PRIVACY POLICY
Managing your personal data and everything related to your privacy is of maximum importance to us. Before explaining how we go about doing it and what our privacy policy consists of, we want to tell you about some of our commitments to you which govern our conduct:
Legality, transparency and clear language
In addition to scrupulously complying with the law, we are also committed to being transparent with you and explaining what data we need and what we will be using it for, in simple and comprehensible terms. If at, any time, there is a significant change to our privacy policy, we will inform you and, if that change affects how we process your data or its purpose, we will ask for your consent again before we do anything. In addition, we will only ask you for the data that we really need in order to deal with your request.
Privacy by design and by default
We take the privacy of the users into account from the initial design phase of all our products, services and administrative processes which are likely to require or make use of personal information.
Your data, protected for its entire life cycle
We test the robustness of our systems and security measures along the value chain to ensure that they meet all of our commitments. We train our team on this matter and we will voluntarily submit to a security audit.
Data Protection Officer
We have voluntarily appointed a Data protection department will oversee the deployment and implementation of these principles and the regulatory compliance. This Privacy Policy constitutes our referential framework in relation to managing your personal data and it applies to all applications managed by us and to all of our interactions with you. It is possible that certain products or services may require a greater level of detail than that which is offered by our privacy policy. In such case, we will use annexes and other legal and informative documents to make your aware of the specific privacy conditions that apply, to manage your consent and to determine your preferences.
Definitions of key terms
It is important that you understand some of the key terms mentioned throughout our privacy policy.
Data of a personal nature: any information relating to identifiable natural persons or enabling their identification.
User: the owner of the data.
Data controller: the person who determines the purposes and means of processing the user’s data before obtaining their consent.
Interactions: some examples of interactions are when you download our mobile app, when you use our mobile app, when you request a service from our customer care service or when you request telephone support. These interactions could result in data of a personal nature being processed.
Personal data processing: the operations or technical procedures whether automated or otherwise, which enable the collection, recording, storage, use, production, modification, restriction or cancellation, transfer or communication of data.
Consent: any freely given, unambiguous, specific and informed indication of the user’s wishes, by which they consent to the processing of their data.
Third parties: any natural or legal person who is external to VinSmart and other than the user.
Transfer or communication of data: any revelation of data made to a third party.
Erasure: the physical elimination of the restricted personal data once the period of limitation (retention period) has ended.
What information we may collect from you and for what purpose
The personal data collected will depend on the type of interaction you have with us. In general, it will be data which you have voluntarily provided and which is characterize by having:
A limited nature (we won’t ask you for more information than is strictly necessary for the purpose indicated).
A specific purpose for which they are to be processed.
A lawful basis that allows for such processing, which may consist of:
Your expression and freely given consent, which can be revoked at any time.
The execution of a contract between yourself and VinSmart.
The legitimate interest of VinSmart that may consist of:
◦ Producing statistics to better understand your needs and provide you with a better service, as well as to adapt our products, applications to you.
◦ Complying with the obligations and legal requirements involving the processing of personal data.
We may also collect information which is not necessarily of a personal nature using technology such as dissociated technologies which do not permit your identification (such as the serial number of your device).
Finally, we will process your data on occasion as a consequence of a request from a third party acting as data controller.
These are the main interactions that you may have with us:
You install or use application developed by VinSmart |
|||
Application |
Personal information |
Personal Data Using Purpose |
Lawful basis for processing |
V Launcher |
None. Parameters of functioning and performance of the software that manages this function |
We uses the data we collect to operate our products and to improve the product experience. We may use the data we collect to: 1. Detecting errors and sending security updates. 2. Improving the quality and user experience of our devices. |
Legitimate interest. |
V Camera |
None. Parameters of functioning and performance of the software that manages this function (for example, focusing and shooting times or luminosity. |
Legitimate interest. |
|
We may use your personal data or information resulting from its combination for other purposes related to the above stipulations or to offer you products, services or personalize value proposals, but only with your consent and within the framework set out by our Privacy Policy.
We may also use your information to invite you to participate, if you so wish, in the evaluation of our products and services through surveys, market research or other systems that allow you to communicate your experience with VinSmart to us.
We do not use your personal data for automated decision-making that could adversely affect you or have legal consequences for you.
How we protect your data
The security of your data is important to us. We employ industry recommended security practices to protect the data that we collect. Furthermore, we do not store any personally identifiable information on our servers. This ensures your protection in the unlikely event that our security precautions fail.
Your responsibility
As a user, you are responsible for the veracity, accuracy, validity and authenticity of the data that you provide to VinSmart. You are also responsible for the information that you provide to us regarding third parties, from whom you are obliged to obtain their consent.
If you are a registered VinSmart user, never share your password or make it public. Remember that we cannot be held liable for any loss of data, files or, in general, any damage resulting from any failure to retain a backup of the data contained on the devices.
VinSmart accepts no liability for the consequences that may result from inappropriate use of our products or services. VinSmart cannot be held liable for any violation of third-party rights by one or more users via their activities on the VinSmart website.
On occasion, for certain services, we must include a link to a third-party website (for example, for the joint provision of services with a partner which has its own privacy policy and may come to act as data controller) and, where applicable, they will be responsible for obtaining your consent. The same applies to social networking services such as (Facebook, Twitter, Instagram or YouTube), which have their own conditions of use and privacy policies, which generally include the use of cookies, pixels, web beacons and other automatic data collection technologies.
What are your rights and how to exercise them
Right to be informed
You have the right to obtain clear and easy-to-understand information about how we use your personal data and what your rights are. We give you this information in this policy.
Right of access
You have the right to access the personal data we hold on you. In certain cases, there may be a reasonable) cost to cover the administrative expenses that providing the information involves. Any repetitive, unfounded or excessive requests will not be processed to. To exercise this right, write to us at care@vinsmart.net.vn and attach a copy of your national ID or official document to verify your identity.
Right to rectification
You have the right to request that we complete or rectify your personal data when it is incorrect, incomplete or not up to date. To exercise this right, write to us at care@vinsmart.net.vn and attach a copy of your national ID or official document to enable the verification of your identity. If you have a username and an account, you can correct it yourself.
Right to restrict processing
The processing of your data will be subject to limitations (we can continue to store it but without using it) when any of the following circumstances apply: 1) you have requested verification of the accuracy of the data that we hold, 2) you have objected to the processing, 3) we no longer require your data for the purposes of processing or 4) the processing is unlawful.
How to contact us
If you have any questions on how we use your personal data, you can contact our customer care service:
ĐÌNH VŨ ECONOMIC ZONE – CÁT HẢI DISTRICT, HẢI PHÒNG CITY
Hotline: 1900 232389
Changes to our Privacy Policy and applicable legislation
We may update our privacy policy at any time, and if this involves substantial changes that could affect your rights, we will inform you using the notifications system of your device, by email or by publishing an informative notice on one of our corporate information channels. Even so, we recommend that you review our policy periodically. If you continue to use our services once the change has been communicated, this implies that you are familiar with the terms set out in the new privacy policy.
Date of application: 9 March 2019