VINAHOST COMPANY LIMITED (“VinaHost”) always values the privacy and protection of Customers’ Personal Data. We understand that, through this Personal Data Protection Policy (“Policy”), You will be transparent about the contents related to how we process and protect Your Personal Data in the process of searching, accessing, ordering, registering and using VinaHost’s services to ensure that Personal Data is always private and safe according to the law as well as VinaHost’s security standards. This Policy is a Notice of processing and protecting Personal Data, which may be changed when necessary and the latest updated version will be posted on our official website. Therefore, we recommend that You periodically check the Policy on our Website.

This Policy is an inseparable part of the terms of the Contract, Service Agreement binding the relationship between VinaHost and the Customer

When the Customer accesses and uses the website (including registering for online services), we understand that the Customer fully agrees with the terms of this policy.

ARTICLE 1. DEFINITIONS

In this Policy, the following terms are construed as follows:

1. VinaHost: full name VINAHOST COMPANY LIMITED, Business Registration Certificate No. 0305592294; head office at 351/31 No Trang Long, Ward 13, Binh Thanh District, Ho Chi Minh City, Vietnam.

2. Customer/Customer: is an individual and/or organization providing personal data in the activities of searching, accessing, ordering, registering and using VinaHost’s services, products and goods.

3. Products, goods, services are any products, goods, services provided by VinaHost and/or by VinaHost in cooperation with partners that Customers search for, access, purchase, register to use, use.

4. Personal data: is information in the form of symbols, letters, numbers, images, sounds or similar forms in the electronic environment associated with a specific. Customer or helping to identify a specific Customer. Personal data includes Basic Personal Data and Sensitive Personal Data. (Data information specified in “Decree 13/2023/ND-CP of the Government”

5. Basic personal data is the information specified including:

(a) Surname, middle name and birth name, other names (if any);

(b) Date of birth; date of death or disappearance;

(d) Place of birth, place of birth registration, permanent residence, temporary residence, current residence, hometown, contact address;

(e) Nationality;

(f) Personal image;

(g) Phone number, ID card number, personal identification number, passport number, driver’s license number, license plate number, personal tax code number, social insurance number, health insurance card number;

(h) Marital status;

(i) Information about family relationships (parents, children);

(j) Information information about an individual’s digital account; personal data reflecting activities and history of activities on the Internet;

(k) Other information related to a specific person or helping to identify a specific person that is not Sensitive Personal Data.

(l) Other data according to current legal regulations

6. Sensitive Personal Data is Personal Data related to the privacy of Customers that, when violated, will directly affect the legitimate rights and interests of Customers, including but not limited to the following types of data:

Political views, religious views;
Health status and privacy recorded in medical records, excluding information about blood type;
Information related to racial origin, ethnic origin;
Information about inherited or acquired genetic characteristics of an individual;
Information about physical attributes, biological characteristics of an individual;
Information about sexual life, sexual orientation of an individual;
Data on crimes and criminal acts collected and stored by law enforcement agencies;
Customer information of credit institutions, foreign bank branches, payment intermediary service providers, and other licensed organizations, including: customer identification information as prescribed by law, account information, deposit information, deposit information, transaction information, information on organizations and individuals who are guarantors at credit institutions, bank branches, and payment intermediary service providers;
Data on individual locations identified through location services;
Other personal data as prescribed by law as specific and requiring necessary security measures.

=> Please note that VinaHost does not collect all of the Data Information listed above. Customer data is actively provided by customers to VinaHost in accordance with the registration information for each service category or is directly stored by customers on VinaHost’s service providing servers.

7. Processing Personal Data: is one or more activities affecting Personal Data, such as: collecting, recording, analyzing, confirming, storing, editing, publicizing, combining, accessing, retrieving, withdrawing, encrypting, decrypting, copying, sharing, transmitting, providing, transfer, deletion, destruction of Personal Data or other related actions.
8. Personal Data Processor: is the organization or individual who performs the Processing of Personal Data on behalf of the Personal Data Controller, through a contract or agreement with the Personal Data Controller.
9. Personal Data Processor: is the organization or individual who performs the Processing of Personal Data on behalf of the Personal Data Controller, through a contract or agreement with the Personal Data Controller.
10. VinaHost’s transaction channels: including call center channels, electronic transaction channels (electronic information pages such as https://vinahost.vn/, websites, social networks) and physical transaction channels (VinaHost’s headquarters and transaction branches) or other transaction channels depending on the time provided by VinaHost or authorized to provide to Customers

