1. Introduction and General Commitment

Our use of your Personal Data will be governed by this Privacy Policy. This Privacy Policy explains why and how we collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose, align or combine, restrict, or erase or destroy your personal data when you stay at our facilities, purchase or use our services, visit our website, use our mobile applications or interact with us. This Privacy Policy also instructs you how to exercise your rights relating to your personal data.

The Company is a controller-cum-processor for the Personal Data that it collects and uses about you. The Company will treat your Personal Data as confidential and in accordance with applicable data protection legislation and your Personal Data will only be shared with others in accordance with this Privacy Policy. The Company also recognizes the importance of protecting Personal Data. The proper use and protection of this information not only forms the basis of our business activities but also represents key areas of our social responsibility. Therefore, to better ensure the trust of our customers, the Company will take action in accordance with the following policy:

• (i)

  The Company will clarify the purpose of use of the Personal Data the Company receives and only use it for the intended purpose.

• (ii)

  The Company will not provide third parties with the Personal Data the Company receives without the customer's approval, except for cases mentioned in this Item 6 below.

• (iii)

  The Company will make every effort to manage Personal Data in a safe and appropriate manner by implementing security measures to prevent exposing Personal Data to risks, such as the unauthorized access of Personal Data from the outside or the loss, destruction, alteration, and leakage of information.

2. Personal Data

Personal Data is any information that is associated with a particular person or may lead to the identification of a particular person. Through the course of our business, the Company receives a wide range of Personal Data about your needs or circumstances which would allow us to identify you, including but not limited to:

• (i)

  Personal details such as name, date of birth, gender, nationality, phone number, email address, VISA or permission for staying Vietnam, emergency contact and credit card information for deposits and payments.

• (ii)

  Digital account information such as username, password, contact preference, or other authentication data.

• (iii)

  Information relating to financial position, business activities, buying habits, and product preferences relevant to our products, services, and business activities.

• (iv)

  Information about your commercial interests and requirements, products you may wish to purchase or services you may wish to engage us to perform.

• (v)

  Information regarding our communication with you and your attendance at conferences or promotional events.

• (vi)

  If you are a supplier or prospective supplier, information about your business skills, services, products, and prices.

The Company may also receive certain information relating health status and private information recorded in the health record which can be considered as ”sensitive personal data” pursuant to the law of Vietnam and under other applicable jurisdiction.

The Company receives this information directly from you through a variety of means, such as applications and requests, surveys, business negotiations, and executed contracts and agreements. The Company also receives Personal Data through publicly available media real estate registries, commercial registries, telephone directories. The Personal Data that comes into our possession will be used for the purposes mentioned in this Item 3 below.

3. Purpose of Use of Personal Data

The customer agrees that the Company will use the Personal Data in compliance with the data protection legislation to present information and proposals, execute and perform contracts and agreements, provide after-sales service, contact and notify customers, develop new products and services, provide information deemed useful to customers, and perform other actions related to the businesses conducted by the Company or its group companies. These businesses include housing, renovation, rental housing, condominium, commercial store development, construction, real estate subdivision, real estate agency services, environment and energy, non-life insurance agency, hotel, interior, and other various businesses.

In addition to the above, Personal Data will also be used for the following purposes.

• (i)

  Receive customer feedback and thoughts.

• (ii)

  Respond to customer inquiries and requests for reference materials.

• (iii)

  Conduct market research and development of new products and services.

• (iv)

  Provide notice about various events, seminars, campaigns, membership services, and other activities.

• (v)

  Offer electronic mail delivery services and deliver publications.

• (vi)

  Provide information about the products and services offered by the Company or its business partners and affiliates.

• (vii)

  Confirm matters for the purpose of audits.

• (viii)

  Use for any other matters incidental and related to the businesses of the Company.

It should be noted that the Company may provide Personal Data to third parties as described in Item 6 and 7 below to the extent necessary to ensure smooth performance of the business operations it outsources to these third parties. In this case, the Company will enter into agreements with these third parties regarding handling the said information and implement other measures to supervise them.

4. Base of Use of Personal Data

By visiting the page to view this Privacy Policy and ticking the consent box in Website, entering the consent statement via message, selecting consent settings or signing the agreements with the Company or other forms that can be printed and reproduced in writing, you agree to this Policy, acknowledge that the Company has notified with the following contents to you and constitute your consent to the processing of your information in accordance with this Policy.

• (i)

  Processing purposes (mentioned in Item 3 above).

