CONFIDENTIALITY

CONFIDENTIALITY

1.INTRODUCTION

1.1.  Welcome to the XinhTuoi.Online platform (including the Xinh Tuoi Online website and mobile application) operated by F5 Online Trading Technology Co., Ltd and its affiliates (collectively and individually) is, "Xinh Tuoi Online", "we", or "our"). Xinh Tuoi Online seriously performs its responsibilities related to information security in accordance with the provisions of Vietnamese law on privacy protection of personal information (“Privacy Law”) and is committed to respecting privacy rights. The investment and interest of all users in the Beautiful Online Platforms (“Platforms”) (we collectively refer to the Platforms and the services we provide as described in our Platforms). means "Services"). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to appropriately manage, protect and process your personal data. This Privacy Policy ("Privacy Policy" or "Policy") is designed to help you understand how we collect, use, disclose and/or process the personal data you collect. You have provided us and/or kept about you, whether now or in the future, and to help you make an informed decision before providing us with any personal data. any of your customers.

1.2.  ""Personal Data" or "personal data" means data, whether true or not, about an individual through which an identity can be identified, or from such data and other information. that an organization has or has the ability to access. Common examples of personal data may include name, national identification number and contact information.

1.3.  By using the Services, registering for an account with us, or accessing the Platform, you acknowledge and agree that you accept the methods, requirements, and/or policies described in This Privacy Policy, and you hereby consent to our collection, use, disclosure and/or processing of your personal data as described herein. IF YOU DO NOT AGREE TO THE PERMIT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM OR SITE. If we change our Privacy Policy, we will post those changes or the revised Privacy Policy on our Platform. We reserve the right to amend this Privacy Policy at any time.

2. WHEN WILL XINH TUOI ONLINE COLLECT THE DATA ?

2.1.  We will/may collect personal data about you: :

a. when you register and/or use our Services or Platforms, or open an account with us;

b. when you submit any form, including, but not limited to, application or other forms in connection with any of our products and services, either online or in other mode;

c. when you enter into any agreement or provide documents or other information relating to your interactions with us, or when you use our products and services;

d. when you interact with us, such as through phone calls (which may be recorded), correspondence, faxes, face-to-face meetings, email and social media platforms;

e. when you use our electronic services, or interact with us through the Platform or the Website or our Services. This includes, but is not limited to, through cookies that we may deploy when you interact with our Platforms or Websites;

f. when you make transactions through our Services;

g. when you provide feedback or submit a complaint to us; ;

h. when you register to enter a contest;

i.  when you submit your personal data to us for any reason. .

The above are just some of the common cases in which we collect your personal data, and do not reflect all of the circumstances in which we will collect your personal data.

3. WHAT DATA WILL US COLLECT ?

3.1.  Personal data that Xinh Tuoi Online may collect includes, but is not limited to:

a. full name;

b. email address;

c. Date of birth;

d. Payment address;

e. bank account and payment information;

f. phone number;

g. Sex;

h. Information sent by or relating to the device(s) used to access our Services or Platforms.

i.  any other information about the user when the user logs in to use our Services or Platforms, and when the user uses the Services or Platforms, as well as information about the user's use How are our Services or Platforms; and

j.  aggregated data about user content.aggregated data about user content.

3.2.  You agree not to provide us with any information that is inaccurate or misleading and you agree to notify us of any inaccurate or misleading information. . We reserve the right in our sole discretion to request other necessary documents to verify the information provided by you.You agree not to provide us with any information that is inaccurate or misleading and you agree to notify us of any inaccurate or misleading information. . We reserve the right in our sole discretion to request other necessary documents to verify the information provided by you.

3.3.  If you log in to become a User of our Platforms using your social media account (“Social Network Account”), link your account to your Social Network Account or use any Social Media feature, we have the right to access information about you that you have voluntarily provided to a Social Media Account service provider. Your personal data is subject to the policies of these service providers, and we will manage and use your personal data in accordance with the provisions of this Policy at all times.

3.4.  If you do not want us to collect the aforesaid personal information/data, you may opt out at any time by notifying our Data Protection Officer in writing. More information about the content can be found under "how can you withdraw permission to remove your name, request access or correct information you have provided to us?" down here. Note, however, that denying or canceling your permission to us to collect, use or process your personal data may affect your use of the Services and the Platform. For example, location services will not work if you do not allow the application to access your location.