ARTICLE 2. TYPES OF PERSONAL DATA PROCESSED

Except as otherwise provided in this Policy, the personal data that VinaHost may collect includes basic personal data and sensitive personal data (according to the provisions of Decree 13/2023/ND-CP of the Government on personal data protection) as listed below:

1. Personal data processed includes data that Customers provide to us when searching for, accessing, purchasing, registering to use, using Products, goods, services services and data arising during the process of Customers using our Products, goods and services, specifically as follows:

a. Basic personal data: Full name; Email address; Date of birth; Nationality; CCCD/ID card number/Passport number; Place of origin; Permanent address; Contact address; Bank account and payment/transaction information; Phone number; Position;

b. Sensitive Personal Data: Usage and transaction information, including details about your search history, transactions, advertisements and content displayed, and interactions with the Website or Platform, as well as related products and services, Location Data

c. Data relating to websites or applications: technical data (as described above, including device type, operating system, browser type, browser settings, IP address, language settings, date and time of connection to the website, application usage statistics, application settings, date and time of connection to the application, location data and other technical communications); security login details; usage data, etc.

d. Marketing data: advertising preferences; cookie data; clickstream data; browsing history; responses to direct marketing; and opt-outs from direct marketing.

2. Personal data is processed in accordance with each type of service that VinaHost provides, the data information is collected in accordance with the provisions of the Law.

ARTICLE 3. PURPOSE OF DATA PROCESSING

Personal data under Article 2 above may be processed for the following purposes:

1. Providing Products, goods, and services to Customers under the Contract and performing the rights and obligations of VinaHost in accordance with the law, including but not limited to:

Serving business management activities; operating, exploiting, optimizing the quality of services that VinaHost provides;
Verifying the identity and ensuring the confidentiality of personal information of Customers;
Providing subject information to Vietnamese and international domain name management agencies / domain name registrars in and outside the country where VinaHost provides domain name registration services.
Authentication and implementation of payment transactions; reconciliation, payment; exchange and provide information related to service users, issue VAT invoices according to the regulations of the Ministry of Finance
Provide, activate or verify Products, goods and services that Customers request according to the Request Form/Contract or through VinaHost’s Transaction Channel or other requests of Customers arising during the process of searching, accessing, purchasing, registering to use, using Products, goods and services;
Serve the purpose of contacting, supporting and notifying Customers;
Exercise Customers’ rights related to Personal Data according to the provisions of law, the agreement between Customers and VinaHost;
Perform Customer’s contractual obligations and VinaHost’s obligations to relevant agencies, organizations and individuals according to the provisions of law;
Disclose Customers’ Personal Data according to the provisions of law (to the Public Security Agency, Vietnam Internet Center, dispute resolution);
Perform VinaHost’s obligations regarding inspection, examination, statistics, reporting, finance, accounting and tax;
Perform data security assurance operations; ensure the security of VinaHost’s information system such as backup, reserve, monitoring, resource optimization and protection of customer personal data;
Detect and prevent illegal acts in cyberspace at the request of competent state agencies and legal regulations, including but not limited to: using VinaHost’s services to commit acts that violate the laws of the Socialist Republic of Vietnam and international regulations applicable in Vietnam

2. Support Customers when purchasing and using Products, goods, and services provided by VinaHost under the contract and legal regulations, including:

Processing orders and providing domain name registration services, website content hosting and other services within the scope of VinaHost’s business.
Receiving and responding to inquiries, comments, requests for support, suggestions or complaints related to the provision of services.
Providing information on promotional programs, price lists, sales policies and customer service.

