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PRIVACY POLICY

FOR VISITORS OF VT SERVICES LIMITED LIABILITY COMPANY’S WEBSITE

VT Services Limited Liability Company (“VT Services”) is committed to protecting Personal Data of users of our Website

(i.e., https://www.vanthiel.com/) (“Website”). This Privacy Policy describes how VT Services manages Personal Data in compliance with the Vietnamese laws (“Laws”).  We encourage you to read this Privacy Policy before you make any interaction with the Website so that you know and understand how and why we collect, use and process your Personal Data.
1.    Application of this Privacy Policy

1.1.    "Personal Data" refers to data, whether true or not, about an individual who can be identified or identifiable

from that data, or from that data in combination with other information to which we may have access and includes the meaning otherwise as defined in the Laws as amended from time to time.

1.2.    For the purposes of the collection of your Personal Data as outlined below, you may be required to provide us

with basic information associated with you, including the following types of personal data (“Basic Personal Data”):


a.    Contact information (e.g., name, residential address, contact address, delivery address postal or e-mail                 address, social media account, fax number and phone number);

b.    Other information associated with you personally;
c.    You may also voluntarily provide other personal data in connection with your inquiries or comments. We                 
encourage you, however, to provide no more personal data relating to you than is necessary in order for               us to provide an appropriate response to your inquiries or comments.

 
At present, we do not collect or process any of your sensitive personal information, which is classified as such under the Laws, e.g., personal location data identified through positioning services (“Sensitive Personal Data”). If, in the future, there arises a need to collect or process any of your Sensitive Personal Data to enhance your experience with us or to meet statutory requirements, we will provide you with prior notification and seek your valid consent (where required) before processing. Both the Basic Personal Data and the Sensitive Personal Data (if processed) are collectively referred to as Personal Data. 

1.3.    By submitting information to or otherwise communicating with VT Services, and explicitly consenting by

taking the affirmative steps and/or actions on our Website or platforms as specifically instructed to you therein, you agree and consent to VT Services and our related entities, affiliates and subsidiaries (individually and collectively, "Companies"), as well as their respective representatives and/or agents (collectively referred to herein as "Van Thiel Group", "us", "we" or "our") collecting, using and processing your Personal Data in accordance with this Privacy Policy. “You” or “your” means any individual to whom the Laws apply and includes our Website’s users such as any employees of prospective customers, any employees of prospective suppliers, vendors, business partners and distributors (“Suppliers”), and/or prospective job applicants. For the purpose of this Privacy Policy, “prospective customers” where “you” have been employed are referred to as “Corporate Customers.”

 

1.4.    This Privacy Policy does not supersede or replace any other consents that you may have previously or

separately provided to us in respect of your Personal Data, and your consent to this Privacy Policy is in addition to any other rights which any of the Companies already has under the Laws.


1.5.    This Privacy Policy and your use of the Website shall be governed in all respects by the Laws.


2.    Collection & Consent


2.1.    Personal Data may be collected from you in one or more of the following ways:


a.    when you visit our Website;
b.    when you input the required information in the contact form on our Website;    
c.    when you post feedback or interact with our customer service officers, e.g. via chatbox, emails, telephone calls, or directly via our social media platforms (which may be recorded for training, quality control, business and/or other lawful purposes);
d.    when you request that we contact you, include you in an email or other mailing lists;
e.    when you respond to our promotions, campaigns or other initiatives, or attend our events;
f.    when you take part in any contest, survey or promotion conducted by us and/or our business partners (including submission of photographs);
g.    when you submit your Personal Data to us for any other reasons; and/or
h.    when we collect your Personal Data by other lawful means.


2.2.    Unless permitted by the Laws, we will not collect, use or process your Personal Data without your consent. W

will limit our collection, use and processing of your Personal Data to what is adequate and relevant to the purposes for which they are needed and to which you have consented. For the avoidance of doubt, unless mandated by the Laws or competent authorities, we will not gather or request you to furnish us with your personal identification number or, when applicable, a copy of your citizen identity card.


