COMMITMENT TO CONFIDENTIALITY AND PERSONAL DATA PROTECTION

Latest updates: 25/04/2025

In accordance with Decree No. 13/2023/ND-CP of the Government on Personal Data Protection, effective from July 1, 2023, VNETWORK understands the importance of Personal Data entrusted to VNETWORK by partners, customers, and users, and is committed to fulfilling its responsibilities related to personal data protection in compliance with legal regulations.

Furthermore, respecting the privacy rights of all partners, customers, and users with respect to VNETWORK’s products, services (“Services”), and website (“Website”) is an integral part of this commitment.

The commitment to personal data protection is made by and between VNETWORK and its valued partners, customers, and users (collectively referred to as “Customers”).

I - DEFINITIONS

1.1 This Personal Data Protection Commitment (“Commitment”) is designed to help partners, customers, and users understand the purposes and methods by which VNETWORK processes Customers’ Personal Data, as well as to assist Customers in making informed decisions before allowing us to process any of their Personal Data.

1.2 By using the Services, registering an account, or accessing VNETWORK’s website system, Customers voluntarily agree to comply with personal data protection regulations and permit VNETWORK to process their Personal Data as described in this Commitment.

1.3 IF CUSTOMERS DO NOT AGREE OR AUTHORIZE VNETWORK TO PROCESS THEIR PERSONAL DATA AS DESCRIBED IN THIS COMMITMENT, PLEASE DO NOT USE VNETWORK’S SERVICES OR WEBSITE.

1.4 We reserve the right to amend or supplement this Commitment at any time. Depending on the purpose, scope, and content of such amendments, we may notify Customers, seek their consent, or proceed without consent, in accordance with applicable personal data protection laws at the time.

1.5 Abbreviations and definitions:

  • “Services” refer to any products or services provided by VNETWORK.

  • “Personal Data” refers to information in the form of symbols, text, numbers, images, sounds, or similar forms in an electronic environment that is associated with a specific individual or helps identify a specific individual. Information that helps identify a specific individual is data generated from an individual’s activities that, when combined with other stored data or information, can identify a specific individual. Personal Data includes Basic Personal Data and Sensitive Personal Data (as per Decree 13/2023/ND-CP).

  • “Processing Personal Data” refers to one or more activities affecting Personal Data, such as collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, recovery, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction of Personal Data, or other related actions.

II – WHEN VNETWORK COLLECTS PERSONAL DATA

2.1 VNETWORK will/may collect Customers’ Personal Data:

  • When Customers register and/or use VNETWORK’s Services or Website;

  • When Customers submit any forms, including but not limited to applications or other forms related to VNETWORK’s products and services, whether online or otherwise;

  • When Customers enter into any agreements or provide documents or information related to their interactions with VNETWORK, or when Customers use our products and services;

  • When Customers interact with us, such as through phone calls (which may be recorded), letters, faxes, face-to-face meetings, social media platforms, and emails;

  • When Customers use VNETWORK’s Services or interact with us via phone, Website, or Services, including but not limited to through cookies that we may deploy when Customers interact with our Services or Website;

  • When Customers provide feedback or submit complaints to VNETWORK, respond to customer inquiries, or participate in customer surveys;

  • When Customers register for promotional programs;

  • When Customers provide their Personal Data to VNETWORK for any reason;

  • When conducting promotional activities related to VNETWORK’s products and services.

2.2 The above are common instances where VNETWORK collects Customers’ Personal Data but do not cover all possible cases.

III – WHAT DATA VNETWORK COLLECTS

3.1 VNETWORK collects only Customers’ Basic Personal Data, which may include one or more of the following:

  • Full name, email address, residential address, phone number, gender;

  • Information from identification documents (ID card, citizen identification, passport, issuance date, and place of issuance);

  • Payment method information, excluding customer information from credit institutions, foreign bank branches, intermediary payment service providers, or other authorized organizations;

  • Information sent by or related to the device(s) used to access VNETWORK’s Services;

  • Any other information about Customers when they log in to use VNETWORK’s Services, as well as information about how Customers use the Services;

  • Aggregated data about the content used by Customers.

