(Applicable to Customers)

VNCS GLOBAL SOLUTION TECHNOLOGY JOINT STOCK COMPANY (hereinafter referred to as “VNCS Global”) always places the highest importance on the privacy and protection of Customers’ Personal Data. We understand that, through this Personal Data Protection Policy (“Policy”), Customers should be fully informed and transparent about how their Personal Data is collected, processed, and protected when searching, accessing, purchasing, registering for, or using VNCS Global’s products, goods, and services.

VNCS Global is committed to ensuring that Personal Data is handled securely, confidentially, and in compliance with applicable laws as well as industry-standard cybersecurity practices.

This Policy serves as a formal notice regarding the processing and protection of Personal Data. It may be updated from time to time, and the latest version will be published on our official website. We recommend that Customers regularly review this Policy to stay informed of any updates.

  • DEFINITION

In this Policy, the following terms are construed as follows:

  1. VNCS GLOBAL: is VNCS GLOBAL SOLUTION TECHNOLOGY JOINT STOCK COMPANY, Business Registration Certificate No. 0109103758; head office at 5th floor, Kham Thien Building, 195 Kham Thien Street, Van Mieu – Quoc Tu Giam Ward, Hanoi City, Vietnam.
  2. Customer/Customer: means (i) an individual and/or (ii) an organization that provides personal data in the activities of searching, accessing, purchasing, registering to use, use VNCS GLOBAL’s products, goods and services.
  3. Products, goods and services are any products, goods and services provided by VNCS GLOBAL and/or cooperated by VNCS GLOBAL with partners that the Customer searches, accesses, buys, registers to use, use.
  4. Personal data: is digital data or other forms of information that identify or help identify a specific person. In this Policy, the Personal Data processed by VNCS GLOBAL includes:
  • Full name, middle name and birth name, other names (if any);
  • Date of birth; date of death or disappearance;
  • Gender;
  • Place of birth, place of birth registration, place of permanent residence, place of temporary residence, current place of residence, hometown, contact address;
  • Nationality;
  • Telephone number, email address;
  • identity card number, citizen identification number, personal identification number, passport number.
  • History of activities in cyberspace
  1. Processing of Personal Data:means an activity that affects personal data, including one or more of the following activities: collection, analysis, aggregation, encryption, decryption, correction, deletion, destruction, de-identification, provision, disclosure, transfer of personal data, and other activities that affect personal data.
  2. Personal Data Controller:means an organization or individual that decides the purposes and means of Processing Personal Data.
  3. Personal Data Processor: means an organization or individual that performs the Processing of Personal Data on behalf of the Personal Data Controller, through a contract or agreement with the Personal Data Controller.
  4. Controller and Processor of Personal Data:means an organization or individual that concurrently decides the purpose, means and directly Processing of Personal Data.
  5. VNCS GLOBAL’s transaction channels:including call center channels, electronic transaction channels (applications, websites, social networks) and physical transaction channels (VNCS GLOBAL stores, business points) or other transaction channels from time to time provided or authorized by VNCS GLOBAL to provide to Customers.
  • TYPES OF PERSONAL DATA PROCESSED
  1. Processed personal data includes the data that the Customer provides to us when searching, accessing, purchasing, registering to use, using the Products, goods and services and data generated during the process of using our Products, goods and services are the basic Personal Data specified in Section 4 Article 1 of the Policy this.
  2. Personal data is processed in accordance with each respective type of Product, goods, and service.
  • PURPOSE OF DATA PROCESSING

Personal data in accordance with Article 2 above may be processed for the following purposes:

