Privacy Policy
PERSONAL DATA PROTECTION POLICY
1. OUR COMMITMENT TO YOUR PRIVACY PROTECTION
· The Grand Ho Tram ("HTP" or "we") fully respects your rights to privacy and utilizes the following practices regarding any information we are provided with or obtain.
· The privacy and security of your information is very important to us. Whether you are visiting our website, using our app, booking a room, or are a member of one of our programs, we want to keep you informed about how we use the information and of your choices in adherence to the principles of privacy, personal data protection, and in compliance with prevailing legal regulations.
· In adherence to the principles of privacy, personal data protection, and in compliance with prevailing legal regulations, this Personal Data Protection Policy ("Policy") elucidates and informs about the specific instances in which HTP undertakes the processing and protection of your personal data during negotiations, contracts, and transactions with HTP.
2. SCOPE OF APPLICATION
· This Policy is intended to be addressed to any Data Subject (as defined below) who has, is, or will be engaged in providing Personal Data to HTP, including but not limited to employees, applicants, customers, and other Data Subjects in connection with organizations and enterprises that are suppliers, service providers, merchants, partners, dealers, financial institutions, competent authorities, and any third parties in connection with HTP's business or any services, or any other third parties from whom HTP receives or to whom HTP provides any services and/or with whom HTP enters into, negotiates, or discusses for or in connection with any transactions or services, and any of their personnel or authorized representatives.
· In this Policy, the following terms shall be construed as follows:
o "The Grand Ho Tram" means Ho Tram Project Company Limited, a company incorporated and operating under the Laws of Vietnam whose registered office is at Ho Tram Hamlet, Ho Tram Commune, Ho Chi Minh City, Vietnam.
o "Affiliates" means specialized departments of HTP, offices, and HTP branches incorporated under the law of Vietnam.
o "Personal Data" refers to digital data or information in other forms that identifies or assists the identification of a specific individual, including: basic personal data and sensitive personal data. Personal data, once de-identified, is no longer considered personal data.
o "Data Subject" refers to an individual reflected in the personal data.
o "Processing of Personal Data" refers to activities impacting personal data, including one or more of the following: collection, analysis, summary, encryption, decryption, modification, deletion, destruction, de-identification, provision, disclosure, transfer of personal data, and other activities impacting personal data.
3. WHAT PERSONAL DATA IS COLLECTED?
· At various times, we may collect your information and/or information of persons accompanying you, including the following:
o Basic Personal Data: refers to personal data reflecting common personal details and background information, frequently used in transactions and social relations, as specified by the Government of Vietnam in the issued list, including:
(i) Full name, middle name, and birth name, other names (if any);
(ii) Date, month, year of birth; date, month, year of death or missing status;
(iii) Gender;
(iv) Place of birth, registered place of birth, registered permanent residence, registered temporary residence, current residence, hometown, contact address;
(v) Nationality;
(vi) Personal image;
(vii) Phone number, personal identification number, passport number, driver's license number, vehicle registration number;
(viii) Marital status;
(ix) Information about family relationships (parents, children, spouse);
(x) Information about personal digital accounts;
(xi) Other information associated with or used to identify a specific individual not covered above.
o Sensitive Personal Data: refers to personal data associated with an individual's privacy rights which, if infringed upon, directly affects the legitimate rights and interests of agencies, organizations, and individuals, as specified by the Government of Vietnam in the issued list, including:
(i) Data revealing racial or ethnic origin;
(ii) Views on politics, religion, or belief;
(iii) Information about private life, personal secrets, family secrets;
(iv) Health status;
(v) Biometric data, genetic characteristics;
(vi) Data revealing sexual life or sexual orientation;
(vii) Data on crimes and law violations collected and stored by law enforcement agencies;
(viii) Images of identity cards and citizen identity cards;
(ix) Bank card information (in cases related to payment);
(x) Other personal data required by law to be kept confidential or subject to strict security measures.
· We do not intentionally collect personal data from children or market products and services directly to children. The processing of personal data of a child must have the consent of the child if the child is seven years of age or older, and the consent of their parent(s), guardian(s), or legal representative, except for cases where processing without the consent of the data subject is permitted under current law.
