup information, API calls, and other logs; 
•    the content you viewed or searched for, page response times, and page interaction information (such as scrolling, clicks);
•    email addresses and phone numbers used to contact us; and
•    identifiers and information contained in cookies.  

Information from Other Sources

Examples of information we receive from other sources include:
•    marketing, sales generation, and recruitment information, including your name, email address, physical address, phone number, and other similar contact information; 
•    subscription, purchase, support, or other information about your interactions with products and services offered by us or third parties in relation to Vinpearl’s Products; 
•    search results and links, including paid listings (such as Sponsored Links); and 
•    credit history information.


 

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