3. Improving the quality of Products, goods and services that VinaHost provides to Customers:

Providing information that Customers have requested or VinaHost believes Customers may find useful, including information on VinaHost’s products and services in accordance with the law;
Managing Customer accounts and Customer Loyalty programs;
Store information, market research, analysis, statistics and other internal management activities to improve Customer experience;
Statistics on the number of visitors to the website and the level of interest in VinaHost’s services
Build marketing campaigns for Products, goods, services and determine how VinaHost can personalize those products, goods and services;
Develop and provide new Products, goods and services that are personalized according to the needs and actual conditions of Customers with effective measurement methods;
Introduce and provide promotional programs for Products, goods, services, incentives, promotions of VinaHost and of VinaHost in cooperation with partners;

4. Provide marketing, advertising, and product introduction services that are suitable for the needs of Customers or that VinaHost believes the Customers are interested in, with the following content, form, and frequency:

Content: Introduce information about products, goods, services, and promotions provided by VinaHost and VinaHost’s partners;
Method: Via advertising messages (SMS, ZNS, etc.), calls, notifications on VinaHost’s Transaction Channels, or other methods as prescribed by law;
Form: Send directly to Customers via devices, electronic means, or other forms on cyberspace as prescribed by law;
Frequency: According to the law on advertising.

5. Provide market research, public opinion polling, and brokerage services;
6. Organize trade introductions and promotions;

ARTICLE 4. DATA PROCESSING METHOD

1. Method of collection

Personal data is collected directly from you in the following cases:

From VinaHost’s electronic information pages: We may collect Personal Data when you visit any VinaHost electronic information page via the official website. When customers visit the Electronic Information Page, VinaHost collects information about the customer’s device and browser.
When customers register to purchase services / products at VinaHost (including online and direct transactions): provide information according to the regulations corresponding to each type of service.
When Customers submit their personal information to VinaHost for any other reason, including when Customers register for a free trial of any products and services or when Customers express interest in any products and services of VinaHost
From exchanges and communications with Customers: We may collect Personal Data through interactions between Us and Customers (in person, by mail, telephone, online, switchboard system, electronic communication or any other means) including Customer surveys;
From recording and video recording devices located at VinaHost’s headquarters and transaction branches. The placement of recording and video recording devices is intended to contribute to protecting social order and safety, protecting the legitimate rights and interests of Customers and VinaHost in accordance with the law;

2. Storage method

Personal data will be stored and processed in whole or in part in Vietnam. If you access VinaHost’s website from countries other than Vietnam, using this website means agreeing to transfer your data out of the country and to Vietnam.

3. How to transfer/share data

We will use necessary security measures to ensure the transfer/sharing of your Personal Data to individuals/organizations participating in the Personal Data Processing process specified in Article 8 of this Policy); or competent state agencies, ensuring information security, no data disclosure, and requiring the parties receiving Personal Data to have data security measures.

4 .How to analyze

Personal Data analysis is carried out according to VinaHost’s internal processes. We always have a strict monitoring mechanism for each data analysis process, including checking compliance with legal requirements on data security, ensuring information security for information technology systems before conducting analysis. We also have strict rules to ensure that personal information is anonymised or de-identified at the appropriate stage of processing.

5. How it is encrypted

Personal data collected is encrypted according to standards appropriate encryption when necessary during the storage or transfer of data, to ensure that the data is protected, authenticated, intact and cannot be changed after it has been sent.

6. How to delete data

When you stop using VinaHost’s Products, goods and services and have a valid request, we will proceed to delete Personal Data with all Personal Data that you have provided and/or we have collected during your use of the Products, goods and services, except where otherwise provided by law and in some cases where it cannot be done as follows:

The law does not allow data deletion or requires mandatory data storage;
Personal data is processed by a competent state agency for the purpose of serving the activities of the state agency in accordance with the provisions of law;
Personal data has been made public in accordance with the provisions of law;
Personal data is processed to serve legal requirements, scientific research, statistics according to legal regulations;
In case of emergency regarding national defense, national security, social order and safety, major disasters, dangerous epidemics; when there is a threat to national security and defense but not to the extent of declaring a state of emergency; preventing and combating riots, terrorism, preventing and combating crimes and violations of the law;
Responding to emergency situations that threaten the life, health or safety of Customers or other individuals

ARTICLE 5. PRINCIPLES OF DATA SECURITY OF VINAHOST

1. Your personal data is kept confidential according to this Policy and legal regulations.
2. VinaHost commits to making every effort to implement measures to protect customer information and data within its capabilities, including:

Using encrypted Internet transmission protocols with digital certificates (SSL).
Protecting servers storing customer information and data with multi-layer access authorization and authentication.
Authenticate access or edit customer information using other measures in case of no direct access via the Internet.