4. WHEN IS YOUR PERSONAL DATA COLLECTED?
Personal data may be collected on a variety of occasions, including:
For Customers:
Resort activities: Booking, checking-in and paying, hotel stays and services provided during a stay; eating/drinking at the hotel bar or restaurant during a stay; requests, complaints, and/or disputes.
Participation in marketing programs or events: Signing up for our marketing/promotion programs; participation in customer surveys; subscription to newsletters to receive offers and promotions via email (upon your subscription).
Transmission of information from third parties: tour operators, travel agencies (online or not), international travel operators...
Internet activities: Connection to our social networks, website, online forms (online reservation, questionnaires...), conversations with chatbot, etc.
Other information you provide to us by filling in forms or by communicating with us, whether in person, by phone, email, online, or otherwise.
For Employees, Applicants:
Application procedures: applying for a position at HTP.
Implementation of probationary agreements or employment agreements.
Transmission of information from third parties: employment service centers, Universities, Colleges or educational organizations, healthcare facilities, medical facilities, tax authorities, social insurance authorities for the purpose of implementing probationary agreements and employment agreements.
Other information you provide to us by filling in forms or by communicating with us, whether in person, by phone, email, online, or otherwise.
For Vendors, advertising service providers:
Implementation of Order Forms/Purchase Orders, Contracts/agreements between the vendor and HTP from time to time, or any other source of information (such as bidding documents, capability profiles, information through brokers, service requests, feedback...).
Transmission of information from third parties: Partners; operators...
Internet activities: Connection to our social networks, website, conversations with chatbot, etc.
Other information you provide to us by filling in forms or by communicating with us, whether in person, by phone, email, online, or otherwise.
5. WHAT PURPOSES ARE YOUR DATA COLLECTED FOR AND HOW LONG DO WE RETAIN IT?
· The purposes of processing your personal data vary according to each data subject. The processing of your personal data commences upon receipt by HTP and concludes upon the fulfillment of all processing purposes as stipulated in this Policy, unless otherwise required by law. The table below sets out why we process your data applicable to each data subject, and the lawful basis for the processing ("Purposes").
· Except for the below circumstances, HTP commits not to disclose your personal data unless either (i) your explicit consent has been granted to HTP, or (ii) HTP is mandated to disclose such information in accordance with legal regulations. Under no circumstances shall HTP exchange, lease, or sell your personal data without your explicit consent under any form.
Data Subject | Purposes | Lawful Basis and Basis of Legitimate Interest |
Customers | Meeting our obligations to our customers | Performance of a contract/agreement with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests in running our business and providing you with the requested products and services. |
Managing the reservation of rooms and accommodation requests, in particular the creation and storage of legal documents in compliance with accounting standards | ||
Managing your stay at the hotel: Managing access to rooms Monitoring your use of services (telephone, bar, pay TV, etc.) | ||
Managing our relationship with customers before, during and after your stay: o Managing the promotion/marketing program o Inputting details into the customer database o Segmentation analysis based on reservation history and customer travel preferences with a view to sending targeted communications. o Predicting and anticipating future customer behaviors. o Developing statistics, commercial scores and carrying out reporting of the same. o Providing contextual data for our marketing tools. o Understanding and managing the preferences of new or repeat customers. o Sending customers newsletters, promotions, travel, hotel or service offers from HTP, or contacting you by telephone subject to your prior consent for direct marketing purposes. | Performance of our contract with you and for the management of your promotion/marketing program with HTP. Necessary for our legitimate interests in promoting and improving our services. Processing based on your prior consent for direct marketing purposes. Customers have the right to refuse to receive promotional information. | |
Improving our services by: o Personalizing your check-in, improving our service experience quality. o Processing your personal data through our customer marketing program in order to carry out marketing operations, promote brands and gain a better understanding of your requirements. o Adapting our products and services to better meet your requirements. o Customizing the commercial offers and promotional messages we send you. o Informing you of special offers and any new services created by HTP. o Carrying out surveys and analyses of questionnaires and customer comments. o Managing claims/complaints. o Offering you the benefits of our programs. | ||