  1. Providing products, goods and services to customers who request and exercise the rights and obligations of VNCS GLOBAL in accordance with the law, including but not limited to:
  • Providing, activating, or verifying the Products, goods, and services requested by the Customer;
  • Serving the purpose of contacting and notifying customers;
  • Exercise the Client’s rights related to Personal Data in accordance with the law, the agreement between the Client and VNCS GLOBAL;
  • Performing obligations under the Client’s contract and VNCS GLOBAL’s obligations to relevant agencies, organizations and individuals in accordance with the law;
  • Disclosure of Customer’s Personal Data in accordance with the law;
  • Performing VNCS GLOBAL’s obligations on inspection, examination, statistics, reporting, finance, accounting and taxation;
  • Performing operations to ensure data security; ensuring the security of VNCS GLOBAL’s information system such as backup, backup, monitoring, resource optimization and protection of customer personal data;
  • Detect and prevent violations of the law in cyberspace at the request of competent state agencies and legal regulations.
  • In case of national defense and security emergencies, social order and safety, major disasters, dangerous epidemics; when there is a threat to security and defense but not to the extent of declaring a state of emergency; to prevent and combat riots, terrorism, crime and law violations in accordance with law;
  • Detect and prevent fraudulent acts, fraud, attack, intrusion, and appropriation of Customers’ assets.
  • Serving the activities of state agencies in accordance with specialized laws.
  1. Supporting Customers when buying and using products, goods and services provided by VNCS GLOBAL under contracts and legal regulations, including:
  • Updating and processing information when customers buy and use products, goods and services;
  • Taking care of Customers, receiving and resolving Customers’ questions and complaints about VNCS GLOBAL’s products, goods and services;
  • Use and transfer to partners Personal Data, problematic information, incidents, and error reports reported by Customers to identify and fix problems of products, goods and services; repair of the Customer’s equipment; perform other activities of customer care and support.
  1. Improving the quality of products, goods and services that VNCS GLOBAL provides to Customers:
  • Provide information that the Client has requested or VNCS GLOBAL thinks the Client may find useful, including information about VNCS GLOBAL’s products, goods and services in accordance with the law;
  • Improving technology, interface of websites, websites, social networks, applications to ensure convenience for customers;
  • Manage Client accounts and loyalty programs;
  • Storing information, market research, analysis, statistics and other internal management activities to improve customer experience;
  • Reporting, statistics, and analysis of internal data to research, build, develop, manage, measure, provide and improve products, goods and services as well as operate VNCS GLOBAL’s business activities;
  • Develop marketing campaigns for products, goods and services and determine how VNCS GLOBAL can personalize those products, goods and services;
  • Developing and providing new products, goods and services that are personalized according to the needs and actual conditions of customers with effective measurement methods;
  • Introducing and providing promotional programs for products, goods, services, incentives and promotions of VNCS GLOBAL and VNCS GLOBAL in cooperation with partners;
  1. Carry out advertising and product introduction activities in accordance with the needs of customers or VNCS GLOBAL believes that customers are interested in according to the content, form and frequency as follows:
  • Content: Introduction of information on products, goods, services, and incentives provided by VNCS GLOBAL and its partners;
  • Method: Via advertising messages (SMS, USSD, MMS…), IVR calls, notifications on VNCS GLOBAL’s trading channels or other methods as prescribed by law;
  • Form: Send directly to customers via devices, electronic means or other forms in cyberspace in accordance with the law;
  • Frequency: According to the law on advertising.
  1. Carrying out market research and public opinion polling activities;
  2. Organizing trade introduction and promotion.
  • HOW DATA IS PROCESSED
  1. How to collect

Personal data is collected directly from you in the following cases:

  • From VNCS GLOBAL Sites: We may collect Personal Data when you visit any VNCS GLOBAL website (collectively, the “Site“) or use any features and resources available on or through the Site. When you visit the Website, VNCS GLOBAL collects information about the Customer’s device and browser (such as device type, operating system, browser type, browser settings, IP address, language setting, date and time of connection to the Website and other technical communications);
  • From the App: We may collect Personal Data when you download or use VNCS GLOBAL’s mobile application (collectively, the “App“). These Applications may record certain information (including statistics when using the Application, device type, operating system, Application settings, IP address, language settings, date and time of connection to the Application, and other technical communications);
  • From Products, Goods and Services: We may collect Personal Data when you search, access, purchase, register to use, use any Products, goods and services through any form (SMS, USSD, IVR, website, wapsite, application…); Trading channels of VNCS GLOBAL, cyberspace; and/or other methods as prescribed by law;
  • From exchanges and communications with Customers: We may collect Personal Data through interactions between Us and you (face-to-face, by mail, telephone, online, switchboard system, electronic communication or any other means) including customer surveys;
  • From social networks: means VNCS GLOBAL’s social networks and/or social networks that we cooperate with partners;
  • From interactions or automated data collection technologies: We may collect information including IP addresses, referrer URLs, operating systems, e-news browsers, and any other information that is automatically recorded from the connection:
    • Cookies, flash cookies, plug-ins, pixel tags, electronic message beacons, third-party social media connectors, or other tracking technologies;
    • Any technology capable of tracking personal activity across devices or Sites;
    • Other data information provided by a device.
  • Other means: We may collect Personal Data when you interact with VNCS GLOBAL through any other means.