3.2 Customers are responsible for providing complete and accurate Personal Data and agree not to provide us with any inaccurate or misleading information. Customers agree to notify VNETWORK of any inaccurate information or changes to their information. VNETWORK reserves the right to request additional necessary documents to verify the information provided by Customers.

3.3 Other data collection: As with most websites, when Customers submit information, it may include data about Customers recorded by a server when using VNETWORK’s Services. This information typically includes but is not limited to IP address, computer/mobile device operating system, browser type, mobile device type, referring website address (if any), pages visited on VNETWORK’s website or system, access time, and sometimes “cookies” (which can be disabled using browser settings) to help the website remember Customers’ last visit. If Customers log in, this information is linked to their personal account. This information is also included in anonymous statistics to help us understand how customers access and use our Services and Website.

3.4 VNETWORK’s Services may use technologies such as Camera API or similar technologies provided by the mobile device’s operating system to record facial expression information for in-app features. Such information is not used for any purpose other than the provided in-app features. Customers may refuse to grant camera access for these features at any time (note that disabling camera access may prevent some app features from functioning). We do not store or share this information with third parties.

3.5 We may occasionally use “cookies” or other features to allow us or third parties to collect or share information to improve our Website and Services, or to offer new services and features. “Cookies” are identifiers sent to Customers’ computers or mobile devices, enabling us to recognize their devices and track usage or access to our Services or Website, including the number of users and their activities.

IV – HOW VNETWORK USES CUSTOMERS’ PERSONAL DATA

VNETWORK may process Customers’ Personal Data for one or more of the following purposes:

4.1 Reviewing and/or processing Customers’ applications/transactions with us or their transactions or correspondence with third parties via the Services;

4.2 Managing, operating, providing, and/or administering Customers’ use of and/or access to our Services and Website (including but not limited to) their preferences, as well as their relationship and user account with us;

4.3 Responding to, processing, resolving, or completing a transaction and/or fulfilling Customers’ requests for certain products and services and notifying Customers about service issues and unusual account activities;

4.4 Enforcing our Terms of Service or any applicable end-user license agreements or terms of use;

4.5 Protecting personal safety and the rights, property, or safety of others;

4.6 Identification and/or verification;

4.7 Maintaining and managing any software updates and/or other updates and support that may be required from time to time to ensure the smooth operation of our Services;

4.8 Resolving or facilitating customer service, executing Customers’ instructions, addressing or responding to any inquiries submitted by (or purportedly submitted by) Customers or on their behalf;

4.9 Contacting or communicating with Customers via phone, text messages, and/or fax messages, email, and/or mail or otherwise for the purpose of administering and/or managing their relationship with us or their use of our Services, such as but not limited to conveying administrative information related to our Services. Customers acknowledge and agree that such communication by us may involve sending correspondence, documents, or notices via postal mail, which may include disclosing certain Personal Data about Customers to provide those documents as well as on the packaging/envelope;

4.10 Notifying Customers when another user has sent them a private message or posted a comment for them on the Website;

4.11 Conducting research, analysis, and development activities (including but not limited to data analysis, surveys, product and service development, and/or profiling) to analyze how Customers use our Services, improve our Services or products, and/or enhance Customers’ experience;

4.12 Complying with legal procedures or adhering to applicable laws and requirements of competent state authorities;

4.13 Compiling statistics and research to meet reporting and/or internal record-keeping requirements or regulations;

4.14 Conducting due diligence and other screening activities (including but not limited to background checks) in accordance with legal or regulatory obligations or our risk management procedures, which may be required by law or implemented by us;

4.15 Auditing our Services or VNETWORK’s operations;

4.16 Preventing or investigating any actual or suspected violations of our Terms of Service, fraudulent, unlawful, negligent, or wrongful activities, whether related to Customers’ use of our Services or any issues arising from their relationship with us;

4.17 Storing, hosting, or backing up (whether for disaster recovery or other purposes) Customers’ Personal Data;

4.18 We may process Customers’ Personal Data as circumstances require, possibly for purposes not listed above. However, we will notify Customers of such other purposes when seeking their consent, unless processing without consent is permitted under applicable laws.

