PRIVACY POLICY
This Privacy Policy (“Policy”) is issued by Nguyen Cong Tri Company Limited, headquartered at 194 Nguyen Dinh Chieu, District 3, Ho Chi Minh City, Vietnam, with tax ID 0302644297 (“CONG TRI”). It details the practices and processes related to the handling of Customer Personal Data by CONG TRI. This Policy is an integral part of the contracts, agreements, terms, and conditions that govern the relationship between CONG TRI and its Customers.
1. GENERAL PROVISIONS
1.1 This Data Protection Policy, issued by Nguyen Cong Tri Company Limited, the owner and operator of www.congtri.com (hereafter collectively referred to as “CONG TRI”), applies to all activities on the Website concerning the protection of Personal Data of every customer and/or user of the Website (collectively referred to as “Customer”).
1.2 This Policy is an inseparable part of CONG TRI’s terms and conditions, contracts, transactions, service subscriptions, and/or any other agreements established between the Customer and CONG TRI.
1.3 By registering an account, using any service, product, or accessing any page or application of CONG TRI, the Customer acknowledges having read, understood, and accepted all terms of this Policy. The Customer voluntarily agrees (“Consent”) as a legal basis for CONG TRI to collect, use, disclose, store, transfer, and/or process their Personal Data, including data provided before, during, and after accepting this Policy, as outlined in this Policy.
1.4 By providing Consent, the Customer acknowledges full awareness of this Policy’s terms, including but not limited to the processing of both basic and sensitive Personal Data and the sharing of Personal Data with third parties for purposes described in this Policy.
1.5 If the Customer provides Personal Data of a third party (including but not limited to information on spouses, children, parents, guardians, friends, beneficiaries, authorized persons, partners, guarantors, emergency contacts, legal representatives, stakeholders, or other individuals connected to the Customer) to CONG TRI, the Customer confirms that they have obtained the third party’s consent for CONG TRI to process the Personal Data as described in this Policy. CONG TRI is not responsible for verifying the legality of this consent and is not liable if the Customer fails to comply with this clause.
1.6 CONG TRI adheres to the following principles when processing Personal Data:
Privacy and Security: Respect and prioritize the privacy, confidentiality, and security of Customer Personal Data, in compliance with Vietnamese law, this Policy, and all established agreements with the Customer.
Purposeful Processing: Process Personal Data for specific, clear, and lawful purposes, within the scope of this Policy and in alignment with Vietnamese law.
No Processing of Minor’s Data: CONG TRI does not collect or process Personal Data of children under 18 years. Any online orders or account creations must be supported by a parent or guardian. Parents or guardians should monitor and ensure that Personal Data of children under 18 is not shared with CONG TRI. If a parent or guardian provides such data, it is deemed as consent for CONG TRI to process this data on behalf of the child in compliance with this Policy. CONG TRI is not liable for issues arising from non-compliance with these terms.
Data Controller and Processor Role: Depending on the context, CONG TRI may act as (i) a Data Controller, (ii) a Data Processor, or (iii) both Data Controller and Processor, fulfilling the corresponding rights and obligations as required by applicable laws.
2. TYPES OF PERSONAL DATA PROCESSED
In order for CONG TRI to provide products and services to Customers and/or process Customer requests, CONG TRI may need to and/or be required to collect Personal Data. The Personal Data of Customers includes the following information:
Basic Personal Data of Customers: Includes full name, and any other names (if applicable); date of birth; gender; phone number; current contact address; personal account information; data on activities, browsing history in the digital space; and any other data as required by law.
Data Related to Websites or Applications: Includes technical data (device information, operating system, browser type, browser settings, IP address, language, connection time to the website, app usage statistics, app settings, location, and other technical contact information); secure login information and usage data.
Marketing Data: Includes interests in advertisements; cookie data; clickstream data; browsing history; responses to direct marketing activities; and opt-out preferences from direct marketing.
3. METHODS OF COLLECTING PERSONAL DATA
CONG TRI collects Personal Data from Customers using the following methods:
3.1 Direct Collection from Customers through Various Channels: When Customers register or fill out forms related to CONG TRI products or services or those of its partners; When Customers contact CONG TRI customer service via phone, mail, in person, email, or social media; When Customers use CONG TRI services or access CONG TRI websites and applications, including creating an online account or using surveillance devices (CCTV); When Customers respond to marketing representatives and customer service staff from CONG TRI; When Customers submit personal information for any reason, including signing up for trials or expressing interest in CONG TRI products or services; When Customers purchase or use services from Third Parties through or at CONG TRI’s business premises; CONG TRI may also collect Personal Data from other legitimate sources.
3.2 Collection from Third Parties: If Customers interact with content or advertisements from Third Parties on the Website or Application, CONG TRI may receive personal information from those Third Parties in accordance with their privacy policies; If Customers choose to make electronic payments directly to CONG TRI or via the Website or Application, CONG TRI may receive Personal Data from payment service providers to complete the transaction; In order to comply with legal obligations, CONG TRI may receive Customer information from competent authorities as required by law.