Payment transactions by International Cards, Domestic Cards (internet banking), and E-Wallets ensure compliance with the security standards of payment gateway providers, including:

All Customer information will be protected throughout the transaction process using SSL protocol (Secure Sockets Layer).
Encryption standards up to 128 bits.
Comply with the principles and regulations on information security in the banking and finance sector as prescribed by the State Bank of Vietnam.

3. VinaHost’s online payment information security policy applies to Customers:

VinaHost only stores the Token string encrypted by payment gateway providers when Customers make online payments (Direct Payment, Pay Token or Automatic Renewal) on VinaHost’s website system. VinaHost will not directly store information related to Customers’ card information on the system. The security of Customers’ payment card information is performed by payment gateway providers.

ARTICLE 6. CONSEQUENCES, POSSIBLE UNWANTED DAMAGES

1. We use many different information security technologies such as: international standards PCI, SSL, firewalls, encryption… to protect and prevent your Personal Data from being accessed, used or shared unintentionally. However, no data can be completely secure. Therefore, we cannot guarantee absolute security of your Personal Data in some cases such as:

Hardware or software errors during data processing that cause loss of Customer data;
Security vulnerabilities beyond our control, the system is hacked and data is leaked.

2. VinaHost is not responsible for incidents related to customer information security or customer data arising from causes beyond VinaHost’s control, including but not limited to customers revealing their passwords or being attacked through other methods unrelated to VinaHost’s services.

3. You need to be aware that at any time you disclose and make public your Personal Data, that data may be collected and used by others for purposes beyond your and our control.

4. We recommend that you keep your personal devices (phones, tablets, personal computers, etc.) safe during use; you should log out of your account when not in use.

5. In the event that the data storage server is attacked, resulting in the loss, disclosure, or leakage of Customer Personal Data, VinaHost will be responsible for notifying the authorities to promptly investigate and handle the incident and notify you in accordance with the law.

6. The cyberspace is not a safe environment and we cannot absolutely guarantee that your Personal Data shared via the cyberspace will always be secure. When you transmit Personal Data via the cyberspace, you should only use systems that secure system to access the website, application or device. You are responsible for keeping your access credentials for each website, application or device secure and confidential.

ARTICLE 7. START AND END OF PERSONAL DATA PROCESSING

1. Personal Data is processed from the moment we receive the Personal Data provided by you and we have an appropriate legal basis for processing the data in accordance with the law.
2. To the extent permitted by law, Personal Data will be processed until the purposes of data processing have been fulfilled.
3. We may have to store your Personal Data even after the contract between you and VinaHost has terminated to fulfill our legal obligations in accordance with the law and/or the request of competent state agencies.

ARTICLE 8. ORGANIZATIONS AND INDIVIDUALS PARTICIPATING IN THE PROCESS OF PERSONAL DATA

1. Depending on each case, we may be the Personal Data Controller or the Personal Data Controller and Processor.

2. To the extent permitted by law, VinaHost commits not to provide customer contact information to third parties, except in cases notified to customers as follows:

Vietnam Internet Center – VNNIC.
International domain name management agencies for the purpose of initiating, maintaining and managing domain name registration activities for VinaHost.
VinaHost’s professional advisors such as auditors, lawyers, etc. as prescribed by law.
Courts, competent state agencies in accordance with the provisions of law and/or when required and permitted by law
Any individual or organization that is a representative or authorized party of the Customer, acting on behalf of the Customer;
Payment service providers based on the authorization or consent of the Customer;

Data sharing will be carried out in accordance with the order, manner and current legal regulations. The parties receiving Personal Data are obliged to keep your Personal Data confidential in accordance with this Policy; VinaHost’s regulations, procedures, standards on Personal Data Protection and current legal regulations.

3. In the event of the participation of other personal data processing organizations as stated in this Article, the Customer agrees that VinaHost will notify the Customer before VinaHost performs.

4. We may share your information with competent state agencies when performing the purpose of processing Personal Data stated in Article 3 of this Policy in accordance with the law.

ARTICLE 9. PROCESSING PERSONAL DATA IN SOME SPECIAL CASES

VinaHost ensures that the processing of Customer’s personal data fully meets the requirements of the Law in the following special cases:

Video footage from surveillance cameras (CCTV), in specific cases, may also be used for the following purposes:

for quality assurance purposes;
for public security and labor safety purposes;
detect and prevent suspicious, inappropriate or unauthorized use of the Company’s utilities, products, services and/or facilities;
detect and prevent criminal acts; and/or
conduct investigations into incidents.

