PRIVACY POLICY

This Privacy Policy describes how VinSmart Research and Manufacture Joint Stock Company, head office located at Lot CN1-06B-1&2, Hi-tech Industrial Park 1, Hoa Lac Hi-tech Park, Ha Bang, Thach That, Hanoi, Vietnam (“VinSmart”) collects, uses and shares your personal information in relation to VinSmart’s websites, applications, products and services (together, “Our Offerings”). This Privacy Policy does not apply to products or services we may provide to third parties on their behalf. Please refer to their privacy policies and terms for additional information.

1. Personal Information We Collect

2. How We Use Personal Information

3. Collection and use of cookies

4. How We Share Personal Information

5. Location of Personal Information

6. How We Secure Information

7. Internet Advertising and Third Parties

8. Access and Choice

9. Juvenile’s Personal Information

10. Retention of Personal Information

11. Contacts, Notices, and Revisions

12. Additional Information for the EU/UK

13. Information You Give Us

Personal Information We Collect

We may collect your personal information in the course of providing Our Offerings to you. The collection of your personal information shall be made in accordance with this Privacy Policy where posted in connection with Our Offerings and as permitted by applicable data protection laws of relevant jurisdictions.

Here are the types of information we gather:

Information You Give Us: We collect any information you provide or about you in relation to Our Offerings.

Automatic Information: We automatically collect certain types of information when you interact with Our Offerings

Information from Other Sources: We might collect information about you from other sources, including preloaded applications, service providers, partners, and publicly available sources.

For more detailed about the information collected, please refer to Section 13 of this Policy. We may combine this information with other information we have about you.

How We Use Personal Information

We use your personal information to operate, provide, and improve Our Offerings. Our purposes for using personal information include:

Provide Our Offerings: We may use your personal information to provide and deliver Our Offerings and process transactions related to Our Offerings, including registrations, subscriptions, loyalty programs, surveys, purchases, and payments.

Measure, Support, and Improve Our Offerings: We may use your personal information to measure use of, analyze performance of, fix errors in, provide support for, improve, maintain, and develop Our Offerings.

Recommendations and Personalization: We may use your personal information to recommend Our Offerings that might be of interest to you, identify your preferences, and personalize your experience with Our Offerings.

Comply with Legal Obligations: In certain cases, we have a legal obligation to collect, use, or retain your personal information.

Communicate with You: We use your personal information to communicate with you in relation to Our Offerings via different channels (e.g., email, chat) and to respond to your requests.

Marketing: We use your personal information to market and promote Our Offerings in accordance with the applicable laws. We might display interest-based ads for Our Offerings as discussed below.

Prevent Fraud: We use your personal information where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our terms or this privacy policy.

Purposes for Which We Provide Notice or Seek Your Consent: We may also provide notice or obtain your consent to use your personal information for a specific purpose that we communicate to you and other legitimate purposes permitted by applicable law.

Collection and use of cookies

We may use cookies, web beacons, pixels, and other similar technologies (collectively, “cookies”) for a variety of purposes. We may use Flash Local Storage Objects to store your site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page. We may use pixel tags, which are tiny graphics with a unique identifier, which are embedded invisibly on web pages.

We may use cookies to recognize your browser or device, learn more about your interests, provide you with essential features and services, and for other additional purposes, including:

Recognizing you when you use or sign in use Our Offerings. This allows us to provide you with recommendations, display and manage personalized content, and provide other customized features and services.
Keeping track of your specified preferences or email response rates and identifying when our emails are viewed or forwarded. This allows us to honor your language and configuration preferences.
Conducting research and analysis to improve Our Offerings.
Compliance with legal obligations, as part of our general business operations.
Preventing fraud, and situations that cause a potential threat to the safety or property of any person.
Securing your information and our services from unauthorized access, loss, and misuse.
Improving security.
Delivering content, including ads, relevant to your interests on our sites and third party sites.
Measure, analyze, and ensure the quality and performance of Our Offerings.

Cookies allow you to take advantage of some of our essential features. For instance, if you block or otherwise reject our cookies, you might not be able to use certain offerings that require you to sign in, or you might have to manually adjust some preferences or language settings every time you visit our sites.

Third parties may also set cookies when you interact with Our Offerings. Third parties usually include search engines, providers of measurement and analytics services, social media networks, and advertising companies. Third parties use cookies and other technologies such as web beacons or clear GIFs in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, and to perform services on our behalf. The use of these technologies and any information about you we may provide to third parties is governed by each third party’s specific privacy policy, not this one.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. If you are a user in the European Union, you may opt-out of certain third party cookies that we and other websites may use for targeted advertising through the European Interactive Digital Advertising Alliance (EDAA) Your Online Choices Page or www.aboutads.info.

Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or the EDAA Your Online Choices Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA, NAI, or EDAA websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

You can opt out of personalized advertising on Android and iOS through your device settings. Please note that these opt outs will disable personalized ads from all providers on all of your apps.

The DAA offers AppChoices, a separate choice tool for users to exercise control over the collection and use of data through mobile applications for personalized advertising and other related uses. To exercise choice for participating companies, you can install the DAA's AppChoices application on your mobile device. Visit https://youradchoices.com/appchoices for information.

You can manage browser cookies through your browser settings. The 'Help' feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you reject or disable cookies, you may have to manually adjust some preferences every time you visit a site and some features and services may not work. You can also partially manage targeted ads on your mobile through your system settings by resetting your device advertising identifier.

How We Share Personal Information

We share information as follows:

Sharing with Subsidiaries: We may share personal information with our parent company - Vingroup and its subsidiaries to the extent permitted by the applicable laws.

Transactions Involving Third Parties: We make available to your services, software, and content provided by third parties for use on or through Our Offerings.

Third-Party Service Providers: We employ other companies and individuals to perform certain functions on our behalf. Examples include sending communications, processing payments, assessing credit and compliance risks, analyzing data, providing marketing and sales assistance (including advertising and event management), conducting customer relationship management, and providing training. These third party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must comply with data protection obligations in the relevant agreement with us and the applicable data protection law.

Business Transfers: As we continue to develop our business, we might sell or buy businesses or services. In such transactions, personal information generally is one of the transferred business assets but remains subject to the Privacy Policy (or the individual consents otherwise). Also, in the event that VinSmart or its assets are acquired, your information will, of course, be one of the transferred assets, to the extent allowed by the applicable laws.

Protection of Us and Others: We may release account and other personal information when we believe release is appropriate to comply with legal or regulatory obligations, enforce or apply our terms and other agreements, or protect the rights, property, safety or security of us, our customers, or others. This includes responding to appropriate requests from law enforcement or governmental authorities and exchanging personal information with other companies and organizations for fraud prevention and detection and credit risk reduction.

Additional sharing and disclosure: We may also disclose and share your personal information if in our sole discretion; we believe is appropriate under exigent circumstances in response to a perceived threat to the personal safety, property, or rights of any other person or organization.

Notice or Consent: Pursuant to this Privacy Policy or our terms, you may receive notice and where necessary, we will seek consent when personal information about you is shared with unrelated third parties for marketing purposes, and you have the right to choose not to share the information.

Storage of Personal Information

VinSmart is located in Vietnam, and our subsidiaries companies are located throughout the world. Depending on the scope of your interactions with Our Offerings, your personal information may be stored in or accessed from multiple countries, including Vietnam. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by applicable data protection laws of relevant jurisdictions.

How We Secure Information

At VinSmart, security is important to us.

We employ appropriate technical and security measures to prevent unauthorized access and use of your personal information. Despite our efforts, no data security measures can guarantee security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Internet Advertising and Third Parties

Our Offerings may include third-party advertising, analytics and links to other websites and applications. Third party advertising partners may collect information about you when you interact with their content, advertising, or services. Any access to and use of third party links or websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third party operators. We are not responsible for the information practices of third parties. To opt out of interest-based advertising, please see Collection and Use of Cookies above.

Third-Party Analytics. Our Offerings may use services operated by third parties, such as Google Analytics, which uses cookies and similar technologies to understand use of Our Offerings and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources.

Social Plugins. We may use Facebook, YouTube, Instagram and LinkedIn social plugins on our sites. When you view a site that contains a plugin, your browser will create a direct link to the third parties’ servers. If you are logged into your social media account, the social media platform will record the visit to your social media account. Please visit the social media platform’s privacy policy for more information.

Access and Choice

You can view, update, and delete certain personal information about your account and your interactions with Our Offerings. If you cannot access or update your personal information yourself, you can always contact us for assistance by contacting us as described below.

You have choices about the collection and use of your personal information. Many of Our Offerings include settings that provide you with options as to how your information is being used. To opt out of interest based advertising, please see Collection and Use of Cookies as described above. You can unsubscribe from any marketing emails you receive from us by clinking the link in the email or contacting us as described below. You can choose not to provide certain personal information, but then you might not be able to take advantage of some of Our Offerings.

Juvenile’s Personal Information

Our Offerings are not designed for children. If we discover that a child has provided us with personal information in violation of applicable law, we will delete such information from our systems.

Retention of Personal Information

We retain your personal information to enable your continued use of Our Offerings, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required by law (including for tax and accounting purposes), or as otherwise communicated to you. How long we retain specific personal information varies depending on the purpose for its use, and we will delete your personal information in accordance with applicable law.