We may also collect Personal Data indirectly from you through public, official sources of information; or through receiving and sharing necessary data from subsidiaries and partners that they collect in the process of cooperation with VNCS GLOBAL to provide products, goods and services to you and are allowed by you to share.

  1. How to store

Personal data is stored in Vietnam in VNCS GLOBAL’s Customer database system or wherever we or our affiliates, subsidiaries, affiliates, partners or service providers have facilities and create archival copies for data centers in another region.

In the process of visiting VNCS GLOBAL’s website, website, application, social network, we may also store temporary information via cookies, clickstreams or similar browsing data storage tools to store data that can be retrieved by the web server in the domain.

  1. How data is transferred/shared

We will use the necessary security measures to ensure the transfer/sharing of your Personal Data to (i) other businesses; (ii) individuals/organizations participating in the Processing of Personal Data specified in Article 8 of this Policy); or (iii) competent state agencies, ensuring information security, not being disclosed or leaked and requesting the parties receiving Personal Data to take measures to keep the data confidential.

  1. How it is analyzed

The analysis of Personal Data is carried out in accordance with VNCS GLOBAL’s internal processes. We always have a strict monitoring mechanism for each data analysis process, which requires checking the compliance with the requirements of the law on data security and ensuring information security for information technology systems before conducting analysis. We also have strict rules in place that ensure that personal information is anonymized or de-identified at an appropriate stage during processing.

  1. How to encrypt

Collected personal data is encrypted in accordance with appropriate encryption standards as necessary during data storage or transfer, to ensure that the data is protected, authentic, integrity and cannot be altered once it has been sent.

  1. How to delete data

When you terminate the use of VNCS GLOBAL’s Products, goods and services and have a valid request, we will delete the Personal Data with all the Personal Data that you have provided and/or collected during your use of the Products,  goods and services, unless otherwise provided for by law and in some cases where it is impossible to perform as follows:

  • The law does not allow data deletion or mandatory data retention;
  • Personal data is processed by competent state agencies for the purpose of serving the operation of state agencies in accordance with the law;
  • Personal data that has been made public in accordance with the law;
  • Personal data is processed to serve legal requirements, scientific research, and statistics in accordance with the law;
  • In case of national defense and security emergencies, social order and safety, major disasters, dangerous epidemics; when there is a threat to security and defense but not to the extent of declaring a state of emergency; prevention and combat of riots, terrorism, prevention and combat of crimes and law violations;
  • Responding to an emergency situation that threatens the life, health, or safety of the Customer or other individual.
  • VNCS GLOBAL’S DATA SECURITY PRINCIPLES
  1. Your personal data is kept confidential in accordance with this Policy and the law.
  2. We are responsible for ensuring cyber information security in accordance with the law, ensuring national defense and security, state secrets, maintaining political stability, social order and safety, and promoting socio-economic development.
  3. The handling of cyber information security incidents when implementing always ensures the legitimate rights and interests of customers.
  4. Activities  to ensure  cyber information security are carried out regularly, continuously, promptly and effectively.
  • CONSEQUENCES, UNINTENDED DAMAGE IS LIKELY TO OCCUR
  1. We use many different information security technologies such as: international standard PCI, SSL, firewall, encryption, etc. to protect and prevent your Personal Data from being accessed, used or shared unintentionally. However, no single piece of data can be completely secured. Therefore, we cannot commit to the absolute confidentiality of your Personal Data in some cases such as:
  • Hardware and software failures in the process of data processing that cause the loss of the Customer’s data;
  • Security vulnerabilities are beyond our control, the system is attacked by hackers, causing data leakage.
  1. We recommend that you keep the information related to your account login password, OTP code confidential and do not share this content with any other person.
  2. You should be aware that at any time you disclose and make your Personal Data public, it may be collected and used by others for purposes beyond your and our control.
  3. We recommend that you preserve your personal devices (phones, tablets, personal computers, etc.) during use; You should log out of your account when you don’t need to use it.
  4. In case the data storage server is attacked, resulting in the loss, disclosure or leakage of the Customer’s Personal Data, VNCS GLOBAL will be responsible for notifying the case to the investigating authorities for timely handling and notifying the Customer in accordance with the law.
  5. Cyberspace is not a safe environment and we cannot absolutely guarantee that your Personal Data shared via cyberspace will always be secure. When you transmit Personal Data over cyberspace, you should only use secure systems to access websites, applications or devices. You are responsible for keeping your access credentials for each website, application or device safe and confidential.
  • START TIME, END TIME OF PROCESSING OF PERSONAL DATA
  1. Personal Data is processed from the time we receive the Personal Data provided by you and we have an appropriate legal basis to process it in accordance with the law.
  2. To the extent permitted by law, Personal Data will be processed until the purposes of the data processing have been completed.
  3. We may have to store your Personal Data even if the contract between you and VNCS GLOBAL has been terminated in order to fulfill our legal obligations in accordance with the law and/or the requirements of competent state agencies.
  • ORGANIZATIONS AND INDIVIDUALS PARTICIPATING IN THE PROCESS OF PROCESSING PERSONAL DATA
  1. As the case may be, we may be the Personal Data Controller or the Controller and Processor of Personal Data.
  2. To the extent permitted by law, you understand that we may share Personal Data for the purposes mentioned in Article 3 with the following organizations and individuals:
  • Member enterprises and associated companies of VNCS GLOBAL;
  • Organizations and individuals providing services and/or cooperating with VNCS GLOBAL, including but not limited to: agents, consultants, auditors, lawyers, notaries and business cooperation partners, providing information technology solutions, software, applications, etc operation, management, incident handling, infrastructure development services;
  • Any person or organization that is the representative or authorized party of the Client, acting on behalf of the Client;
  • Payment service providers are based on the Customer’s authorization or approval.

The data sharing will be carried out in accordance with the order, method and current legal regulations. Recipients of Personal Data are obliged to keep your Personal Data confidential in accordance with this Policy; regulations, processes and standards on Personal Data Protection of VNCS GLOBAL and current laws.

  1. We may share your information with competent state authorities when performing the purposes of Personal Data Processing specified in Article 3 of this Policy in accordance with the law.
  • CUSTOMER RIGHTS
  1. You are informed about the Processing of your Personal Data, unless otherwise required by law.
  2. You are entitled to consent in relation to the Processing of your Personal Data, unless otherwise provided for by law.
  3. You have the right to access to view, correct or request correction of your Personal Data, unless otherwise provided for by law.

We will correct your Personal Data when requested by you or in accordance with specialized laws. In case this is not possible, we will notify you according to the agreement between us and you, as prescribed by law.

  1. You have the right to delete or request the deletion of your Personal Data in accordance with the provisions of Section 6, Article 4 of this Policy.
  2. You have the right to request the restriction of the Processing of your Personal Data in accordance with the law.

The restriction of data processing will be implemented by us after your request is in accordance with the technical conditions permitted, unless otherwise provided for by law or as agreed by the parties.

  1. You have the right to request that we provide you with your Personal Data, unless otherwise required by law.

The provision of your Personal Data will be carried out by VNCS GLOBAL after your request, unless otherwise provided for by law.

  1. You have the right to request the withdrawal of consent for the purposes of processing that you agree to allow VNCS GLOBAL to process, unless otherwise provided for by law. Upon receipt of the request, VNCS GLOBAL informs you of the consequences and damages that may occur when withdrawing consent.