4. COLLECT OTHER DATA

4.1.  As with most websites and other mobile applications, your device sends information that may include data about you, which is recorded by a web server when you use our Platform. . This information generally includes but is not limited to IP address, computer/mobile operating system, browser type, mobile device type, mobile device characteristics, device identifier uniform device identifier (UDID) or mobile device identifier (MEID) of your mobile device, the Site's reference address (if applicable), the pages you have visited on the Site, or our mobile application and visit time and sometimes "cookies" (which can be disabled using your browser preferences) to help the website remember your last visit guest. 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.

4.2.  Our mobile applications may 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, location-based services that you request or transfer. content that is relevant to you based on your location or allows you to share your location with other Users as part of the Services offered by mobile applications. our move. For most mobile devices, you can withdraw your permission for us to collect this information based on your location through your device's settings. If you have any questions about how to disable location services on your mobile device, please contact your mobile device service provider or device manufacturer. Guest.  

5. COOKIES

5.1.  We may sometimes use "cookies" or other features to enable us or third parties to collect or share information that will help us improve our Platform and the Services we provide provide, or help us roll out new services and features. "Cookies" are identifiers we send to your computer or mobile device that allow us to identify your computer or device and let us know when the Services or Platforms are available. used or accessed, by how many people and to track activities within our Platforms. We may associate cookie information with personal data. Cookies are also associated with information about the content you have selected for the shopping pages you have viewed, or the games you have played. This information is used for shopping cart tracking, for example. Cookies are also used to deliver content based on your interests and to track usage of the Services.

5.2.  You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note, however, that if you do this you may not be able to use the full functionality of the Platform or our Services.

6. VIEW AND DOWNLOAD CONTENTS AND ADVERTISING

6.1. Because when you view pages on our website or mobile application, when you view content and advertising, and access other software on our Platform or through the Service, the much of the same information will be sent to us (including, but not limited to, IP address, operating system, etc.); but, instead of page views, your device sends us information about the content, advertisements viewed and/or software installed on the Services and Platforms and when.

7. HOW WE USE THE INFORMATION YOU PROVIDE US?

7.1.  We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

a. to review and/or process your application/transaction with us or your transaction or correspondence with third parties via the Services;

b.to administer, operate, provide and/or administer your use and/or access to our Services and Platforms (including without limitation, your preferences), as well as your relationship and user account with us;

c. to respond to, process, settle or complete a transaction and/or respond to your requests for certain products and services and to notify you of service issues and unusual account activity;

d.to enforce our Terms of Service or any applicable end user license agreement;

e. to protect personal safety and the rights, property or safety of others;

f. for identification and/or verification;

g. to maintain and manage any software updates and/or other updates and support as may be required from time to time to ensure the smooth functioning of our Services; ;

h. to address or facilitate customer service, carry out your instructions, resolve or respond to any enquiry submitted by (or intended to be submitted by) you or on your behalf;

i.  to contact you or communicate with you by phone, text message and/or fax message, email and/or mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you in connection with our Services. You acknowledge and agree that our communications may be by way of mail, documents or notices to you, which may include disclosure of certain personal data about you. you to provide such documents as on the package/envelope;

j.  to notify you when another user has sent you a private message or posted a comment to you on the Platform;;

k. to conduct research, analysis and development activities (including, but not limited to, data analysis, surveying, product and service development and/or characterization), to analyze how you use our Services, to improve our Services or products and/or to improve your customer experience;

l.  to enable advertising and other tests and surveys, among other things, to validate the size and composition of the survey audience, and understand their experience with the Fresh Online Services;

m.  for marketing purposes, in this case, to send you through various communication methods, marketing and promotional information and materials relating to products and/or services (including, (but not limited to, the products and/or services of third parties with which Xinh Tuoi Online may cooperate or affiliated) may sell, market or promote, whether such products or services exist now or be created in the future. You may unsubscribe from marketing communications at any time by using the unsubscribe function in electronic marketing materials. We may use your contact information to send newsletters from us or from our related companies;

n. to respond to legal proceedings or to comply with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction, including, without limitation in, meet the disclosure requirements under any law applicable to Xinh Tuoi Online or its companies or affiliates;

o. to prepare statistics and research to meet reporting requirements and/or maintain internal or regulatory records;

p. to perform discovery and verification or other screening activities (including, but not limited to, background checks) in compliance with regulatory or regulatory obligations or audit procedures. our risk control, which may be required by law or which may be applied by us;

q. to check our Services or our operations;