Contacts, Notices, and Revisions

If you have any concern about privacy at VinSmart or want to contact one of our data controllers, please contact us, and we will try to resolve it. You may also contact us at the address below:

VinSmart Care Center

Call center: 1900 232389

Email: [email protected]

Our business changes constantly and our Privacy Policy may also change. You should check our website frequently to see recent changes.

Additional Information for the EU/UK

We provide additional information about the privacy, collection, and use of personal information of prospective and current customers of Our Offerings located in the European Economic Area and the United Kingdom.

Controller of Personal Information. Vingroup – parent company of VinSmart (at No. 7 Bang Lang 1 street, Viet Hung, Long Bien, Hanoi, Vietnam) is the controller of the personal information collected or processed under this Privacy Policy.

Processing. We process your personal information on one or more of the following legal bases:

as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide Our Offerings, to respond to requests from you, or to provide customer support;
where we have a legitimate interest, as described in Section 2 of this Privacy Policy;
as necessary to comply with relevant law and legal obligations;
respond to lawful requests and orders; or
with your consent.

Your Rights. Subject to applicable law, you have the right to:

ask whether we hold personal information about you and request copies of such personal information and information about how it is processed;
request that inaccurate personal information be corrected;
request deletion of personal information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements;
request us to restrict the processing of personal information where the processing is inappropriate;
object to the processing of personal data;
request portability of personal information that you have provided to us (which does not include information derived from the collected information), where the processing of such personal information is based on consent or a contract with you and is carried out by automated means; and
lodge a complaint with the supervisory authority.

You can exercise your rights of access, rectification, erasure, restriction, objection, and data portability by contacting us. If you wish to do any of these things and you are our customer, please contact us. If you are not our customer, please contact us at the address under Section 11 above.

When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.

Transfers outside of the EU and UK. When we transfer your personal information outside the EU and UK, we do so in accordance with the terms of this Privacy Policy and applicable data protection law. This may include the transfer of data pursuant to data transfer agreements that incorporate the Standard Contractual Clauses approved by the EU Commission or other transfer mechanism.

Information You Give Us

You mainly provide information to us when you:

search for, subscribe to, or purchase Our Offerings;
register, create or administer your account;
configure your settings for, provide data access permissions for, or otherwise interact with Our Offerings;
register for or attend a VinSmart’s event;
purchase or use content, products, or services from third-party providers through VinSmart’s websites or apps (or other similar venues operated or provided by us);
offer your content, products, or services on or through Our Offerings or VinSmart’s websites or apps (or other similar venues operated or provided by us);
communicate with us;
complete a questionnaire or other information request forms;
post on VinSmart’s websites or apps or similar venues.

Depending on your use of Our Offerings, you might supply us with such information as:

your name, email address, physical address, phone number, and other similar contact information;
purchase history, payment information, including credit card and bank account information;
information about your location;

information about your organization and your contacts, such as colleagues or people within your organization;

usernames, aliases, roles, and other authentication and security credential information;

content of feedback, testimonials, inquiries, communications with us;
your image (still, video, and in some cases 3-D), voice, and other identifiers that are personal to you when you attend an event of VinSmart or use certain Our Offerings to the extent allowed and according to the procedures provided for by the applicable laws;
information regarding identity, including government-issued identification information;
biometric information, including but not limited to a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry
corporate and financial information; and
VAT numbers and other tax identifiers.

Automatic Information

We mainly collect information automatically when you:

visit, interact with, or use Our Offerings (including when you use your computer or other device to interact with Our Offerings);
download content from us;
open emails or click on links in emails from us; and
interact or communicate with us.

The information we may automatically collect include:

network and connection information, such as the Internet protocol (IP) address used to connect your computer (or other device) to the Internet and information about your Internet service provider, such as IP address, Wi-Fi SSID, access time, page views, MAC address, network cell info,;
computer and device information, such as device name, device model, IMEI number, application, or browser type and version, browser plug-in type and version, operating system, current software version or time zone setting; battery info, unique IDs, password recovery for lock phone with SIM feature, installed app information (such as package name, version, binary), security issue reports;
the precise or coarse location of your device or computer as permitted, such as location for find my phone feature;
authentication and security credential information;
content interaction information, such as content downloads, streams, and playback details, including duration and number of simultaneous streams and downloads;
Our Offerings metrics, such as offering usage, occurrences of technical errors, reports, your settings preferences, backup information, API calls, and other logs;
the content you viewed or searched for, page response times, and page interaction information (such as scrolling, clicks);
email addresses and phone numbers used to contact us; and
identifiers and information contained in cookies.

Information from Other Sources

The information we receive from other sources include:

marketing, sales generation, and recruitment information, including your name, email address, physical address, phone number, and other similar contact information;
subscription, purchase, support, or other information about your interactions with products and services offered by us or third parties in relation to Our Offerings;
search results and links, including paid listings (such as Sponsored Links); and
credit history information if you are financing Our Offerings.