In case the withdrawal of your consent affects the performance of the contract between VNCS GLOBAL and you, the legal obligations of VNCS GLOBAL, the life, property and legitimate rights and interests of you, other organizations and individuals, the task of protecting national security,  social order and safety, we have the right to restrict, suspend, terminate, cancel part or all of the contract for the supply of products, goods and services between VNCS GLOBAL and the Client. We do not accept any liability or compensation for any losses incurred by you in this case.

  1. You have the right to object to VNCS GLOBAL Processing your Personal Data in order to prevent or restrict the disclosure of your Personal Data or other reasons as required by law.

We will process your objection request after receiving the request, unless otherwise provided for by law.

In case your objection affects the performance of the contract between VNCS GLOBAL and you, the legal obligations of VNCS GLOBAL, the life, property and legitimate rights and interests of you, other organizations and individuals, the task of protecting national security, social order and safety,  we have the right to restrict, suspend, terminate, cancel part or all of the contract for the supply of products, goods and services between VNCS GLOBAL and the Customer. We do not bear any losses incurred by you in this case.

  1. You have the right to complain, denounce or initiate a lawsuit in accordance with the law.
  2. You have the right to claim compensation for actual damages in accordance with the law if VNCS GLOBAL violates the regulations on the protection of your personal data, unless otherwise agreed by the parties or otherwise provided for by law.
  3. You have the right to defend yourself in accordance with relevant laws, including but not limited to the Civil Code, or request competent agencies and organizations to implement civil rights protection methods such as forcible termination of infringement, forced apologies, etc public correction, compulsory compensation for damages.
  4. Other rights under this Policy and as required by law.
  5. You can exercise the rights in Sections 1, 2, 3, 4, 5, 6, 7, 8, 9 and 10 of this Article by sending an email to: marketing@vncsglobal.vnor other methods as prescribed by law and regulations of VNCS GLOBAL from time to time. VNCS GLOBAL can verify the necessary information from the Client to fulfill the Client’s requests.
  • CUSTOMER OBLIGATIONS
  1. Comply with VNCS GLOBAL’s laws and regulations related to the Processing of your Personal Data.
  2. Provide complete, truthful and accurate Personal Data and other information at the request of VNCS GLOBAL when searching, accessing, purchasing, registering to use and using Products, goods and services and when there is a change in this information. We will protect your Personal Data based on the information you have provided. Therefore, if there is any false information, we will not be responsible in case such information affects or limits your rights. In case of failure to notify, if there are risks or losses, you are responsible for errors or acts of taking advantage or fraud when using products, goods and services due to your fault or failure to provide correct, complete, accurate and timely changes in information; including financial losses and expenses incurred due to false or inconsistent information.
  3. Coordinate with us, competent state agencies or third parties in the event that issues arise that affect the security of your Personal Data.
  4. Self-protection of your Personal Data; request other relevant organizations and individuals to protect your Personal Data; proactively apply measures to protect your Personal Data during the use of VNCS GLOBAL’s products, goods and services; promptly notify us when an error or mistake is detected about Personal Data or suspects that Personal Data is being compromised.
  5. Respect and protect the Personal Data of others.
  6. Take responsibility for the information and data that you create and provide in cyberspace; take responsibility in case Personal Data is leaked or infringed due to their fault.
  7. Regularly update VNCS GLOBAL’s regulations and policies related to the protection and Processing of Personal Data in each period which are notified to you through VNCS GLOBAL’s Transaction Channel.
  8. Comply with the law on personal data protection and participate in the prevention and control of violations of regulations on personal data protection.
  9. Other obligations as prescribed by law.
  • GENERAL TERMS
  1. This policy is effective from 02/04/2026 and may be amended from time to time and notified to you through VNCS GLOBAL’s trading channels before applying. These changes will take effect in accordance with the law.
  2. This Policy is a Notice of Processing of Personal Data in accordance with applicable law.

Enacted April 2, 2026

VNCS GLOBAL SOLUTION TECHNOLOGY JSC