4. PURPOSE AND SCOPE OF DATA COLLECTION
CONG TRI may collect, store, use, and process Customer Personal Data to provide the best experience (hereinafter referred to as the “Purpose”), including but not limited to the following purposes:
4.1 Providing Products, Services, and Programs to Customers: Providing products, services, and programs to Customers and fulfilling agreements between CONG TRI and Customers; Personalizing the Customer experience with CONG TRI; offering relevant promotions, customer services; managing events that Customers have registered for and/or participated in; Sending information related to transactions, customer needs, in compliance with direct marketing regulations; conducting promotional programs, gift exchanges, rewards, and gift deliveries; Supporting and caring for Customers, continuously improving and enhancing service quality; Identifying and quickly resolving issues, investigating, processing requests, inquiries, and complaints from Customers; Notifying Customers of changes to the policies and promotions related to products and services provided by CONG TRI.
4.2 Understanding and Improving Product and Service Quality: Delivering relevant advertisements based on behaviors and preferences; displaying content, website features, applications, and devices customized as required; Monitoring and improving shopping experiences, enhancing product and service quality, and minimizing product defects; Building trust to provide the best products and services, organizing loyalty programs to bring optimal consumer value; Analyzing Customer information to develop and improve service and product quality; Providing services to partners according to policies to execute services for Customers; Performing activities related to the provision, operation, and management of CONG TRI products and services to improve service quality.
4.3 Risk Management, Information Security, and System Safety: Identifying and maintaining accurate information about Customers; Supporting the update of information when Customers register or use services; Ensuring the security of personal data and protecting Customers’ information systems.
4.4 Compliance with Legal Requirements: To establish and protect the legal rights of CONG TRI; Complying with legal regulations, internal standards, procedures, and guidance from government authorities; Preventing and combating fraud, identity theft, and illegal activities.
4.5 Other Purposes as Required by Government Authorities or Legal Regulations.
4.6 Other Purposes as Announced by CONG TRI at the Time of Data Collection or Before Processing Data, If Permitted by Law.
5. RIGHTS AND OBLIGATIONS OF CUSTOMERS
5.1 As the data subject, Customers have the following rights: Customers have the right to be informed about the processing of their personal data, unless otherwise provided by law; Customers have the right to access all information related to themselves, including personal information used by CONG TRI; Customers have the right to correct any inaccurate or incomplete personal information. Customers should carefully check their information, noting that CONG TRI is not responsible for issues arising from providing incorrect information, whether accidentally or intentionally; Customers can request to limit the processing of their personal data without deleting the related data, in compliance with applicable laws; If the processing of personal data is based on prior consent, Customers may withdraw their consent at any time. However, such withdrawal will not affect the legality of data processing conducted prior to the withdrawal. If a Customer withdraws their consent, CONG TRI may not provide the requested services if it directly impacts the quality of service; Customers have the right to file complaints if they discover that CONG TRI is using their personal data for purposes other than those originally stated. CONG TRI is committed to investigating and taking responsibility for any harm that Customers may suffer in this case; Customers are entitled to other rights under the law.
5.2 To the extent permitted by law, Customers can exercise their rights via their personal account on the CONG TRI Website, by visiting a CONG TRI store, or by sending a request to the email cs@nctgroup.vn. CONG TRI commits to responding and processing Customer requests within 72 working hours. All legitimate requests will be processed within the time frame required by law after receiving the valid request from the Customer.
5.3 Requests for Cancellation or Deletion of Personal Data: If a Customer withdraws consent for the processing of personal data, requests cancellation or deletion of personal data, or exercises rights related to all or part of their personal data, CONG TRI may decide to stop providing products or services to the Customer if it cannot meet quality standards as assessed by CONG TRI, or if the law requires the collection of personal data when providing products or services; If CONG TRI decides to stop providing products or services, the Customer’s actions under this provision will be considered a unilateral termination of any relationship with CONG TRI, which may result in a breach of obligations or commitments in contracts or agreements (if applicable). In such cases, CONG TRI reserves the right to retain necessary rights and legal measures to address any arising issues; After the cancellation request is processed, the Customer’s personal information will be removed from CONG TRI’s information system and Customer Relationship Management system within 72 working hours. Please note that once the cancellation is completed, the Customer will no longer be entitled to any benefits from CONG TRI (including but not limited to: discounts, priority customer service, etc.); CONG TRI will not be liable for any losses that may occur due to this request, and CONG TRI’s legal rights will be reserved in cases of limitations, restrictions, suspensions, cancellations, prevention, or prohibition. Customers should note that, due to CONG TRI’s operational nature, in some cases, CONG TRI must retain information as required by law and may not be able to comply with the deletion request if doing so would violate legal regulations.