Use a trusted third party to cross-check, analyze and combine your collected data at the time of booking or during your stay, in order to determine your interests and develop your customer profile, and to allow us to send you personalized offers. | Necessary for our legitimate interests in promoting our services, performing direct marketing activities (upon your direct consent and/or your subscription), and improving our services. | |
Internal management of lists of customers having behaved inappropriately during their stay at the hotel (aggressive and anti-social behavior, non-compliance with safety regulations, theft, damage and vandalism, or payment incidents). Complying with any applicable legislation (e.g. storing accounting documents), managing data subjects' requests regarding their personal data. | Necessary for our legitimate interests in running our business and to prevent fraud and the abuse of our property and staff. Necessary to comply with a legal obligation. | |
Complying with any applicable legislation (e.g. storing accounting documents), managing data subjects' requests regarding their personal data. | Necessary to comply with a legal obligation. | |
Employees, Applicants | Recruitment Execution: Identify, verify identity, collect reference information, conduct due diligence and/or check legal background within the scope required or permitted by current laws; evaluate and assess compatibility with the position applied for; contact for advice, provide and exchange information pertinent to the recruitment. | Performance of our contract with the Employee. Necessary for our legitimate interests in human resource management. Necessary to comply with legal obligations under the law of Vietnam. |
For Recruiters: Only required to provide information serving the Company's recruitment purposes in accordance with the law; the information provided will only be used for recruitment purposes and other purposes as agreed in accordance with the law. The Company will delete or destroy the information provided by applicants in the event of non-recruitment, unless otherwise agreed with the applicants. | ||
Execution of probationary agreements, employment agreements, policies regarding salary payment, allowances, bonuses, and benefits for Employees; execution of courses and training to enhance soft skills or other necessary skills for the execution of probationary agreements and employment agreements. | ||
Management and improvement of recruitment process; retention of potential candidate profiles; compliance with internal and legal regulations; risk control and management; internal investigations. | ||
Fulfillment of tax obligations, social insurance, labor reporting as mandated by law; provision of information upon request by competent state authorities; execution of administrative procedures pertaining to Visas, Work Permits, Temporary Residence Cards (for foreign Employees). | ||
Other necessary purposes to manage HTP's human resources and to execute labor relations, dispute resolution, addressing complaints and claims related to labor in accordance with the law. | ||
Vendors, advertising service providers | Negotiation, bargaining: Identify, verify identity, collect reference information, conduct due diligence within the scope required or permitted by current laws; assess the suitability of the Partner; contact for advice, provide and exchange information related to negotiation. | Performance of our contract with the Vendor. Necessary for our legitimate interests in management. Necessary to comply with legal obligations under the law of Vietnam. |
Contracting, performing Contracts/Agreements, documents, providing goods, products, services. | ||
Manage, improve cooperation processes, implement internal regulations and legal regulations compliance processes, control and manage risks, conduct internal investigations, statistics, and reporting. | ||
Fulfill tax, accounting, auditing obligations, perform related administrative procedures. | ||
Resolve disputes, complaints, lawsuits, and other content as prescribed by law and required by competent authorities. | ||
In the event that the Data Subject is present at The Grand Ho Tram | Audio and video recording via the surveillance camera system at The Grand Ho Tram for the purposes of: (i) ensuring security and safety; (ii) operational management; (iii) service quality control; (iv) prevention, detection, and handling of violations; and (v) serving requests from competent state authorities or other lawful purposes as prescribed by law. | Necessary for HTP's legitimate interests in ensuring security and safety of its property, people, and business operations. Necessary to comply with legal obligations and requirements of competent state authorities under prevailing applicable law. Audio and video data is retained for the period necessary to fulfill the aforementioned purposes, unless otherwise required by law. |
6. METHODS OF PROCESSING YOUR PERSONAL DATA
· Methods: HTP processes your personal data utilizing both automated and manual methodologies. This includes one or more of the following: collection, analysis, summary, encryption, decryption, modification, deletion, destruction, de-identification, provision, disclosure, transfer of personal data, and other activities impacting personal data.
· Data storage: All your personal data will be securely stored in HTP's dedicated database system. Access and usage of this data are strictly limited to authorized individuals and will be used solely for the Purposes in this Policy.
