About DVMS

Personal Data Policy

: About DVMS

DVMS Company Limited (“we” or “us”) respects and is committed to the protection of your personal information and your privacy as presented in our Personal Data Policy herein, and consistent with applicable personal data protection laws in Vietnam, including the Law on Cyber Information Security (Law No. 86/2015/QH13) and the Law on Cyber Security (Law No.24/2018/QH14), and, when enacted as law, the Vietnam Law on Personal Data Protection. If there is any conflict between the English and Vietnamese versions of this Personal Data Policy, the English version shall prevail.

By accessing our website, using any services provided by us, signing up for any products and services provided by us, submitting any information to us, or otherwise showing your agreement thereon, you will be deemed to have agreed and consented to the terms of this Personal Data Policy. This Personal Data Policy supplements but does not supersede nor replace any other consent(s) you may have previously provided to us in respect to your personal data.

Please note that we may amend this Personal Data Policy at any time without prior notice and will notify you of any such amendments via our website. Please check back regularly for updated information on the handling of your personal data. You agree or shall be deemed to agree to be bound by any of such amended, altered, changed or modified Personal Data Policy by continuing to access our website, using any services provided by us, signing up for any products and services provided by us, submitting information to us, or otherwise showing your agreement thereon.

1. Definitions

For the purposes of this Personal Data Policy:

a. “Affiliates” means DVMS Corporation and/or related companies, including their related companies;

b. “channel partner(s)” means distributor(s), dealer(s), authorised service partner(s) and/or business partner(s);

c. “personal data” and “processing” shall have the meaning as set out under the applicable personal data protection laws in Vietnam.

2. Collection of personal data

In the course of your dealings with us, we will request that you provide certain personal data to enable us to enter into transactions with you or to deliver the necessary goods, services and/or communications in connection with such transactions. These are necessary for our business process execution, including delivery of notices, services and/or products, customer or channel partner and/or third party vendor relationship management, new product launches and events, planning purposes in connection with future products, including promotional events with our Affiliates and channel partners.

3. What kind of personal data we collect

In order for us to fulfil one or more of our obligations listed in paragraph 2 herein, we will need to collect relevant personal data from you. The personal data collected by us may include (but is not limited to) the following:

a. Contact information such as your name, date of birth, identification supporting documents (including NRIC or passport number), gender, nationality and race, preferred language, current private address, telephone and/or mobile phone number(s), fax number and email address(es), income range;

b. The status of products and/or services you have acquired from us or have subscribed to;

c. How you use the products and/or services;

d. Your personal interests and preferences to help us tailor offerings on our products and/or services which would suit you best;

e. Information you provide us regarding your marketing preferences or in the course of participating in surveys, competitions, contests, lucky draws orpromotional offers; and/or

f. CCTV or camera visual recordings when you visit our office premises or participate in any of our events.

4. When and how we collect your personal data

We may collect personal data directly from you when you:

a. Communicate with us (for example when you contact us for any enquiries, including by calling our DVMS helpdesk, letters, face-to-face meetings and emails);

b. Submit your information when registering the warranty on your DVMS product either by mail/online;

c. Where you register your interest or subscribe for information on our products and/or service or to our publications (for example newsletters);

d. Participate in any of our surveys, competitions, contests, lucky draws or promotional events or offers;

e. Respond to any marketing materials we send out;

f. Visit our offices;

g. Provide feedback to us (for e.g. via our websites or in hard copy); and/or

h. When you submit your personal data to us for any other reasons.

Other than personal data obtained from you directly (as detailed above), we may also obtain your personal data from third parties we deal with or who are connected with you and from such other sources where you have given your consent for the disclosure of information relating to you, and/or where otherwise lawfully permitted.

If you provide us with any personal data relating to a third party (e.g. information of your spouse, children, parents and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their personal data for the respective purposes.

Please take care when submitting information to us, in particular when completing free text fields or uploading documents and other materials. Some of our services are automated and we may not recognize that you have accidentally provided us with incorrect or sensitive information. You should ensure that all personal data submitted to us is complete, accurate, true and correct.

In order to improve our services to you, we sometimes use automated tracking devices such as a “cookie”. A cookie is a small amount of data that our web server sends to your web browser when you visit certain parts of our website and the use of which is intended to assist our understanding of your interest in our website. We may use the cookies to personalize the content, recommendations, advertisements and communications delivered to you so that they are more relevant to you and your interests. For example, you may see an advertisement for a product that you have recently viewed on our website. Please note that the cookies do not personally identify users although they do identify a user’s browser. You can always choose to disable cookies from being stored on your computer by changing your browser settings. Disabling cookies however, may result in a limited experience of our functionality and services and in some cases may mean that we are unable to provide you with the services, or parts of the services, that you have requested. Some of our business partners whose content is incorporated into or linked to from the website may also use cookies. However, we have no access to or control over these cookies or websites.

