Privacy Notice
VTN and Partners (“VTN”) grasps the importance of the protection of your personal data and compliance with relevant laws and regulations. VTN has prepared this Privacy Notice to inform you, as the data subject, of personal data protection and data subject rights.
VTN would like to inform you, as the data subject, who are (1) a person interacting with VTN whether you are a former, existing or prospective client of VTN, (2) an employee, staff, officer, representative, shareholder, director, contact person, agent, person related to a juristic person or a person as mentioned in (1) above, or (3) a person, a trust or a group of persons interacting with VTN, about the protection of your personal data that VTN receives or will receive from your access, operating business and providing services through our offices, websites, telephones, electronic channels, applications, social media or other sources, to assure you that VTN will take care of your personal information, and will collect, use or disclose your personal information only if VTN deems it necessary, correct and appropriate, and to notify you of data subject rights as stipulated in this Privacy Notice.
- Personal Data Collection
1.1. Data that can identify you, whether directly or indirectly
(1) Personal information, namely, name-surname, gender, date of birth, age, information stated or recorded in documents, such as national identification card, passport, residence certificate, alien identification card, work permit, social security card, driving license, car registration book, or house registration, signature, taxpayer identification number, information about family members, facial photograph, education, occupation, status, membership, work history, other benefits other than compensation for work, information relating to insurance,
(2) Contact information, namely, the address of the household registration, address for document delivery, electronic mail address (Email Address), home telephone number, mobile phone number, facsimile number, name or account for applications or digital channels, such as LINE, Google, Facebook, YouTube Twitter, WhatsApp or WeChat, information of contact person provided to VTN,
(3) Financial and transaction information with VTN, information generated from analysis of your personal data, information about an act or accusation of an offense, prosecution and execution information, information relating to insurance or investments through VTN, making payment or receiving payment information, information for compliance with Anti-Money Laundering and Foreign Account Tax Compliance Act (FATCA), any other information related to your use of or request for services and transactions with VTN,
(4) Information about your contact with VTN, namely, information received by VTN through offices, telephones, electronic or digital channels, social media, information from CCTV and on-site services which may be displayed or recorded in written form, recording tape or record of transactions, photos or motion images,
(5) Technical information, namely, Internet Protocol (IP address), Media Access Control (MAC) address, the identification code affixed to the device connected to the network and the network (MAC Address), log, device ID, Application Programming Interface (API), Cookies, type and version of Plug-in, browser, operating system and platform, internet system or mobile network, geographic location, device setting and other technical data derived from your use of the platform, application and operating system of VTN,
(6) Usage information, namely, username, password, search information, visitation statistics, active menu, time you spent on the website, platform, and application, timestamp of last click, favorites, Q&A, log file, communication
(7) Behavioral information, namely, information relating to your personal interests or preferences, and characteristic of use or utilization of services.
1.2. Sensitive personal data that VTN must obtain consent from you before collecting the sensitive personal data, namely, biometric data (for example, facial recognition, fingerprint recognition, iris and voice recognition data), religions,, criminal records, data concerning heath or any other data as prescribed under the relevant laws and regulations.
- Purposes
VTN will collect, use and disclose your personal data in accordance with the law, which is (1) necessity for the access to our website, (2) necessity for the performance of an engagement or request you made to VTN in order to comply with such engagement or request, (3) necessity for legal obligations which VTN must comply with and legitimate interest of VTN or any other persons or juristic persons, (4) necessity for preventing or suppressing a danger to a person’s life, body or health, (5) necessity for the public interest, task carried out in the public interest or the exercising of official authorities; or (6) your consent, in case where VTN cannot rely on any legal basis specified in (1) to (5), for the following purposes:
2.1. contacting, communication or providing information related to or in connection with the products or services that you use or will use with VTN;
2.2. performing VTN’s obligations as stated in your request or agreement made to VTN, or in connection with such request or agreement, such as the document delivery and debt collection, including compliance with an agreement made between VTN and other person which is necessary and related to services provided to you;
2.3. managing your relationship with VTN, and to conduct details or record of your use of service for providing further service to you;
2.4. managing the information of corporate customers or trusts which may contain your personal data;
2.5. compliance with relevant laws and regulations;
2.6. identifying and verifying your identity, including verifying your information, and auditing such verification as required by the law and VTN;
2.7. taking any action as required or recommended by banking regulatory authorities, such as protecting vulnerable customers from certain restrictions or protecting elderly customers from engaging in certain types of transaction, and damage control;
2.8 managing and administrating VTN’s internal operations, such as supervising, improving and auditing VTN’s internal operations;
2.9 managing and dealing with the risks, such as;
(1) preventing, dealing with, or mitigating risks that may arise from illegal actions and occur to you, VTN’s clients, staffs and VTN, by using those information for improving security system related to the use of various channels, the work system and the security system in VTN’s information technology operation;
(2) security, such as video recording of visitors or customers with VTN through closed circuit camera TV (CCTV) and identity card exchange before entering a building for the purpose of security within VTN’s area.
