• To maintain and improve Our Website
  We process your Personal Data for maintaining or improving Our Website. For example, we collect and use information of trouble informed by you for tracking system failure and troubleshooting, or we collect and use your usage activity on Our Website for improving the functions of Our Website or develop more convenient for users.
• To develop new products or services
  We process your Personal Data for developing new products or services. For example, we collect and utilize information of how you use Our Website, inquiry from you, or questionnaire results for developing new products or services.
• To provide ads
  We process your Personal Data for showing advertisings. We may also show you personalized ads based on your interests. For example, we collect and use your contact information to send texts to provide ads of our services or products or ads of third-party’s services or products in which you might be interested in.
• To measure and analyze performance
  We process your Personal Data for analyzing and measuring how Our Website are used. For example, we measure and analyze your visits to and activity on Our Website for optimizing Our Website.
• To communicate with you
  We process your Personal Data to communicate with you. For example, we respond to inquiries from you or may send you a notification about Our Website by using contact information provided by you such as email address. In addition, if you contact us, we will keep a record of your request in order to help solve any issues you might be facing.
• To protect us, our users, and the public
  We may process your Personal Data to protect us, you or other users, or the public interest. For example, we use your information to detect and prevent fraud, abuse, or security risks. We may also use your Personal Data to investigate or address claims or disputes relating to Our Website.
• Other Purposes
  We may process User Information for the purposes prescribed in 5. below.

3.2. If you do not provide us with your Personal Data which is necessary for complying with laws or performing the contract between you and us or entering into such contract (e.g., the information required to be entered by you on the
inquiry screen through Our Website), your inquiry may not be accepted, or you may not be allowed to use part of Our Website.

• Our Affiliates
• third-party service providers performing functions or services on our behalf, such as customer support, technical support, or customer management
• third-party IT service providers, such as provider of data storage service or business communication platform service
• third-party advertising service providers

4.2. Except for the recipients prescribed above, we will not disclose your Personal Data to any third party without your prior consent, except where we collected your Personal Data based on any of the legal basis prescribed in 5 below.
4.3. We transfer your Personal Data to any of our Affiliates or third-party service providers outside of Vietnam, such as our data center specified in 6.2. When we transfer it to such entities outside of Vietnam, we ensure that appropriate safeguards and rotections are taken in place pursuant to applicable laws. However, please acknowledge that some countries that we transfer your Personal Data might not have appropriate safeguards and protections under the applicable laws of Vietnam.

• Performance of a Contract / Entry into a Contract.
  Some of Personal Data is processed on the basis that it is necessary for the performance of our agreement with you or for taking steps at your request prior to entering such an agreement. For example, we may request you to provide your email address, login name, login passwords to create your account for using Our Website (if necessary) in order to perform our obligation under service agreement with you.
• Legitimate Interests
  A second ground relied upon by us is that it is necessary for the purposes of legitimate interests pursued by us or a third party. These legitimate interests include the operation of Our Website and our business, maintenance and improvement of Our Website, pursuit of the safety of Our Website, such as fraud detection and prevention, charging the payment regarding the chargeable services, providing ads of our services or products or ads of third-party’s services or products. Further examples are shown in 3. above. We only rely on such a ground where such interests are not overridden by your interests or fundamental rights and freedoms.
• Research or Statistics / Preparation of Historical Documents or Archives for Public Interest
  A third ground relied upon by us is that it is necessary for research or statistics, or preparation of historical documents or archives for the public interest. For example, we may create statistics relating to the business area to which our services belong for the purpose of our own or third-party’s marketing. We only rely on such a ground where the suitable measures to safeguard your rights and freedoms are taken in place and in accordance with applicable law.
• Compliance with a Law
  A fourth ground relied upon by us is that it is necessary for compliance with a legal obligation. For example, we are required to retain records for fixed periods of time in order to comply with applicable laws.
• Prevention of a Danger / Performance of a Task for Public Interest In some rare cases, there may be necessity to prevent or suppress a danger to your or other persons’ life, body, or health, or we may need to perform a task for the public interest.

• • request access to and obtain a copy of your Personal Data
  • receive your Personal Data or request us to send or transfer your Personal Data to other Data Controllers by the automatic means
  • object to the collection, use, or disclosure of your Personal Data
  • request to erase, destroy, or anonymize your Personal Data
  • request to restrict the use of your Personal Data
  • request correction or update of your Personal Data
  • withdraw the consent which you have given to us, except where there is a restriction by law or the contract which gives benefits to you (provided, your withdrawal of consent will not affect the lawfulness of procession made prior to such withdrawal)

• complain to the expert committee with respect to our processing of your Personal Data. If you are not satisfied with how we process your Personal Data, you may contact us through the Contact Details below.

• Performance of a Contract / Entry into a Contact
• Legitimate Interests
• Compliance with a Legal Obligation
• Protection of Vital Interests
• Performance of a Task for Public Interest
• Consent

Please refer to 5. above for more details.
9.3. Automated Individual Decision-Making, Including Profiling
We do not use a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
9.4. Your Rights
If you are located in the European Countries, regarding your “personal data” which we collect and store, you have the rights to:

• access to your “personal data” and related information, such as categories of recipient, envisaged retention period, source of acquisition, and obtain a copy of your “personal data” in our possession
• rectify your inaccurate “personal data”
• erase your “personal data”
• restrict on processing of your “personal data”
• receive your “personal data” which you provided to us and request us to transmit those data to another controller (data portability)
• object to the processing of your “personal data”
• withdraw the consent which you have given to us at any time (your withdrawal of consent will not affect the lawfulness of procession made prior to such withdrawal)
• not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where:
  1. the decision is necessary for entering into, or performance of, a contract between you and us;
  2. the decision is authorized by Union or Member State law to which we are subject, and which also lays down suitable measures to safeguard your rights, freedoms, and legitimate interests; or
  3. the decision is based on your explicit consent.

Those rights may be subject to a certain condition as set forth in the GDPR.
9.5. Data Transfers
We transfer your “personal data” to any of our Affiliates or third-party service providers outside of the European Countries. When we transfer your “personal data” to such entity outside of the European
Countries, we ensure that appropriate safeguards and protections are took in place pursuant to the GDPR. For example, we enter into agreements including standard data protection clauses adopted by the European Commission or other appropriate arrangements with various entities located outside the European Countries with whom we share your “personal data”. However, please acknowledge that some countries that we transfer your “personal data” might not have appropriate safeguards and protections under the GDPR. If we transfer your “personal data” to any of such countries, we will notify you of the possible risks of such transfer for you due to the absence of an appropriate safeguards and obtain your consent with such transfer. If you wish to receive a copy of documentation related to these safeguards, please contact us.
9.6. Complaints
If you are located in one of the European Countries, you may file a complaint with the Data Protection Supervisory Authority of the Member State of your habitual residence, place of work, or place of the alleged infringement.

9.7. Contact
If you are located in one of the European Countries, you may contact us through the following representative for EU area or the contacts set out in 10. below.