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PRIVACY POLICY

I. GENERAL PROVISIONS

1. Purpose:

This policy on right of privacy ("Privac Policy") provide description describes how Vinpearl Joint Stock Company and its affiliated companies (hereinafter collectively referred to as “Vinpearl” or "we") collect and use your personal information while you use Vinpearl's websites, applications, products and services (collectively, "Our Products"). 

  • The policy is designed to help you understand how we collect, use, disclose and/or process personal data that you have provided to us and/or hold about you, in the time being or in the future; as well as help you make informed decisions prior to any personal data being provided.
  • By using Our Products, you acknowledge that you have:
    • read this Policy in its entirety, understand and accept its entire content, and
    • expressly and voluntarily consented to our sole discretion to collect, use, disclose and/or process your personal data as described below; and that
    • allowed and agreed that we may access, store, process and disclose your Account information and Content in accordance with the law or at the request of a Court / Competent State Agency rights to Vinpearl; or Vinpearl's branches/affiliates; or where Vinpearl believes in good faith that such access, preservation or disclosure is necessary to: comply with legal process; comply with requests from any State agency or competent regulatory authority for Vinpearl or its branches/affiliates; enforce the terms and conditions of use of Our Products or this Policy; Meet your requests for customer service; or protect the rights, property or personal safety of Vinpearl or its related affiliates, users and/or the public.

2. Scope of application

This policy applies independently or concurrently with notices and documents at Vinpearl facilities and locations.

In case there is a contradiction between this Policy and the documents and documents mentioned above on the same content, this Policy will prevail.

3. Applicable object

This policy applies to all Client who have been using Our Products. This Privacy Policy does not apply to any products, services, websites or content offered by third parties or that use their own privacy policies. 

4. This Privacy Policy includes the following contents:

(1) Personal information collected by us
(2) Sources of information we collect
(3) Collect other data
(4) Regulations on information collected by Internet advertising and third parties
(5) How we use personal information
(6) Collection and use of cookies
(7) How we share personal information
(8) Location of personal information
(9) How we protect personal information
(10) Access and selection
(11) Personal information of minors
(12) Term of storing personal information
(13) Communications, notices and modifications
(14) Some additional information for Europe

II. PRIVACY POLICY CONTENTS

1. Types of personal information we collect

1.1. Your personal information is collected during your interactions with Our Products. Personal data is any information provided to our company that can be used to identify an individual as required by law.

1.2. You agree not to provide any information that is inaccurate or misleading and will notify us of any inaccurate content or changes to the information as soon as possible. We reserve the right (at our sole discretion – from time to time) to request you to provide other necessary documents, to verify any information you have provided.

1.3. If you do not want to provide the above personal information/data, you can opt out at any time by notifying our Personal Data Protection Officer in writing; or follow the instructions set forth in Section 13, Part II of this Privacy Policy. However, please note that refusing or revoking your consent to our collection, use or processing of your personal data may affect your use of Our Products. For example, location services will not work if you do not allow the application to access your location.

2. Sources of information we collect:

2.1. Information you provide to us: Vinpearl collects any information you provide related to Our Products.

2.2. Automatic information: We automatically collect certain types of information when you interact with Our Products. We use cameras and other similar technologies (collectively “cameras”) to identify people and vehicles entering and exitng our businesses and areas under our management. In some cases, you may provide personal data of other individuals to us (for example, family members, friends or people in your contact list). If you provide us with their personal data, you represent and warrant that you have obtained their consent to process their personal data in accordance with this Policy.

2.3. Information from other sources: We may collect information about you from other sources, including but not limited to service providers, partners and publicly available sources.

3. Collect other data

3.1. Your device sends information which may include data about you, which is recorded by a website server when you use our Products. If you log in, this information is linked to your personal account. This information is also included in anonymous statistics to help us understand how visitors use our Website.

3.2. Our mobile applications can collect accurate information about the address of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more purposes including but not limited to providing location-based services that you request. You can withdraw your permission for us to collect this information based on your location through the settings on your device.

3.3. When you view content and advertising and access other software on our Products or through the service, information may be sent to us.

4. Regulations on information collected by Internet advertising and third parties

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

4.2. Our products use Google Analytics and Insider. Google Analytics is a web analytics service provided by Google, Inc. ("Google"), while Insider is a data collection and user interaction platform that helps build automated customer experiences, predict behavior and personalize to understand how users use Products. and report on activities and trends. This service may also collect information about your use of websites, applications and other online resources over time.