2.10 providing and offering products, services and service options to you, including public relations, communication, notification, giving or presenting privileges benefits, rewards or information about products or services of VTN, business partners that may be of your interests, organizing events and promotions for you;
2.11 inspecting the use of services or transactions according to your instruction or your counter party’s instruction;
2.12 managing services and complaints, transmission of information within VTN or between VTN and other parties, or accommodating customer complaints, compensation, or using information to improve the work process on such matters;
2.13 statistical analysis or research related to a course of business of VTN;
2.14 strategic adjustment, protecting benefit, or evaluating the performance or providing services of VTN;
2.15 evaluating, developing and improving services of VTN, or exercising VTN’s rights (such as behavior scoring, and market surveys), and disclosing information generated from such analysis to you for utilization of other services of VTN, or to business partners;
2.16 organizing projects or promotional activities, meetings, seminars, recreation and company visits;
2.17 storing data in the cloud storage and in other systems used by VTN;
2.18 performing VTN’s obligations under terms and conditions stated in an agreement to which VTN is a party or enforcing legal or contractual rights of VTN; and
2.19 connecting to or facilitating the access to website, applications and platforms of VTN or other persons. The collection, use or disclosure including sending or transferring of your personal data overseas, VTN proceeds your personal data in accordance with the aforementioned purposes and legal basis.
- Disclosure
VTN may be required to disclose your personal data to following persons or entities located in Vietnam or overseas in order to achieve the purposes stated in this Privacy Notice, on need-to-know basis, namely:
3.1. VTN’s business partners, such as business partners of VTN relating to financial, banking, service providers, investment, marketing, transportation, telecommunication, healthcare insurance or life insurance companies, or any person involved in any goods and services transaction, promotion or loyalty program, data analytic, platform provider or person whose name or logo appears in the agreement, electronic card, website or other service channels of VTN;
3.2. Persons or competent authorities, VTN may be required to disclose your personal data in order to comply with laws, rules, regulations or orders of government agencies, regulatory authorities, or VTN believes that any action is necessary to comply with the law for protection of the rights of VTN or other persons, the safety of any person, prevention, investigation or dealing with fraud, security or safety in various areas.
3.3. VTN’s advisors, such as financial advisor, legal advisor, technical consultant and auditor.
3.4. Assignees of rights, obligations and legal claims of VTN, including those involved in corporate restructuring, business transfer, investment, mergers and acquisitions, purchase or sale of assets, shares, or businesses; such persons involved in such actions will comply with this Privacy Notice as well.
3.5. Other persons related to you, such as owners of a joint deposit account, joint debtors, trustees, beneficiaries, estate administrators, authorized person, guarantors or any person who place assets as collateral for your debt payment to VTN.
3.6. Associations, organizations, clubs and agencies.
3.7. Websites and social media.
- Retention
4.1. Retention of your personal data
VTN has established security measures for personal data protection both in document and electronic form in order to prevent loss, unauthorized or unlawful access, use, alteration, correction or disclosure of personal data.
4.2. Retention period of your personal data
VTN will collect your personal data for the purposes notified you by VTN as detailed in this Privacy Notice as long as required by law and for a maximum of 10 years from the access date to our website or cessation date of your relationship with VTN, unless VTN is required by law or such personal data is that cannot be deleted or destroyed due to technical limitations.