– Our services are not intended for children under the age of 13. We do not knowingly collect or maintain any personal data or non-personally identifiable information from anyone under the age of 13, nor is any part of our platform or other services intended for children under the age of 13. Parents or guardians of children under the age of 13 are requested to monitor and ensure that the personal information of the child under the age of 13 under their care is not disclosed to VinaHost. In the event that the personal information of a child under the age of 13 under your care is provided to VinaHost, the parent or guardian consents to the processing of the child’s information and agrees to be bound by this Policy on behalf of the child under the age of 13. We will block any account used solely by such children and will remove and/or delete any personal data that we believe has been submitted by any child under the age of 13.

– In addition to complying with other relevant legal provisions, for the processing of personal data relating to the personal data of a person declared missing/deceased, VinaHost will be required to obtain the consent of one of the relevant persons in accordance with the provisions of current law.

ARTICLE 10. CUSTOMER RIGHTS

You are informed about the processing of your Personal Data, unless otherwise provided by law.
You are entitled to decide on your consent regarding the processing of your Personal Data, unless otherwise provided by law.
You have the right to access to view, edit or request correction of your Personal Data, unless otherwise provided by law. We will correct Personal Data when requested by you or in accordance with specialized legal regulations. In case it is not possible to do so, we will notify you according to the agreement between us.
You have the right to delete or request deletion of your Personal Data in accordance with Clause 6, Article 4 of this Policy.
You have the right to request restriction of the Processing of your Personal Data in accordance with legal provisions. The restriction of data processing will be implemented by us after receiving your request in accordance with the technical conditions permitted, unless otherwise provided by law or by agreement of the parties.
You are informed about the processing of your Personal Data, unless otherwise provided by law. The provision of your Personal Data will be implemented by VinaHost after receiving your request, unless otherwise provided by law.
You have the right to request withdrawal of consent for the processing purposes for which you agreed to allow VinaHost to process, unless otherwise provided by law. Upon receiving the request, VinaHost will notify you of the consequences and damages that may occur when withdrawing your consent. In case your withdrawal of consent affects the performance of the contract between VinaHost and you, VinaHost’s legal obligations, the life, property and rights, and legitimate interests of you, other organizations and individuals, the task of protecting national security and social order and safety, we have the right to restrict, suspend, terminate, or cancel part or all of the contract for the provision of products, goods, and services between VinaHost and the Customer. We do not bear any legal responsibility or compensation for any losses incurred by you in this case.
You have the right to object to VinaHost’s processing of your Personal Data to prevent or limit the disclosure of Personal Data or for other reasons as prescribed by law. We will implement your objection request after receiving the request, unless otherwise provided by law. In case your objection affects the performance of the contract between VinaHost and you, the legal obligations of VinaHost, the life, property and legal rights and interests of you, other organizations and individuals, the task of protecting national security and social order and safety, we have the right to limit, suspend, terminate, or cancel part or all of the contract to provide products, goods and services between VinaHost and the Customer. We will not bear any losses incurred by you in this case.
You have the right to complain, denounce or file a lawsuit in accordance with the law.
You have the right to request compensation for actual damages in accordance with the law if VinaHost violates the regulations on protecting your Personal Data, unless the parties have another agreement or the law provides otherwise.
You have the right to self-defense in accordance with relevant laws, including but not limited to the Civil Code, or request competent agencies and organizations to implement civil rights protection methods such as forcing the termination of the infringement, forcing an apology, public correction, and forcing compensation for damages.
Other rights under this Policy and according to the law.
You can exercise the rights in clauses 1, 2, 3, 4, 5, 6, 7, 8, 9 10, 11, 12 of this Article by accessing the website https://vinahost.vn or calling the hotline 1900.6046 or sending an email to cskh@vinahost.vn or other methods according to the law and VinaHost’s regulations at each time. VinaHost can verify the necessary information from customers to carry out the customer’s requests.