• (ii)

  Type of used Personal Data (mentioned in Item 2 above).

• (iii)

  Method of processing Personal Data (mentioned in Item 5 below).

• (iv)

  Information on any third party related to the processing purposes (mentioned in Item 6 and 7 below).

• (v)

  Undesirable consequences and damage that may occur (mentioned in Item 10 below).

• (vi)

  Time for starting and completing the processing of data (mentioned in Item 5 below).

Your consent may always be withdrawn at any time. In such case, be aware that the withdrawal of consent shall not affect the lawfulness of the processing based on your consent before the withdrawal. The Company hereto will stop processing your Personal Data and request related third parties to stop it.

If you refuse to provide us with any or all of Personal Data or if you provide us with incomplete or inaccurate information, please be aware that we may not be able to provide or deliver to you all or parts of our products and services, which you may have requested from us in full quality. Please keep in mind that we only ask for such information that can help us fully provide our products and services to you.

5. Securing Personal Data

The security of information is very important to the Company and the Company has measures in place which are designed to prevent unauthorized access to your Personal Data, including but not limited to:

• (i)

  Client files are stored on our secure client management systems. Access is restricted on client systems to those within the business who are required to have access to Personal Data for legitimate business purposes.

• (ii)

  Hard copy documentation is stored in locked cabinets.

The Company ensures access to Personal Data is restricted to employees and workers or other persons working within the Company or its group companies on a need to know basis. Training is provided to any of those employees and workers who need access to Personal Data.

The Company will retain Personal Data for as long as the purpose for which the Company collected it continues. It is then destroyed unless further retention is required to satisfy a legal regulatory or accounting requirement or to protect Company’s interests or any other case the Company deems necessary.

6. Providing Personal Data to Third Party

The Company will not otherwise provide Personal Data to third parties unless we have your permission or we are under a legal or similar obligation in the following cases:

• (i)

  When the Company provides Personal Data as statistical data in a way that makes it impossible to identify customers.

• (ii)

  When the Company is required by laws and regulations to provide Personal Data.

• (iii)

  When the provision of information is necessary to protect life, body, or property and the Company cannot obtain the customer's consent.

• (iv)

  When the Company is required to cooperate with the administration of the national or local government and other authorities as stipulated by laws and regulations, and the acquisition of consent from customers may inhibit the administration of these bodies.

• (v)

  When the Company provides Personal Data to the contractors, advisors, agents, subsidiaries, associates, owners and competent authorities for the same purpose as purpose of use as mentioned in Item 3 above.

• (vi)

  When the Company provides Personal Data to any officer, employee, agent (including subsidiaries, affiliates, representatives and branch offices of the Company), professional advisers, third party service providers, agents or independent contractors providing services to support the Company's business operations under a duty of confidentiality to the Company.

7. Transferring Personal Data to third countries

The Company may transfer your Personal Data to third parties located outside Vietnam’s boundaries. The Company will take reasonable steps to ensure these third parties handle the Personal Data in compliance with the laws and protect Personal Data regardless of which country it is transferred to.

By providing your Personal Data to us you consent to this transfer. If you do not wish for your Personal Data to be transferred to another jurisdiction then you should not provide us with your Personal Data.

The collection and use of Personal Data by these third parties may also be subject to separate privacy policies.

Your Personal Data may be disclosed to the following third parties, but not limited to:

• (i)

  Investors of the Company

• (ii)

  Travel agents of the Company

• (iii)

  Operators of the Company

8. Disclosing, Correcting, or Suspending the Use, etc. of Personal Data

Upon receiving one of the following requests from a customer, the Company will endeavour to take the necessary action within a reasonable period and to a reasonable extent after confirming the identity of the customer unless we are subject to confidentiality obligations or some other restriction on giving access to the information or permitted to refuse you access under the respective laws.

• (i)

  When a customer requests the disclosure of its Personal Data.

• (ii)

  When a customer requests to correct, add, or delete its Personal Data.
  However, this only applies to cases in which Personal Data is factually incorrect.

• (iii)

  When a customer requests to suspend the use or eliminate its Personal Data.

• (iv)

  When a customer requests the restriction of processing of his/her personal data, unless otherwise provided by law.

• (v)

  When a customer objects to processing of his/her personal data by the Company for the purposes of preventing or limiting the disclosure of personal data or its use for advertising or marketing, unless otherwise provided by law.