2.3.    You warrant and represent to us that (a) Personal Data which you disclose to us is accurate and complete; and

(b) where you volunteer Personal Data of another person to us, that you are authorized by such other person to disclose such Personal Data to us, and that such Personal Data is accurate and complete.


2.4.    In order to provide any information to us or contact or interact with us through the relevant sections on the

Website, you must be 16 years old or older. Access and use of our Website by anyone under the age of 16 is only permitted with the express permission of a parent or legal guardian. If we discover that for whatever reasons and via whatever means, personal data of a child of less than 16 years old is submitted to us without appropriate consent, we reserve the right to erase and/or remove such data from our system without any prior notification to the provider of such data. Furthermore, under such circumstance, we will not owe any obligations to the data subject or the provider of the data.  


2.5.    You are fully informed that we may collect and use your Personal Data without your consent in the

circumstances as set out by the Laws.


2.6.    If you decide to give us a partial or conditional consent on the collection and processing of your Personal

Data, kindly adhere to the instructions provided on our Website or through our relevant communication channels you are engaging with. If you need further assistance in this regard, you can send us a request to the email address of our Data Protection Officer as provided below in Section 12 of this Privacy Policy. We will respond to you on how your case will be addressed and resolved. However, please note that, in order to maintain internal operational efficiency, we retain the right to decline involvement in communication and/or transactions with you if a full consent for data processing is not provided. 


3.    Purposes for which we collect, use and disclose your Personal Data


3.1.    Your Personal Data may be collected, used and/or processed for the following purposes:


a.    to verify and process your personal particulars;
b.    to explore potential business and/or employment opportunities with you; 
c.    to provide products and services to our Corporate Customers;
d.    to respond and deal with enquiries, complaints and other customer-care matters or otherwise communicate with you;
e.    to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
f.    to send you information, promotions, updates, and marketing and advertising materials in relation to our products and services and that of our group companies;
g.    to manage, develop and improve our business and operations to serve our Corporate Customers better;
h.    to carry out marketing promotions and campaigns, contests and lucky draws for our Corporate Customers;
i.    to carry out market research and customer surveys;
j.    to conduct investigations or audits or carry out crime and fraud prevention and risk management activities;
k.    to comply with legal and regulatory requirements;
l.    to enforce our legal rights and obligations;
m.    to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales);
n.    for other purposes for which we have obtained your consent; and
o.    for any other purposes reasonably necessary, ancillary or related to the above specified purposes.


3.2.    Your Personal Data may be disclosed for the purposes indicated above to our officers and employees, third

parties, affiliates, service providers, advisors, which include without limitation, the following persons or entities:


a.    banks, credit card companies, and payment vendors;
b.    debt collection agencies;
c.    credit information companies;
d.    logistics and courier services companies;
e.    call centre services providers;
f.    our business partners and authorised distributors, dealers or resellers;
g.    relevant government regulators or authorities or law enforcement agencies;
h.    our insurers and advisors, including consultants, auditors and lawyers;
i.    data intermediaries; and
j.    any other party whom you authorise us to disclose your Personal Data to. 

Save for relevant government regulators and authorities or law enforcement agencies, we will ensure that such parties receiving your Personal Data (i) are under a duty of confidentiality to us with respect to the use, holding, processing, retention and/or transfer of your Personal Data; and (ii) have the need to know or handle such Personal Data.


3.3.    Likewise, we will only collect, use and/or process your Personal Data for marketing purposes where you have

consented to us doing so after being informed of such purposes and the consequences of providing consent.


3.4.    Your Personal Data may be transferred, stored and/or processed in a country or territory outside Vietnam for

various purposes, including international customer support, service improvements, backup, data storage, improvement of your experience with us, and the fulfillment of our legal business objectives.