r.  to prevent or investigate any fraudulent, illegal, omission or misconduct, whether or not related to your use of our Services or any other matter whatsoever arising out of your relationship with us, and whether or not there is any doubt about the foregoing

s. to store, host, back up (whether for disaster recovery or other purposes) of your personal data, whether within or outside your region;

t.  to process and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves Xinh Tuoi Online as a party or only one Company or affiliates of Xinh Tuoi Online as a party to or related to Xinh Tuoi Online and/or any one or more companies or affiliates of Xinh Tuoi Online such as the party(s), and there may be other third party organizations involved in such a transaction. "Business Asset Transactions" mean the purchase, sale, lease, merger, consolidation or any other acquisition, liquidation or financing of an entity or part of an entity, or of any business or property of an organization; and/or

u. any purpose for which we notify you at the time of obtaining your permission. (collectively, the “Purposes”).

7.2.  As the Purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless the applicable data processing without your consent is permitted under the following provisions. provisions of the law on the protection of privacy of personal information or in accordance with the provisions of the law.

8. HOW TO PROTECT CUSTOMER INFORMATION ONLINE

8.1.  We implement various security measures to ensure the safety of your personal data on our systems. Users' personal data is stored behind secure networks and can only be accessed by certain employees with special access rights to our systems. We will maintain personal data in accordance with the provisions of the law on the protection of privacy of personal information and/or other applicable laws. That is, we will destroy or remove identifying information from your personal data when we have reasonable grounds to determine that (i) retention of such personal data is no longer in service. the purpose for which such personal data is collected; (ii) retention is no longer required for any legal or business purpose and (iii) there is no longer any other legitimate interest to continue to retain this personal data. If you stop using our Platform, or your right to use the Platform and/or Services is terminated, we may continue to save, use and/or disclose personal data Your personal information is subject to this Privacy Policy and our obligations under the laws on the protection of the confidentiality of personal information. Subject to the law, we may safely destroy your personal data without prior notice to you.

9. DO YOU DISCOVER INFORMATION COLLECTED FROM CUSTOMERS TO OUTSIDE PARTIES?

9.1.  In the course of doing business, we will/may need to disclose your personal data to third party service providers, agents and/or affiliated companies or companies. our related companies, and/or other third parties, whether within or outside Vietnam, for one or more of the foregoing Purposes. Such third party service providers, agents and/or affiliates or related companies and/or other third parties will process your personal data or on our behalf. or otherwise, for one or more of the foregoing Purposes. Such third parties include, but are not limited to:

a. our subsidiaries, affiliates and related companies;

b. contractors, agents, service providers and other third parties we hire to support or supplement our business. These parties include, but are not limited to, those who provide administrative or other services to us such as postal companies, telecommunications companies, information technology companies, e-commerce operations, and data centers;

c. purchaser or other successor in the event of a merger, divestment, restructuring, reorganization, dissolution, or sale or transfer of part or all of Xinh Tuoi Online's assets, whether an ongoing matter is out or is in bankruptcy, liquidation or similar proceedings, where the personal data Xinh Tuoi Online holds about our users is part of transferred assets; or to a counterparty in a business asset transaction with which Xinh Tuoi Online or any of its affiliates or related companies is involved in the transaction; and và

d. third parties to whom we disclose information for one of the Purposes and such third parties will in turn collect and process your personal data for one or more Purposes

9.2.  T This may require, among other things, sharing statistical and demographic information about the User and the user's use of the Services with advertising and programming partners. . We will also share statistical and demographic information about our users and their use of the Services with programming and advertising service providers. This case will not include any information that could be used to specifically identify you or disclose personal information about you.

9.3.  For the avoidance of doubt, in the event that privacy laws or other applicable laws permit an organization such as us to collect, use or disclose data personally without your consent, such permission by law will continue to apply.

9.4.  Third parties may intercept or gain unauthorized access to personal data submitted to or contained on the website, technologies may not work correctly or not as intended, or may be accessed by someone. , misuse or misuse information through no fault of ours. However, we will implement reasonable security measures to protect your personal data in accordance with the provisions of the law on privacy protection of personal information; however, absolute security cannot be guaranteed such as, but not limited to, where unauthorized disclosure arises from hacker activity because of malicious intent or the complexity of malicious content through no fault of our own.

10.  INFORMATION ABOUT CHILDREN

These Services are not intended for use by children under 10 years of age. We do not knowingly collect or keep any personal data or non-personally identifiable information from anyone under the age of 10, nor does any part of our Platform or other Services for children under 10 years old. We will lock down any accounts used solely by such children and will remove and/or delete any personal data we believe has been submitted by any children under 10 years old.