V – PRINCIPLES OF PERSONAL DATA PROTECTION

We always prioritize compliance with personal data protection laws, and thus VNETWORK focuses on implementing various security measures and strives to ensure the safety of Customers’ Personal Data on our systems:

5.1 Users’ Personal Data is stored behind modern secure networks (such as encryption, firewalls, access control systems) and can only be accessed by a limited number of employees with special access rights to VNETWORK’s systems. However, absolute security cannot be guaranteed.

5.2 VNETWORK commits not to share, sell, or exchange Customers’ Personal Data with third parties without their consent, except in cases permitted under this Commitment or as required by competent state authorities in accordance with legal regulations.

5.3 VNETWORK ensures that employees and partners with access to data do so only when necessary and must comply with confidentiality policies.

5.4 VNETWORK will maintain Personal Data in accordance with personal data protection laws and/or other applicable legal regulations. This means that VNETWORK will delete or destroy Customers’ Personal Data when there is reasonable grounds to determine that:

  • Retaining such Personal Data no longer serves the purpose for which it was collected;

  • Retention is no longer necessary for any legal or business purpose, and there are no other legitimate interests in continuing to retain such Personal Data and/or in any other cases as stipulated by law.

  • If Customers cease using VNETWORK’s Services, or their right to use the Website and/or Services is terminated or withdrawn, we may continue to store, use, and/or disclose their Personal Data in accordance with this Policy and our obligations under personal data protection laws and/or other applicable legal regulations.

  • Subject to applicable laws, we may securely destroy Customers’ Personal Data without prior notice to them.

  • Customers’ request to delete Personal Data: Customers may request that we delete their Personal Data that we have collected by sending an email to our Personal Data Protection Department at support@vnetwork.vn in cases where: Customers believe it is no longer necessary for the purpose of collection and accept any potential damages from requesting deletion; Customers believe their Personal Data must be deleted under legal regulations. Customers should note that Vietnamese law mandates service providers like VNETWORK to retain users’ information and Personal Data for a minimum of two (2) years (“Retention Period”) from the last time the user used the service; therefore, requests to delete Customers’ Personal Data can only be fulfilled after the end of the Retention Period. We will endeavor to delete Customers’ Personal Data within 30 days from the date of their request and the end of the Retention Period, or notify Customers if this requires additional time.

5.4 Requests to access or correct Personal Data

Customers have the right to access, correct, or update their Personal Data. We reserve the right to refuse to correct Customers’ Personal Data in accordance with personal data protection laws, where such laws require and/or permit an organization to refuse to correct Personal Data in such circumstances.

5.5 Retention period of Personal Data

We store Customers’ Personal Data throughout their use of the Services and continue to store it for three (3) years from the last time Customers accessed and/or used the Services (“Retention Period”). This Retention Period may be extended in cases where such information is necessary for us to provide Services to Customers, or as required or permitted by law, such as regulations on taxation, accounting, or auditing.

5.6 Restricting the processing of Personal Data to storage only

Customers have the right to request that we limit the processing of their Personal Data that we hold to storage purposes only by sending an email to our Personal Data Protection Department at support@vnetwork.vn, when:

  • Customers believe their Personal Data is inaccurate, for the time necessary for us to verify whether their Personal Data is accurate.

  • We intend to delete Customers’ Personal Data, but Customers want us to store it only.

  • We intend to delete Customers’ Personal Data as it is no longer necessary for our purposes, but Customers request storage to establish, exercise, or defend legal claims; or

  • Customers object to our processing of their Personal Data based on our legitimate interests, and Customers want us to cease processing the Personal Data while we determine whether it is critical to process and retain such Personal Data.

If Customers have any questions or concerns about this Policy, please contact us at support@vnetwork.vn.

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