· Data transfer: In the event that your Personal Data requires transfer, storage, or processing outside of Vietnam for one or more of the aforementioned Purposes, HTP will adhere strictly to Article 8 of this Policy and the provisions of the law on personal data protection.
7. ENTITIES PERMITTED TO PROCESS OR PARTICIPATE IN PROCESSING PERSONAL DATA FOR THE ABOVE PURPOSES
· In particular, your personal data shall be shared within HTP — specifically its specialized departments, offices, branches — and with other entities as follows:
o HTP, specialized departments, offices, and branches of HTP.
o Service providers and partners: your personal data may be sent to third parties [IT sub-contractors (including CMC Technology and Solutions Corporation Limited), international call centers, banks, credit card issuers, external lawyers, legal services if applicable, dispatchers, printers, medical facilities, healthcare facilities (for human resources management purposes)] for the aforementioned purposes.
o Local authorities: we may be obligated to send your information to local authorities if this is required by law or as part of an inquiry. We will ensure that any such transfer is carried out in accordance with local regulations.
· You may grant authorization to HTP to transfer personal data to countries where HTP maintains offices, subsidiaries, or affiliates for the aforementioned purposes, all in strict compliance with the law on personal data protection.
8. PROTECTION OF YOUR PERSONAL DATA DURING INTERNATIONAL TRANSFERS
· For the purposes set out in Article 5 of this Policy, we may transfer your personal data to internal or external recipients who may be in countries or regions offering different levels of personal data protection.
· This transfer, if any, is carried out exclusively for the purposes previously mentioned and is done in full adherence to the legal requirements governing personal data protection from time to time.
· Consequently, in addition to implementing this Policy and its stipulated provisions, HTP employs appropriate measures to ensure secure transfer of your personal data to external recipients in countries or regions offering a different level of privacy protection from that in the country or region where the personal data was collected.
9. DATA SECURITY AND POTENTIAL ADVERSE CONSEQUENCES AND DAMAGES IF ANY
· Data security:
o HTP employs robust measures to ensure the secure protection of your personal data.
o HTP shall take appropriate technical, legal, and organizational measures in accordance with applicable legal provisions to protect your personal data against unlawful or accidental destruction, alteration, or loss, misuse, and unauthorized access, modification, or disclosure.
o To this end, we have taken technical measures (such as firewalls) and organizational measures (such as a user ID/password system, means of physical protection, etc.) to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services. Organizational measures ensure the security of the processing.
· Restriction:
o Due to inherent technical limitations, no data transmitted over the internet can be guaranteed to be completely secure. Consequently, while HTP exerts every effort and employs our measures to protect your personal data in accordance with the law, HTP cannot provide an absolute guarantee that the security of your personal data will be entirely free of any incidents.
o As such, HTP cannot be held responsible in the event of unauthorized access to your personal data, or if you voluntarily share information with others, or in the case of hardware/software errors during data processing leading to data loss, security vulnerabilities, or hacking attacks resulting in data disclosure beyond HTP's control.
10. YOUR RIGHTS AND OBLIGATIONS
· Rights: You possess rights in relation to the processing of information as per legal regulations:
o These rights include the right to be informed about personal data processing activities, to give or withhold consent, to request withdrawal of consent for personal data processing, to view, modify, or request modification of personal data, to request provision, deletion, restriction of personal data processing; to submit a request to object to personal data processing, to lodge complaints, denunciations, initiate legal proceedings, request compensation for damages in accordance with law, to request competent authorities or organizations, individuals involved in personal data processing to implement measures and solutions to protect their personal data in accordance with law.
o These rights are applicable except when you and/or HTP are fulfilling obligations through Contracts/agreements/other written forms to meet tax, accounting, auditing obligations, to provide information as required by competent state authorities, or in other cases as stipulated by current legal regulations.
o Please note that certain rights of personal data subjects may be restricted under the law, such as: The right to withdraw consent does not apply to personal data processing that occurred before the data subject requested withdrawal of consent or restriction of processing; the right to request deletion or destruction of personal data may be restricted in the cases prescribed under Article 19 of the Law on Personal Data Protection 2025, or where such deletion or destruction violates Clause 3, Article 4 of the Law on Personal Data Protection 2025; the right to restrict processing may be limited by the Law on Anti-Money Laundering in Vietnam, specifically legal regulations applicable to HTP's business sector and other applicable legal regulations in Vietnam.