ARTICLE 11. CUSTOMER OBLIGATIONS

Comply with the laws and regulations of VinaHost related to the processing of your Personal Data.
Provide complete, honest and accurate Personal Data and other information as required by VinaHost when searching, accessing, purchasing, registering to use and using Products, goods and services and when there are changes to this information. We will proceed to secure your Personal Data based on the information you have provided. Therefore, if there is any incorrect information, we will not be responsible in case that information affects or limits your rights. In case of no notification, if there is any risk or loss, you are responsible for any errors or acts of exploitation or fraud when using
Products, goods and services due to your fault or failure to provide correct, complete, accurate and timely information changes; including financial losses and costs arising from incorrect or inconsistent information provided.
Cooperate with us, competent state agencies or third parties in case of issues arising that affect the security of your Personal Data.
Self-protection of your Personal Data You proactively apply measures to protect your Personal Data during the use of VinaHost’s Products, goods and services; promptly notify us when you discover errors or mistakes in Personal Data or suspect that Personal Data is being violated.
Respect, protect the Personal Data of others.
Be responsible for the information and data that you create and provide on the Internet; be responsible in case your Personal Data is leaked or violated due to your fault.
Regularly update the regulations and policies related to the protection and processing of VinaHost’s Personal Data in each period notified to you via VinaHost’s Transaction Channel.
Other obligations according to the law.

ARTICLE 12. PROCESSING PERSONAL DATA WITHOUT THE CONSENT OF THE DATA SUBJECT

According to the provisions of law, VinaHost may process Personal Data without the consent of the Data Subject in the following cases:

In case of emergency, it is necessary to immediately process relevant Personal Data to protect the life and health of customers or others.
Personal Data is required to be made public according to the provisions of law.
Serving the activities of state agencies as prescribed by specialized laws.
Serving the data processing of competent state agencies in case of emergency regarding national defense, national security, social order and safety, major disasters, dangerous epidemics; when there is a threat to national security and defense but not to the extent of declaring a state of emergency; prevent and combat riots, terrorism, prevent and combat crimes and violations of the law as prescribed by law.
Perform contractual obligations of the Customer with relevant agencies, organizations and individuals as prescribed by law. During the process of VinaHost providing products and services to customers under Contracts, Policies and other agreements, VinaHost is required to disclose Customer Personal Data to competent state agencies or relevant third parties in the following cases:
- To provide services or products as requested or needed to process Customer orders (for example: domain name registration, dispute resolution, etc.);
- Perform obligations to provide personal information as requested by competent state agencies or as prescribed by law;
- To protect us and other third parties: We only provide account information and other personal information when we are confident that providing such information is in accordance with the law, protecting the rights and property of you and other third parties.

ARTICLE 13. GENERAL TERMS

1. This Policy is a Notice of Personal Data Processing in accordance with current legal regulations.

2. This Policy is effective from July 1, 2023. Customers understand and agree that this Policy may be amended from time to time and does not necessarily need to be notified to Customers and publicly announced on the website https://vinahost.vn. Customers’ continued use of the service after the notice period of amendments and supplements in each period means that Customers have accepted such amendments and supplements.

3. The Customer has clearly understood and agreed that this Policy is also the Notice of Personal Data Processing stipulated in Article 13 of Decree 13/ND-CP/2023 and is amended and supplemented in each period before VinaHost proceeds to Process Personal Data. Accordingly, VinaHost does not need to take any other measures for the purpose of notifying the Customer of the Processing of Personal Data.

4. The Customer commits to strictly comply with the provisions of this Policy. For issues that have not been regulated, the Parties agree to comply with the provisions of law, instructions of competent State agencies and/or amendments and supplements to this Policy notified to the Customer by VinaHost in each period.

5.Customers may see advertisements or other content on any website, application or device that may link to websites or services of partners, advertisers, sponsors or other third parties.

VinaHost does not control the content or links that appear on third-party websites or services and is not responsible or/and liable for the practices employed by third-party websites or services linked to or from any website, application or device. These websites and services may be subject to the privacy policies and terms of use of the third party.

6.This policy is entered into on the basis of goodwill between VinaHost and the Customer. During the implementation process, if a dispute arises, the Parties will proactively resolve it through negotiation and conciliation. In case of unsuccessful conciliation, the dispute will be brought to the competent People’s Court for settlement in accordance with the provisions of law.

The Customer has carefully read, understood the rights and obligations and agreed to the entire content of this Personal Data Protection Policy.

PERSONAL DATA PROTECTION POLICY