4.3. We, and third parties, may from time to time make software application downloads available to you. These applications are privately accessible and allow a third party to view your identifiable information. We may also enter into co-marketing and other relationships to provide e-commerce and other services and features to our visitors. We, in our efforts, will implement reasonable security measures to protect your personal data in accordance with the provisions of law; However, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY WEBSITES. These linked sites have their own and independent privacy policies and security measures. Even if that third party is affiliated with us, we do not control these linked websites/applications/services, each of which has its own privacy and data collection practices. separate and independent data from us. You should read the terms and other policies published by those third parties on their websites.

5. How we use personal information

We use your personal information to operate, provide and improve Our Products, specifically: 

5.1. Providing Products and Services: We use your personal information to provide Products and Services and process transactions related to Our Products, including but not limited to deadline for registration, purchase, participation in advertising programs, incentives and payments.

5.2. Measure, support and improve Our Products: We use your personal information to measure usage, analyze performance, fix errors, provide support, improve and develop Our Products:

5.3. Make recommendations and personalize experiences: We use your personal information to recommend Our Products that may be of interest to you, identify your interests and personal preferences. Humanize your experience with Our Products.

5.4. Communications with you: We use your personal information to communicate with you regarding matters related to Our Products through various channels (e.g. email, chat, SMS, voice calls) and to respond to your requests, inquiries or handle complaints (if any).

5.5. Marketing: We use your personal information to market and promote Our Products in accordance with the law. We may display advertisements for Our Products based on your interests.

5.6. Prevention of fraud and abuse, credit risk: We use your personal information to prevent and detect fraud and abuse to protect security, personal safety and other customers. the rights and property of our customers, ours and others. We may also use scoring methods to assess and manage credit risk.

5.7. Some specific purposes require your consent: We may ask for your additional consent to use personal information for a specific purpose when we contact you.

6. Collection and use of cookies

6.1. We or our authorized service providers and advertising partners (specified in section 6.3 below) use cookies, pixels and other similar technologies (collectively “cookies”) to recognize your browser or device, learn more about your preferences, provide you with essential features and services, and for other additional purposes, including:

  • Identify you when you log in and/or use our services. This allows us to provide you with recommendations, display personalized content and provide other customized features and services.
  • Pay attention to the options you have accepted. This allows us to respect your likes and dislikes, such as the language and configuration you choose. Thereby improving service quality and customer experience.
  • Conduct research and analysis to improve Our Products, helping us recommend new services and features tailored to your needs.
  • Prevent fraud.
  • Improved security.
  • Provide content, including advertising, relevant to your interests on our websites and third-party websites.
  • Measure and analyze the quality of Our Products.

6.2. Cookies allow you to take advantage of some of our essential features. For example, if you block or reject our cookies, you will not be able to use certain products or services that require you to log in, or you may have to manually adjust some preferences. Select or set your language each time you revisit our websites.

6.3. Approved third parties may also set cookies when you interact with Our Products. These third parties typically include search engines, measurement and analytics providers, social networks and advertising companies. Third parties use cookies in the delivery of content, including advertising relevant to your interests, to measure the effectiveness of advertising and to perform certain services on our behalf. 

6.4. You can manage browser cookies using your browser settings. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to notify you when you receive a new cookie, how to disable cookies, and when a cookie expires. term. If you disable all cookies on your browser, neither we nor third parties will be able to transfer cookies to your browser.

7. How we share personal information  

7.1. Customer information is an important part of our operations. Vinpearl absolutely does not sell customers' personal information to any other organization or individual. However, in the course of our business, we will/may need to use, process, disclose and/or transfer your personal data to third party service providers, agents and/or our affiliates or related companies, and/or other third parties that may be located in Vietnam or outside Vietnam, for one or more of the above Purposes, and this disclosure will be carried out in accordance with the order and provisions of current law. The above-mentioned third-party service providers, agents and/or affiliates or related companies and/or other third parties will process your personal data on or on our behalf, or vice versa, for one or more of the above Purposes. We strive to ensure that third party service providers and Vinpearl affiliates keep your personal data secure from access, collection, use, disclosure, unauthorized processing or similar risks. Storing your personal data in cases necessary for the above Third Parties' Purpose includes but is not limited to:

  • Transactions involving third parties: We provide you with services, software and content provided by third parties for use on or through Our Products. You can know when third parties are involved in your transactions and when we will share information related to those transactions with third parties. Third parties may be (including but not limited to).
    • our parent companies, subsidiaries, affiliates and related companies;
    • other Client of our Products for one or more of the purposes set out above;
    • contractors, agents, service providers and other third parties we engage to support or supplement our business operations;
    • State agencies or management agencies with jurisdiction over Vinpearl.
  • Third party service providers: We use and/or cooperate with other companies and individuals to carry out certain tasks and programs such as incentive programs, cross-selling, etc. for you. Examples include: sending communications, processing payments, assessing credit risk and compliance, analyzing data, providing marketing and sales support (including advertising and event management), customer relationship management and training. These third-party service providers have access to personal information necessary to perform their functions, but may not use it for other purposes. In addition, they must comply with this Privacy Policy and related privacy laws.
  • Restructuring, Transfer: During the business development process, we may sell or buy businesses or restructure other businesses or services in accordance with the provisions of the laws. In such transactions, personal information, databases and information rights are generally among the business assets transferred but the transferee must still comply with the provisions of this Privacy Policy (or when approved by the customer). Additionally, in the event that Vinpearl or substantially all of its assets are acquired by another company, your information will become one of the transferred assets.
  • Protection of ourselves and others: We release account and other personal information when we believe it is appropriate to comply with the law, enforce or apply our terms and agreements others or to protect the rights, property or security of us, our customers, or any other person. The above tasks may include exchanging information with other companies and organizations to prevent and detect fraud and reduce property and credit risk.
  • Subject to your elections: In addition to the above provisions, you will receive notice when personal information about you may be shared with third parties and you will have the right to not consent to such disclosure. share information.

7.2. In cases where legal provisions on protecting the confidentiality of personal information allow an organization the right to collect, use or disclose your personal data without your consent. This regulation will apply to Vinpearl by default.

7.3. In the event a User comes into possession of the personal data of another person through the use of Our Products (“Data Recipient”) hereby agrees that such User will (i) comply with the provisions of personal data protection legislation in relation to these data, including any collection, processing, storage and transfer of these data; (ii) allow Vinpearl or the User whose personal data of the Receiving Party is collected (“Disclosing Party”) to delete the collected User's data from the Receiving Party's database; and (iii) permit Vinpearl or the Data Disclosing Party to review the content collected in relation to them by the Data Receiving Party, in each case (ii) and (iii) above, in compliance with and when required by relevant legal provisions.  

8. Location of personal information

Vinpearl is headquartered in Vietnam and has offices in many countries around the world. Depending on the scope of your interaction with Our Products, your personal information may be stored in or accessed not only in Vietnam but also from many countries. When we transfer your personal information to other countries, we will ensure that it is transferred in accordance with this Privacy Policy and as permitted by applicable laws on privacy.

9. How we protect personal information  

At Vinpearl, security is our highest priority. Our system is designed with the ability to ensure the safety and privacy of your information in an optimal way.

9.1. We have appropriate technical and security measures to prevent unauthorized access and use of personal information. We also regularly coordinate with security experts to update the latest information on network security to ensure the safety of personal information. When collecting data, we store and secure personal information on the server system and this personal information is secured by firewall systems and access control measures, Data encrypt. Although we cannot guarantee absolute security, we also implement various security measures and always make maximum efforts within the allowable scope to ensure the safety of your personal data on the system. system. User personal data is stored behind secure networks and can only be accessed by certain employees with special access rights to our systems.

9.2. Your payment card information issued by financial institutions is protected by us according to international standards with the principle of not recording important payment card data (card number, full name, credit card, CVV number) on our system. Your payment transaction is made on the relevant bank's system.

9.3. We maintain personal data in accordance with the laws on the protection of personal information confidentiality and/or other applicable laws. We will destroy or delete identifying information from your personal data when we receive your request in accordance with applicable Laws or when we have a reasonable reason to determine that (i) the storage of that personal data no longer serves the purpose for which that personal data was collected; (ii) retention is no longer necessary for any legal or business purpose and (iii) there are no other legitimate interests in continuing to retain the personal data. If you stop using our Products, or your right to use the Products and/or Services is terminated or canceled, we may continue to store, use and/or disclose Your personal data is subject to this Policy and our obligations under the laws on the protection of personal information confidentiality. Subject to legal regulations, we may securely destroy your personal data without prior notice to you.

9.4. We reserve the right to refuse to delete or destroy data in cases where your request does not comply with current provisions of law, or in cases where although the request is appropriate, we are not allowed to do so. delete and destroy according to the provisions of Law.

10. Access and selection

10.1. You can view, update and delete certain information about your account and your interactions with Our Products. If you are unable to access or update your information yourself, you can always contact us for assistance.