· Obligations:
o You are obligated to protect your own personal data; to respect and protect the personal data of others; to provide full and accurate personal data in accordance with the law, under the contract, or when consenting to allow HTP to process your personal data; to comply with the law on personal data protection and participate in the prevention and combating of activities that infringe on personal data.
o In the event that you provide personal data of a third party (such as information of spouse, child and/or parent and/or guardian, friends, beneficiaries, representatives, contact persons, information providers for reference...) to HTP, you acknowledge and ensure that the third party understands the content of this document and consents fully to HTP processing their personal data in accordance with legal regulations. Concurrently, you affirm that HTP is not required to evaluate and bears no responsibility for the approval of the third party in this context.
· Further information:
o In the event that you wish to exercise any of the above rights, please contact our Legal Department directly by emailing [email protected] or writing to the address below:
Ho Tram Project Company Limited
Ho Tram Hamlet, Ho Tram Commune, Ho Chi Minh City, Vietnam
o For security and personal data protection purposes, we will need to verify your identity to fulfill your request. In the event of reasonable doubt regarding your identity, you may be required to submit a copy of an official identity document, such as a Citizen Identity Card or passport, together with your request.
o You may also exercise your rights regarding your personal data stored and processed by our resort. To do so, you need to contact the hotel directly. You will find all the necessary information to contact our resort at www.thegrandhotram.com. If you need any assistance, please contact our Legal Department by emailing [email protected] or writing to the postal address above.
o All requests will be responded to as soon as possible.
11. COOKIES
· When you visit www.thegrandhotram.com, we place a text file called a "cookie" in the browser folder on your computer's hard drive. A cookie is a small piece of information that a website can store in your web browser and then retrieve.
· Cookies cannot be read by any website other than the one that set the cookie. Cookies allow this website to recognize information that you have agreed to provide to this website and help us determine which parts of this website best meet your professional needs.
12. LINKS PROVIDED TO OTHER WEBSITES
· Exclusion of security obligations:
o There may be links to other websites from www.thegrandhotram.com; however, these websites are not controlled by HTP, and we are not responsible for any content on any such website or any loss that you may incur in connection with your use of those websites. You release any and all claims against HTP relating to the inclusion of links to external websites or your use of those websites.
o www.thegrandhotram.com may recommend the services of partners or other companies that you may choose to use during your trip; however, you agree that we are not responsible for any claims of loss that you may incur in connection with your use of those companies and their services. You release any and all claims against HTP relating to your transactions with HTP's vendors or partner companies.
· Governing Law:
o Some states, provinces, and foreign jurisdictions do not allow the exclusion or limitation of implied warranties or liability for certain types of damages. Accordingly, some or all of the above limitations may not apply to you where they are prohibited or superseded by state, provincial, or national provisions.
o The governing law and venue of this Agreement shall be interpreted, construed, and governed by the laws of Vietnam without reference to its conflict of laws provisions and without including the provisions of the United Nations Convention on Contracts for the International Sale of Goods of 1980. The venue for all disputes arising under this Agreement shall be exclusively in the courts of Vietnam, and each party agrees not to contest the personal jurisdiction of such courts.
o No action by HTP other than an express waiver or modification in writing shall be construed as a waiver or modification of any term and condition of this Policy. If any term and condition of this Policy becomes unenforceable, this shall not affect any other term and condition, and each term and condition shall remain in full force and effect to the extent possible.
· Other links:
o Links to other websites — the websites we link to, including but not limited to the websites of subsidiaries and third-party content providers, may have privacy policies and practices different from those disclosed here. We are not responsible for the policies or practices of linked websites and encourage you to familiarize yourself with them.
o Other websites MAY: Connect or link directly from a website to content within www.thegrandhotram.com.
o Other websites MAY NOT: Copy, modify, or display HTP's names, logos, text, or graphics in any way without HTP's express written permission. Material on this page is copyrighted by HTP unless otherwise noted.
o Republish any page/text/image/content of the website www.thegrandhotram.com or use "framing" technology without HTP's express written permission.