5. Purpose of collecting personal data

Personal data you provide will be processed by us for, amongst others, the following purposes as applicable:

a. The delivery of notices, services or products and the marketing of such services or products to you;

b. Such purposes specifically provided for in any particular service or product offered by us;

c. Conducting marketing and customer profiling activities in connection with our services and related products;

d. managing our administrative and business operations and complying with internal policies, procedures, and record keeping;

e. Enabling us to send you information by e-mail, telecommunication means (telephone calls or text messages) or social media about products and services offered by our Affiliates, that we think may interest you;

f. To establish and better manage any business relationship we have with you, including staff training and quality assurance purposes, particularly in relation to our customer relations staff at our call, email and other support centres, and to analyze, investigate, handle, or resolve any security matters or any vulnerability;

g. To process any communication you send us (for example, answering any queries and dealing with any customer service complaints and feedbacks);

h. Post-sales services, such as after-sales maintenance (if any) or customer service related matters;

i. Responding to your queries;

j. To provide you with the products and/or services you have requested;

k. To notify you about benefits and changes to the features of our products and/or services;

l. preventing, detecting and investigating crime and analyzing and managing commercial risks; and

m. Any purposes which are reasonably related to the aforesaid.

6. Failure to supply personal data

The failure to supply such personal data as may be needed may:

a. result in us being unable to provide you with the notices, services and/or products requested;

b. affect our ability to effect the necessary processes relating to the supply of our products and/or services;

c. result in us being unable to update you on our latest products, services, promotions, events and/or launches; and/or

d. result in your inability to enter or participate in contest, promotions or redemption activities organised by us.

7. Disclosure of your personal data

Personal data provided to us will generally be kept confidential but you hereby consent and authorise us to provide or disclose your personal data to the following categories of parties:

a. Companies and/or organisations that act as our agents, contractors and/or service providers;

b. Our channel partners and Affiliates for purposes that are related to the purpose for collecting and using your personal information;

c. Other parties in respect of whom you have previously given your express consent;

d. Our auditors, consultants, accountants, lawyers or other financial or professional advisers;

e. Companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions and providing you with products and/or services that you have requested or subscribed for;

f. Marketing and communicating with you in relation to products and services offered by us, our Affiliates, as well as authorised agents; and/or

g. relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority for safety, security and legal compliance.

8. Direct Marketing Where you have given us consent, we may use your personal data to provide you with information about our and/or an Affiliate’s services and/or products, which may be of interest to or benefit you, unless you subsequently withdraw your consent. Please note that we will only disclose your personal data where you have subscribed for particular services of products which require such disclosure and/or where your consent has been obtained.

9. Personal data Integrity

We will take all reasonable steps to make sure that the personal data collected, used or disclosed is accurate, complete, not misleading and up-to-date.

10. Personal data security

We take the security and protection of your personal data very seriously. We will take all reasonable steps to protect the personal data we hold from loss, misuse, modification, unauthorised or accidental access or disclosure, alteration or destruction. We will not keep personal data for longer than is reasonably necessary and will take reasonable steps to destroy or permanently de-identify personal data.

11. Data transfer and sharing

Where we consider it necessary or appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your personal data to another Affiliate within or outside Vietnam, under conditions of confidentiality and similar levels of security safeguards. You consent and agree to our transferring your personal data outside of Vietnam for any of the purposes as listed above.

12. Contacting us - Access and Correction, Withdrawal of Consent

In accordance with applicable personal data protection laws in Vietnam, we may on a written request received by you, provide you with access to your personal data and consider a request for correction or deletion of that data. In such circumstances, please submit your requests to:

Data Protection Officer

DVMS Company Limited

95/2/26 Binh Loi, 13 Ward, District Binh Thanh, Ho Chi Minh City

Tel: (028) 36028937

Alternatively, you may email your requests to info@dvms.vn

By submitting such a request, you confirm that it relates to your own personal data and warrant that where you are submitting this request on behalf of another person, you are authorized by such person to submit such request and to provide his/her information for such purposes. You will indemnify DVMS in respect of any penalties, liabilities, claims, demands, losses and damages as a result of breach of this warranty. You declare that the information provided in and with such request are true in every respect, and agree that such information may be collected, used and disclosed by DVMS Corporation and its Affiliates, and/or third party service providers for the purpose of processing said request and/or in accordance with this Data Protection Policy.

We will use reasonable efforts to comply with your request within 30 days of receiving your duly completed Form and the relevant processing fee.

Please note that in certain situations we may have to withhold access to your personal data, for example where we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event we receive repeated request for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.

If you withdraw your consent to any or all use of your personal data, depending on the nature of your request, we may not be in a position to continue providing our products and services to you. Please be aware that once we receive confirmation of your intention to withdraw your consent, it may take up to 30 days for our withdrawal to be reflected on our database. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the products and services that you hold from us.