11.  INFORMATION COLLECTED BY THIRD PARTIES

11.1. Our platform uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyze how users use our Platform. The information generated by the cookie about your use of the Platform (including your IP address) will be sent to and stored by Google on servers in the United States. Google will use this information to evaluate your use of our Platform, compile reports on website activity for website operators, and provide other services related to website activity. web and Internet use. Google may also send this information to third parties where required by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data that Google holds.

11.2. We, and third parties, may from time to time make downloads of software applications available to you for use by the Platform or through the Services. These applications may privately access, and allow a third party to view, your identifying information, such as your name, user ID, your device's IP Address, or other information such as the game you are playing during any given session, and any cookies you may have previously set or have been set for you by a software application or website. third-party websites. In addition, these applications may ask you to provide additional information directly to third parties. Third party products or services offered through these applications are not owned or controlled by Xinh Tuoi Online. you should read the terms and other policies published by such third parties on their websites or elsewhere.

12.  DISCLAIMER OF SECURITY OBLIGATIONS AND THIRD PARTY SITES

12.1. WE DO NOT GUARANTEE THE SECURITY OF THE PERSONAL DATA AND/OR OTHER INFORMATION YOU PROVIDE ON THIRD PARTY SITES. We implement various security measures to maintain the safety of your personal data that we hold or control. Your personal data is stored behind secure networks and can only be accessed by a limited number of individuals who have special access rights to our systems, and are required to be secure. that personal data. When you place an order or access your personal data, we recommend the use of a secure server. All personal data or personal information you provide will be encrypted into our databases for access only as described above.

12.2. In order to provide you with added value, we may select various third-party websites or applications or services to link to, and frame within the Platform. We may also enter into co-marketing and other relationships to provide e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies and security measures. Even if such a third party is affiliated with us, we do not control these linked websites/applications/services, each of which has its own privacy protection and data collection practices. separate material, independent of us. Data collected by our co-marketing partners or third party websites/apps/services (even if made available on or through our Platform) may not be accessible to us. I access and/or keep.

12.3. We therefore assume no responsibility or liability for the content, security practices (or lack of security measures) and the operations of these linked websites/applications/services. . These linked websites/applications/services are solely for your convenience and you are therefore solely responsible for accessing them. However, we seek to protect the integrity of our Platform and the links placed on each of those websites and we therefore welcome feedback on these linked sites (including, but not limited to, if a particular site is down).

13.  WILL XINH TUOI ONLINE SEND YOUR INFORMATION OUTSIDE?

Your personal data and/or information may be sent to, stored or processed outside of your country. In most cases, your personal data will be processed in Vietnam, our servers are located there and our central database is operated there. Xinh Tuoi Online will only send your information abroad in accordance with the provisions of the law on privacy protection of personal information.

14.  HOW CAN YOU WITHDRAW, DELETE, REQUEST ACCESS OR ADJUSTMENT OF INFORMATION YOU HAVE PROVIDED TO US?

14.1. You may withdraw your consent to the collection, use and/or disclosure of your personal data that we hold or control by sending an email to Personal Data Protection. our email address support@xinhtuoi.online.

14.2. However, your withdrawal of consent may mean that we will no longer be able to provide the Services to you, and we may need to terminate your current relationship and/ or your contract with us.

Request Access to or Correction of Personal Data

14.3. If you have registered an account with us, you may personally be able to access and/or correct your personal data that we hold or control through the Account Settings page or the label. on the platform. If you have not registered an account with us, you can personally request to access and/or correct your personal data that we hold or control by submitting a request in writing. for us. We will need sufficient information from you to determine your identity as well as the nature of your request in order to be able to process your request. Therefore, please submit your request in writing by emailing our Data Management staff at support@xinhtuoi.online

14.4. We may charge you a reasonable fee to process and process your request to access personal data. If we do charge a fee, we will provide you with a written estimate of the fee. Please note that we are not obligated to respond to or process your access request unless you have agreed to pay a fee.

14.5. We reserve the right to refuse to correct your personal data in accordance with the provisions of the laws on the protection of the confidentiality of personal information, where such laws require and/or permit an organization to refuse. correct personal data in such cases.

15.  QUESTIONS, CONCEPTS OR COMPLAINTS? CONTACT US

If you have any questions or complaints about our privacy practices, please contact us at support@xinhtuoi.online.