13. AMENDMENTS
This Policy may be updated from time to time and the updated version will be posted on our website at www.thegrandhotram.com. Data Subjects should visit our website regularly to check for any modifications.
14. QUESTIONS AND CONTACT
For any questions related to HTP's personal data protection policy, please contact us at the relevant address below:
Ho Tram Project Company Limited
Ho Tram Hamlet, Ho Tram Commune, Ho Chi Minh City, Vietnam
Email: [email protected].
Phone: +84 254 378 8888.
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· Q: What is Personal Data Protection (PDP)?
A: PDP stands for Personal Data Protection, referring to the use of forces, means, and measures by agencies, organizations, and individuals to prevent and combat activities that infringe on personal data. It encompasses policies, procedures, and measures designed to protect the privacy and security of individuals' personal information.
· Q: Why do I need to sign the personal data protection notification?
A: Signing the personal data protection notification is necessary and mandatory before proceeding with personal data processing activities because:
o The purpose of the PDP notification is to protect your privacy rights regarding your personal data. It clarifies and informs about the specific instances in which HTP undertakes the processing and protection of your personal data during negotiations, contracts, and transactions with HTP. It is also HTP's way of demonstrating its commitment to respecting privacy and complying with data protection law. It sets out your rights and obligations, enabling you to acknowledge, control, and exercise your rights when sharing your personal information.
o During the course of HTP's negotiation, contract execution, and service provision to you, HTP needs to collect your personal information. Under current law, when HTP collects basic information such as your name and date of birth (please refer to what information is considered Personal Data in Section 3), HTP must obtain your consent through the PDP notification format. Therefore, signing the PDP notification is required by law to enable HTP to negotiate, enter into contracts, and provide services to you.
· Q: Who is responsible for supervising, regulating, and accessing my data?
A: The supervision, regulation, and access to your personal data typically involves several entities:
o HTP, specialized departments, offices, and branches of HTP.
Service providers and partners: your personal data may be sent to third parties [IT sub-contractors (including Vietnam Data Security Joint Stock Company), international call centers, banks, credit card issuers, external lawyers, legal services if applicable, dispatchers, printers, medical facilities, healthcare facilities (for human resources management purposes)] for the aforementioned purposes.
Local authorities: we may be obligated to send your information to local authorities if this is required by law or as part of an inquiry. We will ensure that any such transfer is carried out in accordance with local regulations.
Additionally, with your authorization, HTP may transfer personal data to countries where HTP maintains offices, subsidiaries, or affiliates for the aforementioned purposes, all in strict compliance with the law on personal data protection.
· Q: What are the consequences if I choose not to sign the personal data protection notification?
A: If you do not sign the personal data protection notification, this may mean that HTP cannot legally negotiate, perform contracts, and provide services to you while protecting your privacy. Furthermore, you cannot acknowledge and exercise control over your personal data during our processing. Please remember that this step is essential for compliance with legal requirements and is primarily to protect your privacy.
· Q: What rights and obligations do I have when signing the personal data protection notification?
A:
· Your rights:
o You have the right to be informed about personal data processing activities, to give or withhold consent, to request withdrawal of consent for personal data processing, to view, modify, or request modification of personal data, to request provision, deletion, restriction of personal data processing; to submit a request to object to personal data processing, to lodge complaints, denunciations, initiate legal proceedings, request compensation for damages in accordance with law, to request competent authorities or organizations, individuals involved in personal data processing to implement measures and solutions to protect your personal data in accordance with law.
o These rights are applicable except when you and/or HTP are fulfilling obligations through Contracts/agreements/other written forms to meet tax, accounting, auditing obligations, to provide information as required by competent state authorities, or in other cases as stipulated by current legal regulations.
o Certain rights of personal data subjects may be restricted under the law, such as: The right to withdraw consent does not apply to personal data processing that occurred before the data subject requested withdrawal of consent or restriction of processing; the right to request deletion or destruction of personal data may be restricted in the cases prescribed under Article 19 of the Law on Personal Data Protection 2025, or where such deletion or destruction violates Clause 3, Article 4 of the Law on Personal Data Protection 2025; the right to restrict processing may be limited by the Law on Anti-Money Laundering in Vietnam, specifically legal regulations applicable to HTP's business sector and other applicable legal regulations in Vietnam.