3.5.    Accordingly, you acknowledge and agree that the transfer, storage, and/or processing of your Personal Data

outside Vietnam may be necessary for the aforementioned purposes and any other purposes as described in this Privacy Policy and accordingly, you hereby consent to any such transfer, storage and/or processing of your Personal Data outside Vietnam. 


4.    Withdrawal of Consent & Access    


4.1.    You may withdraw your consent to our continued use and processing of your Personal Data or seek access to

your Personal Data (to a reasonable extent and as permitted by the Laws) at any time by writing to our Data Protection Officer with the contact details provided in Section 12 below. 


4.2.    In withdrawing your consent, you acknowledge that we may not be able to interact or continue interacting

with you or provide or continue providing certain products and/or services to the Corporate Customer you are affiliated with, and that we may cease such provision accordingly without any liability. Please note that it may take up to 30 days for any request for consent withdrawal to be reflected in our systems. We thereafter will discontinue the collection and processing of your Personal Data and will request relevant third parties, as mentioned in Clause 3.2 above, to also cease collecting and processing your Personal Data accordingly. 


4.3.    We reserve the right to charge a reasonable administrative fee for carrying out your request, where

permitted to under the Laws.


5.    Accuracy & Correction


5.1.    We will endeavour to ensure that your Personal Data we use is sufficiently accurate and complete in making

any decision that impacts you.


5.2.    To help us maintain the accuracy of your Personal Data, we encourage you to inform us when there are any

changes to your Personal Data which you have provided us by writing to the Data Protection Officer with the contact details provided in Section 12. Upon receiving your request for correction of your Personal Data, we will promptly update or complete the necessary changes. In the event that an immediate correction is not possible, we will notify you within 72 hours after receiving your request.

 

6.    Protection, Policies and Procedures


6.1.    We will endeavour to protect your Personal Data in our possession or control against risks of unauthorised

access, collection, use, disclosure, copying, modification, disposal or destruction, through reasonable and appropriate security measures. We strive to ensure that our systems are secure and that they meet industry standards. To prevent unauthorised access, maintain data integrity and confidentiality, and ensure the correct use of information, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Data we collect. Notwithstanding our security measures for protecting your Personal Data, you acknowledge that no data transmission over the Internet is completely secure and by providing your Personal Data, you are transmitting information at your own risk.


6.2.    In order to fulfil our obligations under the Laws, we may be required to conduct a data protection impact

assessment report regarding the collection and processing of your Personal Data. This assessment report will be prepared in accordance with legal requirements and may need to be submitted to the relevant competent authorities as mandated by the Laws. Our aim is to ensure compliance with the legal framework and safeguard the privacy and security of your Personal Data as prescribed by the Laws.


7.    Retention and Deletion of Personal Data


7.1.    We will retain your Personal Data for as long as it is necessarily required or relevant for business or legal

purposes. 


7.2.    You are entitled to request the erasure or removal of your Personal Data in accordance with the Laws.


7.3.    We will carefully assess the grounds for your erasure request and take appropriate measures, including

technical measures, to address it. Please note that immediate removal of information from backup systems may not be possible due to legal restrictions and/or technical limitations. If this is the case, we will securely store your personal data and isolate it from any further processing until the backup can be cleared or made anonymous. However, we will make every effort to ensure that the requested data is completely deleted within 72 hours of receiving your deletion request, unless circumstances justify a refusal as outlined by laws.


7.4.    We will cease to retain and delete or anonymise your Personal Data once the purpose of collection has been

fulfilled, or after we confirm your request for erasure, unless we are mandated to retain your Personal Data under the Laws in some specific circumstances.


7.5.    Please note that if your Personal Data is erased due to reasons, such as the completion of the collection and

processing of data no longer being necessary for our business operations, or in the unlikely event of VT Services being liquidated, bankrupt, or ceasing operations in accordance with the Laws, the data will be permanently erased and cannot be retrieved after the erasure process is completed. 