10.2. You have many choices regarding the collection and use of your personal information. Many of Our Products include functionality that gives you options about how your information is used. You can choose not to provide certain information, but then you may not be able to take advantage of some of Our Products.

  • Account information: If you want to add, update or delete information related to your account, please visit vinpearl.com or contact Vinpearl Customer Care Center via hotline 1900.232.389. When you update or delete any information, we usually keep a copy of the previous version for technical reasons.
  • Communication: If you do not want to receive promotional content from us, please unsubscribe or adjust your communication preferences at vinpearl.com (or other methods as specified in the contract). with customers). If you do not want to receive in-app notifications from us, please adjust the notification settings in your app or device.
  • Advertising: If you do not want to see interest-based advertising, please adjust according to the instructions of the relevant advertising sites (or other methods as specified in the Contract related to you).
  • Browsers 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 your browser notify you when you receive new cookies or how to completely disable cookie functionality.

11. Personal information of adolescents

Parents or legal guardians of adolescents please supervise and ensure that the adolescents under their guardianship do not post or provide personal information to Vinpear. In case personal information of a minor is provided to Vinpear, the parent or legal guardian hereby consents to the processing of the adolescents’ information, and agrees to be subject to correction by the adolescents. This Policy is on behalf of the ward. We will close any accounts used by such children and will remove and/or delete any personal data that we believe has been submitted by any children under 18 years old.

12. Term of storing personal information

We store your personal information to ensure your continued use of Our Products. Retention is maintained for as long as necessary to fulfill the objectives set out in this Privacy Policy, or to comply with legal requirements (including for tax and accounting purposes), or to perform other tasks as notified to you in advance.

The retention period for each specific personal information will vary depending on the purpose of use. Vinpearl will delete your personal information after the storage period expires according to relevant legal regulations.

13. Communications, notices and modifications

13.1. If you have any questions or concerns about privacy or want to contact Vinpearl's information controller, please contact us at the following information:

13.2. In response to changes in production and business activities, this Privacy Policy may also be amended and supplemented from time to time. You should visit and check our website regularly to stay informed of the most recent changes. Unless otherwise stated, our current Privacy Policy applies to all personal information we hold about you and your account. Amendments to this Policy will in no case reduce the level of protection of personal information collected in the past without notifying the customer concerned and giving you the right to choose.

13.3. You have the right to:

  • Withdraw your consent, request restriction, object to the collection, processing, use and/or disclosure of your personal data in our possession or control. by emailing our Personal Data Protection Officer at [email protected], and we will handle these requests in accordance with the Policy and relevant laws.
  • Request us to provide you with your Personal Data; request access to or correction of your Personal Data in our possession or control by submitting a request to our Personal Data Protection Officer using the appropriate form and procedure in accordance with the regulations. provisions of the law. We may charge you a reasonable fee for dealing with and processing your request for personal data. If we do charge a fee, we will provide you with a written fee estimate depending on each individual case. We have the right to refuse to provide or edit your personal data in accordance with the provisions of law on protecting the confidentiality of personal information in cases where such laws require and/or allow an organization to refuse to provide personal data in such cases.

14. Some additional information for Europe

14.1. We provide some additional information about the privacy, collection and use of personal information of our potential and existing customers in European Union countries.

  • Personal Information Controller
    Vinpearl Joint Stock Company (headquarter address at Hon Tre Island, Vinh Nguyen Ward, Nha Trang City, Khanh Hoa) is the controller of personal information collected or processed according to this Privacy Policy.
  • Processing.
    We process your personal information based on one or more of the following legal bases:
    • Where necessary to enter into a contract with you or the organization you represent, to carry out contractual obligations, provide Our Products, respond to requests from you customers, or to provide customer support;
    • To protect our legitimate rights and interests according to relevant laws;
    • In cases necessary to comply with the law and fulfill legal obligations;
    • To respond to lawful requests; or
    • Based on your consent.
  • You can exercise your rights of access, correction, deletion, request for suspension, objection and request for portability of information by contacting us using the contact information in Section 14, Part II of the Policy. this book.

14.2. Where you have given us your consent to process your personal information for a specific purpose, you may withdraw that consent at any time and we will cease any further processing of your data. you for that purpose.

14.3. Transfer information outside the European Union. When we transfer your personal information collected and stored in the European Union outside the European Union, we will do so in accordance with the terms of this Privacy Policy and applicable laws on privacy. This may include data transfers under data transfer agreements containing Standard Contractual Clauses approved by the European Commission.

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