5.4 Customer Obligations: Complying with legal regulations, policies, and guidance from CONG TRI related to the processing of personal data; Providing complete, truthful, and accurate personal data as required when registering and using products or services. CONG TRI ensures the confidentiality of personal data based on the provided information; therefore, if there is incorrect information, CONG TRI will not be responsible for any impact on Customer rights; In case of changes, the Customer must promptly notify CONG TRI to update the information. If no notification is given, and any risks or losses arise, the Customer will be responsible for any errors or fraudulent actions when using services due to their failure to provide correct, full, and timely information, including financial damages or costs resulting from incorrect or inconsistent information; Cooperating with CONG TRI, government authorities, or third parties in case of any issues related to personal data; Actively protecting personal data while using CONG TRI services and notifying promptly if there is an error or suspected breach; Being solely responsible for the information, data, and consent provided in the online environment, even in cases of data leakage or breach due to their own fault; Regularly updating CONG TRI’s personal data protection regulations and policies, complying with CONG TRI’s guidance to express consent or dissent regarding the purposes for processing personal data as notified to Customers at each period; Respecting and protecting the personal data of others; Other obligations as required by law.
6. PERSONAL DATA PROCESSING AND STORAGE TIME
6.1 Personal Data Processing Time: Begins when the Customer agrees to allow CONG TRI to process their Personal Data or when the Customer uses the products or services of CONG TRI, and continues until the Customer completely ceases using the products or services or requests data deletion as outlined below.
6.2 Cases where the Customer has the right to request immediate deletion of Personal Data: The Customer withdraws their consent; The data is no longer needed for the initial collection purpose, and the Customer accepts any potential harm that may arise from the deletion request; The Customer objects to the processing, and CONG TRI has no legitimate reason to continue processing; The data is processed for purposes other than those agreed upon, or the processing violates legal regulations; The data must be deleted according to legal requirements.
6.3 Cases where CONG TRI may refuse a request for deletion of Personal Data: If the law does not permit data deletion; Data processed by a competent state authority to serve legal activities; Data that has been made public in accordance with the law; Data that serves legal, scientific research, or statistical purposes under the law; In cases of national defense, national security, social order, natural disasters, epidemics, or when there is a risk to national security but not yet an emergency declaration; to prevent riots, terrorism, or crime; When responding to emergencies that threaten the life, health, or safety of the Customer or others.
6.4 Personal Data Deletion and Cancellation Time: After the data retention period ends or upon receiving a deletion request from the Customer, CONG TRI will process the request and delete the data within 72 hours of receiving the request.
7. DATA PROCESSING METHODS
CONG TRI carries out one or more activities related to Personal Data, including: collecting, recording, storing, retrieving, analyzing, using, sharing, disclosing, deleting, encrypting, decrypting, and processing personal data automatically.
8. COOKIES
8.1 When Customers visit the websites or online pages of CONG TRI (“Website”), CONG TRI may place cookies on the Customer’s device. A “cookie” is a small file stored on the device when the Customer visits the Website, recording information about the device, browser, and in some cases, preferences or browsing habits. CONG TRI uses cookies to identify the Customer when they return, provide personalized services, analyze data to better understand activities on the Website, and improve user experience. Customers can delete or block cookies via browser settings. However, rejecting cookies may limit some features on the CONG TRI Website.
8.2 CONG TRI may process the Customer’s personal information through cookie technology in compliance with this policy. Additionally, CONG TRI may use retargeting tools to advertise to users who have visited the Website.
8.3 If third parties have integrated content on the CONG TRI Website (such as social media features), they may collect the Customer’s personal data (such as cookie data) when the Customer interacts with the content or uses third-party services.
9. PROVISION OF PERSONAL DATA
9.1 CONG TRI commits not to sell, exchange, or rent Customer’s personal information in any form that violates this policy, without the Customer’s consent, in accordance with current laws.
9.2 To carry out the purposes and activities of personal data processing as stated in this policy, the Customer agrees to allow CONG TRI to share or disclose their personal data, and the personal data of related third parties in the following cases:
Employees or workers of CONG TRI to perform tasks that serve the operation of CONG TRI within the legal scope and in accordance with agreements signed between CONG TRI and the Customer;
CONG TRI may share personal information with third-party service providers who use this information to help CONG TRI (i) provide products and services, or (ii) serve business needs, including IT service providers, storage, payment processing, customer care, shipping, marketing, advertising, auditing, and other related services;
CONG TRI may access, store, and disclose any information related to the Customer to third parties in order to comply with legal requirements from authorities, enforce policies or contracts, or support investigations, prosecutions, or other legal activities;
In the event that CONG TRI participates in a merger, acquisition, financial legal audit, restructuring, bankruptcy, sale of assets, or similar procedures, Customer information may be transferred as part of the transaction, in compliance with applicable laws and related contracts.
10. INFORMATION STORAGE TIME
Unless otherwise provided by Vietnamese law, CONG TRI will retain personal data only for as long as necessary to fulfill the purposes for which the data was collected, including meeting legal obligations, accounting requirements, reporting, record-keeping, or other obligations, and for IT data storage purposes if applicable.
As the data subject (“Data Subject”), the Customer has the right to request CONG TRI to delete or cancel the personal data held by CONG TRI. However, if required by law, CONG TRI may refuse this request. In such cases, CONG TRI will notify the Data Subject in writing and comply with any related legal restrictions.
11. PERSONAL DATA CONFIDENTIALITY POLICY