· Your obligations:
o You are obligated to protect your own personal data; to respect and protect the personal data of others; to provide full and accurate personal data in accordance with the law, under the contract, or when consenting to allow HTP to process your personal data; to comply with the law on personal data protection and participate in the prevention and combating of activities that infringe on personal data.
o If you provide personal data of a third party to HTP, you acknowledge and ensure that the third party understands the content of this document and consents fully to HTP processing their personal data in accordance with legal regulations. Concurrently, you affirm that HTP is not required to evaluate and bears no responsibility for the approval of the third party in this context.
· Q: Can I withdraw or modify my personal data after it has been provided?
A:
· You may withdraw or modify the information after it has been provided.
· In the case of withdrawal, please note that:
Your withdrawal of consent will not affect the legality of the data processing that was consented to before the withdrawal of consent.
o Your request to withdraw consent must be expressed in a form that can be printed and reproduced in writing. To withdraw your consent, please contact us at the relevant address below for further guidance:
Ho Tram Project Company Limited
Ho Tram Hamlet, Ho Tram Commune, Ho Chi Minh City, Vietnam
Email: [email protected].
Phone: +84 254 378 8888.
· In the event that certain rights of personal data subjects under the law — such as the right to withdraw consent, the right to delete personal data, and the right to restrict processing — may be restricted under the Law on Personal Data Protection 2025, the Law on Anti-Money Laundering in Vietnam, specific legal regulations applicable to HTP's business sector, and other applicable legal regulations in Vietnam, there may be certain circumstances in which such rights are limited even though you generally have the right to withdraw or modify information.
· Q: Can I request HTP to provide back the personal data I previously provided to HTP?
A: Yes, you have the right to request HTP to provide the personal data that you previously provided.
· Q: Is HTP permitted to use my personal data and images for brand advertising and financial gain without my consent?
A: Except for the purposes mentioned in this Policy, HTP commits not to disclose your personal data unless (i) your explicit consent has been granted to HTP, or (ii) HTP is authorized to disclose such information in accordance with legal regulations. Under no circumstances shall HTP exchange, lease, or sell your personal data without your explicit consent under any form.
· Q: Does HTP apply security measures to protect my provided personal data?
A: HTP employs robust measures to ensure the secure protection of your personal data, including but not limited to:
· Except for the circumstances mentioned in this Policy, HTP commits not to disclose your personal data unless (i) your explicit consent has been granted to HTP, or (ii) HTP is authorized to disclose such information in accordance with legal regulations.
· Under no circumstances shall HTP exchange, lease, or sell your personal data without your explicit consent under any form.
· HTP will, from time to time, implement appropriate technical, legal, and organizational measures in accordance with applicable legal provisions to protect your personal data against unlawful or accidental destruction, alteration, or loss, misuse, and unauthorized access, modification, or disclosure. To this end, we have taken technical measures (such as firewalls) and organizational measures (such as a user ID/password system, means of physical protection, etc.) to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services.
· Q: What should I do if a violation is detected?
A: If you detect a violation related to personal data protection, here are some steps you can take:
· Document the details: record the specific details of the violation, including the date, time, and any evidence you have; identify which organization or individual is involved.
· Contact HTP at the information below:
Ho Tram Project Company Limited
Ho Tram Hamlet, Ho Tram Commune, Ho Chi Minh City, Vietnam
Email: [email protected].
Phone: +84 254 378 8888
· HTP will investigate the matter and take appropriate action. HTP is committed to handling all violations in accordance with prevailing regulations.
· Q: Who should I contact and where if I need more information?
A: For any questions related to HTP's personal data protection policy, please contact us at the relevant address below:
Ho Tram Project Company Limited
Ho Tram Hamlet, Ho Tram Commune, Ho Chi Minh City, Vietnam
Email: [email protected].
Phone: +84 254 378 8888.