7.6.    However, there are statutory exceptions for the deletion of your Personal Data even upon your request. In

these circumstances, we may retain this type of information for a longer period than the standard retention period, as permitted by the Laws, even if further data processing is not directly related to the original purpose of collection.

 

8.    Other rights to Your Personal Data


Regarding your Personal Data, amongst others, you have the following entitlements as set out by the Laws:


8.1.    Be provided with your Personal Data. 

You have the right to request a copy of the Personal Data we hold about you.
Please be advised that if you wish to obtain the Personal Data that we have collected from you and currently process, you are required to contact our Data Protection Officer as provided below in Section 12 of this Privacy Policy and complete and sign a standard request form provided. Once you have filled out and signed the form, please send it to the email address of our Data Protection Officer. We will only provide you with the requested data upon receipt of your completed and signed request form, ensuring that it satisfies the requirements of the Laws. 
If you are illiterate or disabled and cannot complete the request form, please contact our Data Protection Officer as provided below in Section 12 of this Privacy Policy so that we can assist you to complete the request form. 


8.2.    Restrict the continuation of collecting and processing your Personal Data. 


8.3.    Object to the disclosure of any of your Personal Data to any third parties, unless we have already had your

consent to do so, or we are legally required to do so.


9.    Processing Personal Data of individuals who have been declared deceased or being missing 


In the event of you being declared deceased or being missing by a competent authority as set out in the Laws, we recognise the significance of protecting your Personal Data. We understand the sensitive nature and privacy considerations surrounding such circumstances, and we are dedicated to upholding the confidentiality of your information. Consequently, we will only further process your Personal Data upon receiving written consent from your spouse or children above the age of 18, or from your parents if the aforementioned individuals are not available. 


10.    Cookies


10.1.    We gather information on our Website’s activities, such as IP address of the visitors, data on the number of

visitors, the pages they visit, the duration of their stay, etc. Such information is collected on an aggregate, anonymous basis, and gathered through the use of web server logs and cookies. We may collect your Personal Data through your IP address and upon your input of your Personal Data in the contact form on our Website.


10.2.    Cookies are small bits of data automatically stored in the hard drive of the end user and are commonly used

to track preferences in relation to the subject of such website. If you enable these cookies, then your web browser will store a text file (piece of code) on your device. You may wish to set your web browser to notify you of a cookie placement request or refuse to accept cookies by modifying relevant internet options or browsing preferences of your computer system, but in doing so you may not be able to utilise or activate certain available functions on our website.


10.3.    By accessing and using our Website, products and services, you consent to the storage of cookies, other

local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents. Should you wish to dissent, kindly follow the specific instructions provided on the Website or the cookie notification.   


11.    Third Party Links and Products on Our Services


Our Website may link to third-party websites and services that are outside our control. For example, we may enable you to share certain materials on our products and/or services with others through social networking services such as Facebook. We are not responsible for the security or privacy of any information collected by third-party websites or other services. You should exercise caution, and review the privacy statements applicable to the third-party websites and services that you use. To the fullest extent permitted under the Laws, we cannot be responsible for a third party's acts, omissions, data policies or their use of cookies nor the content or security of any third-party websites, even if linked to our Website. Any such liability is expressly disclaimed and excluded.


12.    Contact us


We have appointed Data Protection Officer(s) to oversee our compliance with the Laws. Should you have any query, request or feedback relating to your Personal Data, please contact us at the following addresses:


Data Protection Officer
VT Services Limited Liability Company

Lily 19, No. 36 Thao Dien, Thao Dien Ward, Thu Duc City, 
Ho Chi Minh City, 
Vietnam.
Email:  personaldata@vanthiel.com 


13.    Update to the Privacy Policy


We reserve the right to modify or update this Privacy Policy from time to time.  Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time. The date stated at the bottom of this Privacy Policy indicates the last time this document was revised. We encourage you to check back regularly for the latest version of this Privacy Policy. 

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