A. Collection of Personal Data

COLLECTION OF PERSONAL DATA

“Personal Data” means information about you, from which you are identifiable, including but not limited to your name, identification card number, birth certificate number, passport number, nationality, address, telephone number, fax number, bank details, credit card details, race, gender, date of birth, marital status, resident status, education background, financial background, personal interests, email address, your occupation, application forms or any other similar forms and/or any information about you that has been or may be collected, stored, used and processed by VTrade from time to time and includes sensitive personal data such as data relating to health, religious or other similar beliefs.

The provision of your Personal Data is voluntary. However if you do not provide VTrade your Personal Data, VTrade will not be able to process your Personal Data for the Purposes and Additional Purposes outlined below.

If you are an agent, vendor, supplier or service provider, provision of your Personal Data is mandatory and failure to provide your Personal Data, may be a breach of laws or regulatory requirements, and may cause VTrade to be unable to engage you to provide services or products or issue payments to you for products or services provided.

By using any service of VTrade or its partners, which includes all websites operated by VTrade and under the names of its respective brands Your personal data may also be collected from cookies used on the Websites.

B. Purpose and field of use the information

PURPOSE AND FIELD OF USE THE INFORMATION

1. General:

to respond to questions, comments and feedback from you;

to communicate with you for any of the purposes listed in this Notice;

for internal administrative purposes, such as auditing, data analysis, database records;

for purposes of detection, prevention and prosecution of crime;

for VTrade to comply with its obligations under law; and you agree and consent to VTrade using and processing your Personal Data for the Purposes and in the manner as identified in this Notice.

2. Where you are a customer of the services provided by VTrade:

to perform the VTrade s obligations in respect of any contract entered into with you;

to provide you with any service you have requested;

to process your subscriptions and to deliver the services to you;

where you have requested to download and use the VTrade or VTrade App (“App”), to process your request, to deliver the App to you and to provide you a license for the use of the App;

to process your participation in any events, activities, focus groups, research studies, contests, promotions, polls, surveys or any productions;

to process, manage or verify your application for subscription with the VTrade and to provide you the benefits offered to subscribers;

to validate your bookings and process payments relating to any products or services you have requested;

to understand and analyses our sales as well as your needs and preferences;

to develop, enhance and provide products and services to meet your needs;

to process exchanges or product returns;

3. Where you are an agent, vendor, supplier, partner, contractor or service provider:

for the purposes of engaging you to provide services or products;

to facilitate or enable any checks as may be required by VTrade in order to engage you;

to process payments relating to any products or services you have provided;

to contact you or your VTrade;

4. Marketing and promotional purposes:

VTrade may also use and process your data for other purposes such as (“Additional Purposes”): To send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings from VTrade, its partners, sponsors or advertisers;

To notify and invite you to events or activities organized by VTrade, its partners, sponsors or advertisers;

To process your registration to participate in or attend an event or activity and to communicate with you regarding your attendance at the event or activity;

To share your Personal Data amongst its subsidiaries, associate companies and jointly controlled entities as well as with its agent, vendor, supplier, partner, contractor or service provider who may communicate with you to market their products, services, events or promotions. by way of post, telephone call, short message service (SMS), by hand and/or by email.

C. Who can access the information

WHO CAN ACCESS THE INFORMATION

1. Transfer of Personal Data

Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than your home nation or otherwise in the country, state and city in which you are present while using any services provided by VTrade (“Alternate Country”), to companies under VTrade which are located outside of your home nation or Alternate Country and/or where VTrade servers are located outside of your home nation or Alternate Country. You understand and consent to the transfer of your Personal Data out of your home nation or Alternate Country as described herein.

2. Disclosure to Third Parties

Your personal data may be transferred, accessed or disclosed to third parties for the Purposes and Additional Purposes. Further, VTrade may engage other companies, service providers or individuals to perform functions on its behalf, and consequently may provide access or disclose to your Personal Data to such service providers or third parties. The third parties include, without limitation

VTrade partners, which include parties with whom VTrade collaborates with for certain events, programs and activities;

Event management companies and event sponsors;

Marketing research companies;

Service providers, including, information technology (IT) service providers for infrastructure, software and development work;

Professional advisors and external auditors, including legal advisors, financial advisors and consultants;

Other entities within VTrade Group; and

Governmental authorities to comply with statutory, regulatory and governmental requirements. Your Personal Data may also be shared in connection with a corporate transaction, such as a sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of winding-up.

3. Access & Correction Requests and Inquiries, Limiting the Processing of Personal Data

Subject to any exceptions under applicable laws of your home nation or Alternate Country, you may request for access to and/or request correction of your Personal Data, request to limit the processing of your Personal Data for the Additional Purposes and/or make any inquiries regarding your Personal Data by contacting:

Subject to any laws of your home nation or Alternate Country, VTrade reserves the right to impose a fee for access of your Personal Data in the amounts as permitted therein.

In respect of your right to access and/or correct your Personal Data, VTrade has the right to refuse the your requests to access and/or make any correction to your Personal Data for the reasons permitted under law, such as where the expense of providing access to you is disproportionate to the risks to your or another person’s privacy.

If you do not wish for your Personal Data to be collected via cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser.

D. Other

OTHER

1. Links to Third-Party Websites

The Websites may contain links to third parties’ websites. Please note that VTrade is not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information directly to such sites, the privacy policy and terms of service on those sites are applicable and VTrade is not responsible for the information processing practices or privacy policies of such sites.

2. Personal Information from Minors and Other Individuals

As a parent or legal guardian, please do not allow the minor (individuals under 18 (eighteen) years of age) under your care to submit Personal Data to VTrade. In the event that such Personal Data is provided to VTrade, you hereby consent to the processing of the minor’s Personal Data and personally accept and agree to be bound by this Notice and take responsibility for his or her actions.

In some circumstances you may have provided personal data relating to other individuals (such as your spouse, family members or friends) and in such circumstances you represent and warrant that you are authorized to provide their personal data to VTrade and you have obtained their consent for their personal data be processed and used in the manner as set forth in this Notice.

3. Acknowledgement and Consent

By communicating with VTrade, using VTrade services, purchasing products from VTrade or by virtue of your engagement with VTrade, you acknowledge that you have read and understood this Notice and agree and consent to the use, processing and transfer of your Personal Data by VTrade as described in this Notice.

VTrade shall have the right to modify, update or amend the terms of this Notice at any time by placing the updated Notice on the Websites. By continuing to communicate with VTrade, by continuing to use VTrade services, purchasing products from VTrade or by your continued engagement with VTrade following the modifications, updates or amendments to this Notice, such actions shall signify your acceptance of such modifications, updates or amendments.

In the event of any conflict between the English and other language versions, the English version shall prevail.

4. Data Deletion

Upon request, we will delete all of your personal data permanently in our system. However, the transactional data will be kept for accounting purposes as required by the government. Please send your request to vtradevietnam@gmail.com if you wish to delete all of your personal data from VTrade.

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