- Overseas Transfer
In case that VTN has a necessity to send or transfer your personal data to a person overseas, such as your counter party or VTN’s counter party, VTN’s representative, VTN’s overseas offices, VTN’s business partners, international agency or organization where the recipient country may have inadequate standard for personal data protection as required by law. In such cases, VTN will provide appropriate measures to ensure that your personal data sent to the recipient is sufficiently secure.
- Collection through VTN’s Website
To access VTN’s website, VTN will automatically collect certain information from your use for the purposes stated in this Privacy Notice for the purpose of enabling VTN to provide you with a good experience when you browse our website, as well as enhancing the efficiency and quality of VTN’s website services.
- Your Rights
You, as the data subject, have the rights as follows:
7.1. Access and obtain
You have the right to request access to and obtain a copy of your personal data related to you which is under VTN’s responsibility or to request VTN to disclose the acquisition of such personal data obtained by VTN with or without your consent in a form readable or generally usable.
7.2. Right to object
You have the right to object to VTN’s collection, use or disclosure of your personal data unless VTN collects, uses or discloses your personal data in contrary to the purposes hereunder.
7.3. Destroy of personal data
You have the right to request VTN to erase, destroy or make your personal data non-identifiable information if (1) your personal data is no longer necessary for VTN to store according to the purposes herein, (2) you withdraw your consent and VTN has no other lawful basis to collect, use or disclose such personal data, (3) you object the collection, use, and disclose of your personal data collected by VTN due to the necessity in carrying out missions for VTN’s public interest or the exercise of governmental rights or for the legitimate interests of VTN or any other person or juristic person, and VTN may not be able to reject such objection, (4) you object the collection, use or disclosure of your personal data for direct marketing purposes, or (5) your personal data has been unlawfully collected, used or disclosed, unless VTN is obliged to collect your personal data to comply with the law, establishment, legal claims or the use or defense of VTN’s claims.
7.4. Restriction
You have the right to restrict the use of your personal data in the event that (1) VTN is under verification of the request to rectify your personal data to be accurate and up-to-date, (2) VTN collects, uses or discloses your personal data unlawfully, (3) it is not necessary to VTN to collect, use or disclose your personal data for any purpose, but you request VTN to collect your personal data for your benefit, or (4) you request VTN to suspend the use of your personal data because it is in the process of verifying or reviewing the request to object to processing your personal data.
7.5. Rectification
You have the right to request VTN to rectify your personal data to be accurate, up-to-date, complete and not misleading.
7.6. Consent withdrawal
You have the right to withdraw your consent given to VTN for the collection, use and disclosure of your personal data at any time by submitting a request for revocation of consent to VTN at the addresses hereunder.
7.7 Complaint lodgment
You have the right to lodge a complaint to a competent authority or legal authority in the event that VTN or its data processor, including employees or contractors of VTN, or such data processor, violate or do not comply with personal data protection laws and regulations. If you wish to exercise any rights under Clauses 7.1 to 7.6 set forth above, you can submit a request to VTN at the addresses hereunder. Once VTN receives your request, VTN will review your request in accordance with the conditions prescribed by law, complete your request, and notify you of the result of the reviewing and completion of the request within 30 days from the date of receipt of all request and supporting documents.
If you exercise rights of data subject, you may not be able to obtain certain services from VTN while VTN is in process of reviewing or processing your request.
VTN will not charge a fee for exercising the right, unless VTN deems that your request is excessive or unreasonable; VTN may charge a fee to process your request according to the rate announced by VTN.
- Amendment
VTN may amend this Privacy Notice from time to time as it deems appropriate. VTN will notify you of such changes through our offices, websites and other means (if applicable), and VTN recommends you to read and check the details in Privacy Notice every time when such changes are made.
- Contact information
If you wish to contact or would like to receive more information or explanations about the collection, use and disclosure of your personal data, and exercise the rights of the personal data subject stated in this Privacy Notice, please contact the us or unit that you use or have used the service of the VTN.
Furthermore: you can contact us through email address: admin@vtn-partners.com or our Head Office at Level 18 Tower 789, No. 147, Hoang Quoc Viet, Cau Giay, Hanoi, Vietnam.