However, this does not apply to Personal Data the Company holds in accordance with applicable data protection legislation.

Inquiries about Personal Data and requests to disclose, correct, or suspend the use, etc. of Personal Data as described above will be accepted in accordance with the following procedures:

• (a)

  Requests must be made by submitting a request by mail or Email via contact information as described at Item 13 below.

• (b)

  When a customer submits a request, the identity of the customer will be confirmed by various means, such as by using the driver's license, passport, identity card or other forms of identification, information registered with the Company such as address, name, telephone number, and date of birth, or by calling back the telephone number registered with the Company.

  When a proxy submits a request, in addition to confirming the identity of the customer as described above, the capacity of proxy will be confirmed by power of attorney, certificate of seal-impression, or other means.

• (c)

  A prescribed fee may be charged to process a request to disclose Personal Data.

In addition, only for requests for disclosure of Personal Data, we will charge a fee of VND 200,000 per request item.

When we have no ongoing legitimate business need to process Personal Data or you request that we delete Personal Data, we will make reasonable attempts to delete it.

9. Use of cookies on the Website:

The Company and its group companies use cookies. Cookies are a form of technology that identifies the customer's terminal on the web server side by storing specified files on the terminal when the customer accesses the website.

The Company and its group companies use cookies exclusively for improving the information and services we provide, to make the website easier for customers to use, to ensure the security of the web server, and to evaluate the content on the website. Cookies do not record any privacy information, such as the names and contact information of customers. In addition, cookies do not affect the terminals used by customers and the data stored on them.

The customer can disable the cookie function by changing the configuration of the browser the customer use. Please note that disabling this function may prevent the customer from using all or some of the services on the website.

10. Limitation of liability

The Company will apply appropriate technical and security solutions to effectively protect Personal Data. However, the customer should be noted that although the Company has taken reasonable measures to protect Personal Data, there is no website, internet connection, computer system or wireless connection which is safe absolutely. Therefore, the Company cannot make a commitment to ensure that Personal Data provided to the Company will be absolutely secure, and the Company cannot be responsible in case of having illegal access or leakage of Personal Data without fault of the Company. The Company excludes all liability for the consequences of any unauthorized access, disclosure of, misuse of or loss or corruption of Personal Data not due to our misconduct. If the customer does not agree to the terms described above, the Company recommends that customers should not send details of information to the Company.

11. Rights and Obligations

By providing Personal Data for the Company, you have rights and obligations in accordance with respective laws, which may include:

• (i)

  To be informed of your Personal Data handling procedures.

• (ii)

  To give/withdraw consent to the processing of your Personal Data.

• (iii)

  To access or to request the Company to provide you with Personal Data in order to disclose, correct or suspend.

• (iv)

  To obtain restriction on or object to the processing of Personal Data, which is implemented within 72 hours after receiving your request, and all Personal Data that you request the restriction.

• (v)

  To self-protection or request competent authorities to implement civil right protection methods, including but not limited to recognizing, respecting, protecting and guaranteeing your civil rights; order the termination of the act of violation; order a public apology and/or rectification; order the performance of civil obligations; order compensation for damage from the Company or cancellation of isolated unlawful decision of competent individuals and entities.

• (vi)

  To comply with the relevant applicable laws.

• (vii)

  To respect and protect your and others’ Personal Data.

• (viii)

  To provide your Personal Data fully and accurately when you consent to the processing.

12. Complaints

If the customer has any concerns or complaints about the way the Company uses Personal Data, please contact us at our Contact Information below. If the Company cannot resolve any issue, the customer has the right to complain to the data protection authority in Vietnam.

13. Contact Information

If the customer has any questions, comments or requests regarding any aspect of this Privacy Policy or would like to access or correct your Personal Data held by us, please do not hesitate to contact us via the following address:

We will respond to your complaint or try to resolve the issue to your satisfaction within a reasonable period at our best effort.

14. General

This Privacy Policy provides a general statement on the ways in which the Company aims to protect and use your Personal Data. The Company reserves the right to update the Privacy Policy that is necessary for business requirements or to stay compliant with relevant laws from time to time. The updated version will be posted on our website and date stamped so that you can be aware of when the Privacy Policy was last updated. The customer is encouraged to regularly check the Privacy Policy to make sure you are familiar with the most recent version. Your continued use of our Website after updates to this Privacy Policy have been posted constitutes your acceptance of such updates.

This Privacy Policy was last updated on 1^st Jul 2023